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1987 OAK RIDGE MODEL CONFERENCE PROCEEDINGS
.•= _ ap Waste Management -^ s 11 I = ^ M ^. Volume I 55 c c -^ c C "^ -C C i_ Part 1 1^ I Bis I*eS
sponsored by * _ I « -2 3 5 S 2 S £ 5 * ^ .31 -E S c-1 ~ The Department of Energy/Oak Ridge Operations ii c S-^ $ 1 2- 3 §•• Research and Waste Management Division and Martin Marietta Energy Systems, Inc.
Prepared by ANALYSAS CORPORATION
Printed by MARTIN MARIETTA ENERGY SYSTEMS, INC. for the U.S. DEPARTMENT OF ENERGY under Contract No. DE-ACC5-840R21400
WSTB CONF-871075—Vol.1-Pt.1 \ DE88 007803 EXECUTIVE STEERING OGMfFFEEE
XANCE J. MEZGA EXECUTIVE STEERING COMMITTEE CHAIRMAN
ED AEHESCHER DR. lARRy JONES PUBLIC RELATIONS - TOURS UNIVERSITY PARTICIPATION
ANNE CAIHOUN CYNTHIA KENERICK AEMENISTRATTVE SUPPORT TECHNICAL PROGRAM CHAIRMAN
KWISE DUNLAP JUDITH IAHBERT CCMMUNHY PARnCIPATION CONFERENCE COC3RDINATOR
KATHRYN FCREES NELSON PRESENTATICW COORDINATOR DDE IiAISON
ROBEKT HHI'lM. IIKY MATIESON ANS TEACHER'S WORKSHOP CONFERENCE COORDINATOR
DR. ROBEST JOII£Y •van BOH EXHIBITS - POSTER SESSIONS EXECUTIVE STEERING CCMMTTTEE CHAIRMAN EMERITUS
TECHNICAL PROGRAM COMOTIEE
CYNTHIA M. KENDRICK CHAIRMAN
GARY D. ODXON MIKE C. SMITH
J. CARROLL DUGGAN IRVIN G. SPEAS
LARRY H. JONES, PhD. DON WILKES J. T. PRILE CM-S1.TK STAFF
OOHFJJKENCE COORDINATORS COORDINATOR Judith Lambert Kathryn Forbes Lucy Matteson SESSION COORDINATORS
Anne Calhcun Kathryn Forbes Kimberly Collirs Sallye Harrell Bat Evans Karla Spence Brenda Huckaby Bob Zerby Carolyn Johnson Rita Morgan Michelle Poore Kathy Penf ro Leanne Smith Joyce Sudderth
OOOKDINfllCR
Kevin Whaley Tim Golden Eddie McCarter John McCarter Ray Mitchell Tan Muncy Gene Rose Ed Trohtoridge Val Valentine
H1WERS OFF-STTE
Anns Calhoun Michelle Poore Kinlaerly Collins Larry Stewart Leanne Smith Kevin Whaley
Kimberly Collins Leanne Smith
IV Oak Ridge Model Conference Proceedings Waste Management Volume I Part 1 TABLE OF CONTENTS PAGE SESSION 1: WASTE MANAGEMENT PLENARY SESSION The Oak Ridge Waste Disposal Strategy Robert C. Sleeman, Department of Energy/Oak Ridge Operations (DOE/ORO) - . . . 3
Environmental Analyses for Proposed Savannah River Plant Waste Management. Actions John R. Jansen, Department of Energy/Savannah River Operations (DOE/SRO) 27
Recommendations Concerning Tennessee's Hazardous Waste Management Policies by a Task Force Representing Generators, Environmentalists, and Other Key Constituencies E. William Colglazier, University of Tennessee .... 43
In Situ Vitrification Demonstration for the Stabilization of Buried Wastes at the Oak Ridge National Laboratory Gary K. Jacobs, Oak Ridge National Laboratory/Martin Marietta Energy Systems, Inc. (ORNL/MMES) 51
Mixed Waste Disposal Facility at the Nevada Test Site Robert L. Dodge, Reynolds Electrical and Engineering Co. , Inc 71
SESSION 2: SITE REMEDIATION RI/FS Planning Activities at Oak Ridge National Laboratory (ORNL) Joseph F. Nemec, Bechtel National, Inc 87
RCRA Land Unit Closures at the Y-12 Plant Sara H. Welch, Y-12/Martiii Marietta Energy Systems, Inc. (Y-12/MMES) 103 ORGDP RCRA Facility Investigation Program: Plans and Content J. L. Haymore, Oak Ridge Gaseous Diffusion Plant/Martin Marietta Energy Systems, Inc. (ORGDP/MMES) . . 147
How Clean is Clean - A Review of Superfund Cleanups Charles F. Baes III, ORNL/MMES 173
Case Study: FUSRAP in New Jersey (1980-1987) James R. Kannard, Bechtel National, Inc. 185
SESSION 3: WASTE MINIMIZATION I Hazardous Waste Minimization Practices Bruce E. Boggs, Engineering-Science, Inc 203
Y-12 Plant Waste Minimization Strategy Michael A. Kane, Y-12/MMES 215
Process for Volume Reduction of Solution Raffinate for the Portsmouth Gaseous Diffusion Plant (PORTS) Roy D. Bundy, ORGDP/MMES 233
The Compaction of Baled Low Level Radioactive Waste H. W. Arrowsmith, Scientific Ecology Group, Inc 265
Environmental Experience and Potential, Using TVA's Coal Gasification Facility Phebus C. Williamson, Tennessee Valley Authority (TVA) . 271
Replacement of Chlorinated Solvents at the Oak Ridge Y-12 Plant L. M. Thompson, Y-12/MMES 291
SESSION 4: ECONOMIC AND SOCIAL ASPECTS OF WASTE MANAGEMENT Charging Generators for Waste Management Costs J. B. Berry, ORNL/MMES 307
Waste Management Facility Acceptance - Some Findings Dr. Brent Sigmon, Science Applications International Corporation (SAIC) 317
VI Permitting and the Public Jo Ann Garrett, International Technology Corporation (IT Corporation) 323
SESSION 5: WASTE MANAGEMENT TRAINING Integrating Waste Management into the Curriculum Dr. Culyer A. Dunbar, Roane State Community College . . . 333
A University Program in Hazardous Chemical and Radioactive Waste Management Frank L. Parker, Vanderbilt University 345
Interpreting the SARA and RCRA Training Requirements W. Michael Moreland, ORNL/MMES 369
vi l FPOM BEST t oOPY Initiative
CONFERENCE ACTIVITIES Exhibitors' Reception, Garden Plaza Hotel
Registration, Garden Plaza Hotel
XI Exhibitors' Reception, Garden Plaza Hotel
Presentation coordination, William G. Pollard Auditorium Poster Sessions, American Museum of Science and Energy
xrn Discussions between Technical Sessions, William G. Pollard Auditorium
Discussions between Technical Sessions, William G. Pollard Auditorium
xiv Exhibit booth, Garden Plaza Hotel
xv Oak Ridge Model Exhibit, Garden Plaza Hotel
Conference Staff
xvi Initiative BEST
WASTE MANAGEMENT SESSIONS PART 1 The Oak Ridge Waste Disposal Strategy
Presented by:
R. C. Sleeman, DOE/ORO THE QftK RIDGE WASTE DISPOSAL STRATEGY R. C. Sleeman, DOE/QRO
The Oak Ridge Operations Office has developed a strategy for the treatment and disposal of hazardous and radioactive waste. The basic philosophy behind the strategy is to detoxify and/or fix waste prior to disposal. Mixed waste will be detoxified to destroy the RCRA component and then handled as a low-level radioactive waste. A program to demonstrate detoxification technologies is underway. Low-level radioactive waste disposal strategies are being developed under the Low-Level Radioactive Waste Disposal Demonstration and Development (LLWDDD) Program. The ultimate goal of LLWDDD is to develop new, environmentally acceptable low-level waste disposal facilities for 0R0. The LLWDDD strategy defines four classes of waste:
1) slightly contaminated radioactive waste, 2) short half-life radioactive waste, 3) long half-life material—primarily uranium, and 4) waste that cannot be disposed of on the Oak Ridge Reservation. Alternative technologies are being evaluated for each waste class. Disposal and treatment demonstrations are being carried out to demonstrate new technologies that will be required to implement the strategy. ORO WASTE MANAGEMENT STRATEGY
BACKGROUND
OVERALL STRATEGY
HAZARDOUS/MIXED WASTE PROGRAM
LOW-LEVEL WASTE DISPOSAL DEVELOPMENT AND DEMONSTRATION PROGRAM
RCS 1087 01.22 BACKGROUND
• MAJOR ORO RADIOACTIVE, MIXED, AND HAZARDOUS WASTE STREAMS
- HAZARDOUS/MIXED INCINERABLES - MIXED WASTE SLUDGES - LOW LEVEL RADIOACTIVE (LLW) SOLIDS - LLW LIQUIDS oo
# PAST PRACTICES
- HAZARDOUS INCINERABLES SHIPPED OFF-SITE AND MIXED INCINERABLES STORED ON-SITE - MIXED WASTE SLUDGES STORED ON-SITE - LLW SOLID DISPOSAL BY SHALLOW LAND BURIAL - LLW LIQUID DISPOSAL BY HYDROFRACTURE
RCS 1087 01.26 ORO WASTE MANAGEMENT STRATEGY HAZARDOUS, MIXED AND RADIOACTIVE WASTE
HAZARDOUS MIXED TSCA STORAGE INCINERABLE INCINERATOR
ASH
MIXED WASTE HAZARDOUS WASTE MIXED WASTE SLUDGES TREATMENT DISPOSAL FACILITIES DELISTED LLW
NEW LLW LLW SOLID IMPROVED LLWDDD WASTE DISPOSAL OPERATION DEMONSTRATIONS FACILITIES I LLW LIQUID TANK SOLIDIFICATION WASTE STORAGE
WMO 0987 03.15 STEPS TO DEVELOPING MIXED WASTE TREATMENT CAPACITY
• IDENTIFY NEEDED TECHNOLOGY DEMONSTRATIONS - REDUCE/ELIMINATE TOXICITY - REDUCE MOBILITY OF HAZARDOUS CONSTITUENTS - IMPROVE WASTE FORM
« PERFORM DEMONSTRATIONS - TRIAL DEMONSTRATION WILL BE PERFORMED NEXT YEAR OF MIXED WASTE FROM PLATING OPERATIONS
• DELIST WASTE FROM DEMONSTRATION PROJECT - TRIAL DELISTING EFFORT UNDERWAY ON FIXED SLUDGE FROM ORGDP SURFACE IMPOUNDMENT
• DEVELOP FULL SCALE FACILITIES BASED ON DEMONSTRATED TECHNOLOGIES
0937 RCS20 LLWDDD STRATEGY
« PERFORMANCE OBJECTIVES
METHODS TO MEET PERFORMANCE OBJECTIVES
# SITE SPECIFIC STRATEGY
PROPOSED WASTE CLASSIFICATION SYSTEM
0987 RCS06 PERFORMANCE OBJECTIVES
PERFORMANCE OBJECTIVE EFFECTIVE DOSE EQUIVALENT (mrem/yr)
RELEASES TO PUBLIC ENVIRONMENT 25
INTRUDER EXPOSURES ro CONTINUOUS 100 SINGLE EVENT 500
WATER RESOURCES TBD
REQUIREMENT FOR REMEDIAL ACTION TBD
0987 RCS07 METHODS TO MEET PERFORMANCE OBJECTIVES
SITE SUITABILITY IS UNCERTAIN - COMPLEX SITE GEOLOGY AND HYDROGEOLOGY DIFFICULT TO CHARACTERIZE AND MODEL
- REGIONS OF UNSTABLE GEOLOGY (STEEP SLOPES AND KARST FORMATIONS)
- REGIONS OF SHALLOW GROUNDWATER
- REGIONS OF GROUNDWATER DISCHARGES TO SURFACE WATER
# ENGINEERED DISPOSAL TECHNOLOGIES TO ASSURE SITE PERFORMANCE - IMPROVED WASTE FORMS
- LEACHATE COLLECTION AND MONITORING
- EFFLUENT/LEACHATE TREATMENT
- ENGINEERED INTRUDER PROTECTION
0987 RCS08 SITE SPECIFIC STRATEGY
« DOSE LIMIT - DESIGN BASIS - 10 mrem/yr - BELOW 10 CFR 61 LIMIT - SITE PERFORMANCE UNCERTAINTIES - MINIMIZES POTENTIAL FOR FUTURE REMEDIAL ACTIONS
INSTITUTIONAL CONTROL PERIOD - 100 YEARS CURRENTLY SPECIFIED BY EPA, NRC, AND DOE - PERIOD OF HAZARD
# INTRUDER PROTECTION
- PROVIDED BY ACCESS CONTROL/WASTE FORM DURING INSTITUTIONAL PERIOD - PROVIDED BY ENGINEERED FEATURES AFTER INSTITUTIONAL PERIOD
RCS I087 01.09 WASTE CLASSIFICATION SYSTEM
CLASS I - NEAR SURFACE BURIAL
• DESIGN BASIS 10 mrem/yi AT TIME OF DISPOSAL
• TECHNOLOGY MEETS STATE REQUIREMENTS FOR INDUSTRIAL LANDFILL »—' in e INSTITUTIONAL PERIOD MEETS STATE REQUIREMENTS
• INTRUDER PROTECTION NOT REQUIRED AFTER INSTITUTIONAL PERIOD
0987 RCS10 WASTE CLASSIFICATION SYSTEM
CLASS II - ENGINEERED DISPOSAL
• DESIGN BASIS 10 mrem/yr AETER INSTITUTIONAL PERIOD
• ENGINEERED EACILITY DESIGNED EOR ZERO DISCHARGE WITH LEACHATE COLLECTION AND MONITORING
CTl
INTRUDER PROTECTION BY ACCESS CONTROL AND ENGINEERED EEATURES
- NONE REQUIRED AETER INSTITUTIONAL PERIOD
TUMULUS DEMONSTRATIONS OPERATIONAL, GCD SILOS DESIGNED
0987 RCS11 WASTE CONTAINER
CONCRETE PAD
DRAIN
DRAIN
87-5995 WMO 0987 13.44
SWSA 6 SITE TUMULUS DISPOSAL H3 FACILITY DEMONSTRATION ROEHL CONST. CO (615) 573-1971
WMO 1087 13.43 20
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•'^. '.•xaww^if4 21 GREATER CONFINEMENT DISPOSAL SILO
MONITORING POINT
BACKFILL
OUTER SHELL SOLIDIFIED WASTE SAMPLE TUBE
SOLIDIFIED WASTE
PERFORATED UNDERDRAIN
RCS 0987 01.17 WASTE CLASSIFICATION SYSTEM
CLASS III - LONG HALF-LIFE DISPOSAL
# DESIGN BASIS 10 mrem/yr
» TREATMENT TO REMOVE SOLUBLE URANIUM - IN SITU FACILITY - PROCESSING FACILITY
INJ
# DISPOSAL OF "CLEAN" RESIDUALS ON-SITE
DISPOSAL OFF-SITE OR STORAGE/RECYCLING ON-SITE OF CONCENTRATED WASTE
INTRUDER PROTECTION BY ENGINEERED FEATURES AFTER INSTITUTIONAL PERIOD
RCS 0987 01. IS IN-SITU TREATMENT/DISPOSAL DEMONSTRATION
COLLECTION WELL
TREATMENT
ENVIRONMENTAL LINER GROUNDWATER MONITORING WELL-
RCS 1087 01.15 24 CLASS III WASTE PROCESSING SYSTEM
CLASS III WASTE
SOLIDS HANDLING AND MAKEUP PREPARATION CHEMICALS ) • I CHEMICAL URANIUM PREPARATION DISSOLVER 1
LIQUID f RECYCLE
SOLIDS LIQUIDS URANIUM DEWATERING RECOVERY
CLASS IV RESIDUAL
f 1 f SHIP \ ON-SITE / OFF-SITE ) DISPOSAL VOR STOREy/ CLASS 1, II, OR III
RCS 0987 01.19 WASTE CLASSIFICATION SYSTEM
CLASS IV - NOT ACCEPTABLE FOR ON-SITE DISPOSAL
SHIP OFF SITE WITH/WITHOUT VOLUME REDUCTION/STABILIZATION
en ¥ « STORE ON-SITE
RCS 0987 01.18 27
Environmental Analyses for Proposed Savannah River Plant Waste Management Actions
Presented by:
John R. Jansen, DOE/SRO 29
ENVIRONMENTAL ANALYSES FOR PROPOSED SAVANNAH RIVER PLANT WASTE MANAGEMENT ACTIONS
John R. Jansen Savannah River Operations Office U. S. Department of Energy
The Savannah River Plant (SRP) has been a major installation of the U. S. Department of Energy (DOE) for the production of nuclear materials for national defense since the 1950's. Previously acceptable industrial activities conducted in support of the SRP mission have resulted in groundwater and soil contamination at some SRP sites. DOE is preparing analyses of the environmental impacts of ongoing and planned waste management activities for hazardous, low-level radioactive, and mixed waste to provide a comprehensive framework within which future waste management activities can be evaluated, especially as these activities relate to the protection of groundwater resources. This paper provides an overview of the analysis techniques, technical documentation, and environmental impact statement being prepared for proposed SRP waste management actions. 31
ENVIRONMENTAL ANALYSES FOR PROPOSED SAVANNAH RIVER PLANT WASTE MANAGEMENT ACTIONS
John R. Jansen Savannah River Operations Office U. S. Department of Energy Aiken, South Carolina
INTRODUCTION
The Savannah River Plant (SRP) has been a major installation of the U. S. Department of Energy (DOE) for the production of nuclear materials for national defense since the 1950's. Previously acceptable industrial activities conducted in support of the SRP mission have resulted in the discharge of hazardous, low-level radioactive, and mixed waste constituents and groundwater and soil contamination at some SRP sites. Ongoing SRP operations will require that decisions be made on clean up/remedial actions at these existing SRP waste sites as well as decisions on the construction of additional waste treatment, storage, and disposal facilities. This paper provides an overview of the DOE environmental impact statement (EIS) which assesses these proposed SRP waste management activities.
DESCRIPTION OF OPERATIONS AND GENERATED WASTE
The primary SRP function is the production of plutonium, tritium, and other special nuclear materials for national defense purposes. Nuclear fuels and targets, together with other reactor components, are manufactured at SRP in the fuel and target fabrication facility for subsequent irradiation in the SRP heavy water moderated and cooled reactors. Reactor products are recovered in the SRP chemical separations areas. Waste from each operations activity (except for some PCB's and solvents) is placed in SRP storage or disposal facilities. Various support facilities, including the Savannah River Laboratory, are also located at SRP.
SRP operations result in the generation of a variety of waste constituents. Wastes are generated during each €uel cycle process and in supporting activities. Hazardous wastes such as spent degreasing solvents are generated during the fabrication of fuel and target elements; low-level radioactive job control wastes are generated during reactor, chemical reprocessing, and laboratory operations; and mixed wastes are generated in laboratories.
One hundred and sixty-eight SRP sites have received wastes. Many of these waste sites (e.g., the sanitary landfill and construction rubble pits and piles) present limited hazards. However, there are 77 sites (Figure 1) which receive or may have received wastes or hazardous and/or low-level radioactive constituents. Most of these 77 waste sites are in or adjacent to an SRP production area. 32
SRP "CRITERIA" WASTE SITES
GEORGIA
0 1 Figure 1. Seals in Miles 33
DESCRIPTION OF PLANNED WASTE MANAGEMENT ACTIONS
As a result of previously acceptable industrial waste management practices conducted at some SRP sites (e.g., the use of seepage basins and the disposal of wastes in other unlined facilities), groundwater and soil in the vicinity of several waste sites have become contaminated with materials such as volatile organics, nitrates, heavy metals (e.g., lead, cadmium, and mercury), pesticides, and radionuclides.
While modifications of previous waste management practices have begun, further actions will be required at some waste sites to ensure continued environmental and human health protection and to comply with applicable groundwater protection requirements such as those of the Resource Conservation and Recovery Act (RCRA) and State of South Carolina requirements. Continued operations and planned remedial actions at other facilities will also require the construction of new waste storage/disposal facilities. In addition, alternatives for the continued management of filtered, deionized reactor disassembly-basin water discharges are being analyzed.
EIS STRATEGY CONCEPTS AND INSTITUTIONAL AND REGULATORY MANDATES
Alternative strategies were developed for modifications of SRP waste management activities for hazardous, low-level radioactive, and mixed wastes to ensure the continued protection of groundwater resources, human health, and the environment. These alternative strategies are assessed in the "Waste Management Activities for Groundwater Protection" EIS.l The alternative modification strategies differ in terms of:
o the concepts and designs proposed for closure/remedial actions at existing waste sites, the construction of new disposal facilities, and the continued discharge of disassembly-basin purge water;
o the degree to which land area dedication is required; and,
o the degree of periodic monitoring and oversight required to ensure that releases from SRP facilities are within applicable standards.
The strategies are reflective of DOE institutional requirements for continued safe, environmentally sound, and cost-effective operations and of legislative and regulatory mandates such as RCRA. For example, RCRA reflects these waste management strategy differences by requiring the owner of a RCRA hazardous waste management site that is releasing waste constituents to remove and control contaminants from the soil, surface water, and groundwater outside the site, or to remove the source of contamination from the site to achieve background levels or acceptable alternate concentration limits. If the owner removes and 34
controls the contaminants in environmental media outside the waste site, the waste site may remain dedicated to waste management; however, long-term monitoring and oversight of the waste site will be required to ensure continued environmental protection.
The long-term monitoring and oversight requirements are also reflective of the choice which must be made between waste disposal or waste storage. The disposal of wastes that retain their hazardous and/or radioactive characteristics requires permanent or long-term dedication and monitoring. Alternatively, the use of storage as a temporary isolation technique implicitly assumes acceptable future alternatives for treatment of stored waste will be developed before ultimate disposal of the waste.
ALTERNATIVE STRATEGIES ANALYZED IN THE EIS
Strategies were developed for analysis in the EIS which coubine concepts for closure actions at existing waste sites, designs and locations for the construction of new storage/disposal facilities, and the continued management of reactor disassembly-basin purge water. The EIS alternative waste management strategies are:
Dedication
Elimination
Combination
Dedication Strategy - Under this strategy, DOE could modify waste management activities to comply with groundwater protection requirements by implementing closure and remedial actions at existing waste sites to control contamination in accordance with applicable standards, establish new disposal facilities, and continue to use seepage basins for the periodic discharge of reactor disassembly-basin purge water.
If implemented, this strategy would require that DOE dedicate for waste management purposes those hazardous and radioactive contaminated areas that could not be returned to public use after a 100-year institutional control period. Releases of hazardous and mixed waste constituents from waste sites would be controlled by implementing closure actions and remedial actions as necessary to control groundwater contaminant plume migration.
Under this strategy, DOE would establish new disposal facilities at SRP. The new facilities would be used to accommodate wastes from ongoing operations, wastes in interim storage, and wastes from ongoing and planned waste treatment facilities (e.g., liquid effluent treatment facility sludges). 35
The periodic discharge of reactor disassembly-basin discharge water Co seepage basins would continue. These basins, which receive the low-level liquid radioactive discharges (principally tritium), allow radioactive decay to occur before the water is discharged to surface water systems. If these basins could not be returned to unrestricted public use after a 100-year control period, they would be dedicated to waste management purposes.
Elimination Strategy - This strategy would allow DOE to modify waste management activities by removing wastes to the extent practicable from all existing waste sites and closing these sites, establishing new retrievable storage facilities, and directly discharging disassembly- basin discharge water to onsite streams or evaporating this discharge water.
Under this strategy, DOE would not dedicate any land for waste management purposes. Hazardous, low-level radioactive, and mixed wastes and contaminated soils would be removed from existing waste sites to the extent practicable. After the 100-year institutional control period, these sites could be used for purposes other than waste management.
DOE would store wastes from ongoing operations and from waste site closure and removal actions in facilities from which they could be retrieved. Hazardous and mixed wastes already in storage would remain in facilities from which they could be retrieved. DOE would continue its research on new waste disposal technologies for the eventual disposal of the stored wastes.
Disassembly-basin purge water could be discharged directly to onsite streams in accordance with applicable permitting requirements. Alternatively, one of several evaporation processes could be used. In either case, the seepage basins now used for the discharge of disassembly-basin purge water would be eliminated and closure and remedial actions undertaken as necessary so that these sites could be used for purposes other than waste management after the 100-year institutional control period.
Combination Strategy - Under this strategy, DOE could modify SRP waste management activities by removing wastes at selected waste sites, establishing a combination of retrievable storage and new disposal facilities, and continuing the discharge of reactor disassembly-basin purge water to seepage basins.
Under this strategy, waste materials and contaminated soil would be removed from selected sites based environmental/health risk evaluations and the cost-effectiveness of these actions. After the 100-year institutional control period, the sites from which waste material had been removed could be used for purposes other than waste management. Sites from which waste material had not been removed would continue to be controlled as necessary or returned to other uses. 36
New SRP storage/disposal facilities would be constructed for wastes from ongoing operations and closure/removal actions at existing waste sites. Hazardous and mixed wastes facilities would be constructed in accordance with applicable regulatory requirements. Some waste disposal facilities would be dedicated for waste management purposes following the end of their operational lifetimes.
Disassembly-basin water discharges to seepage basins would continue. DOE would continue monitoring and modeling activities in the SRP reactor areas to confirm groundwater flow paths and contaminant concentrations. Following the end of the 100-year institutional control period, DOE would determine whether the seepage basin sites could be returned to unrestricted use or remain dedicated to waste management.
ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
The determination of environmental consequences associated with the alternative strategies is based on groundwater monitoring, waste inventory estimations, groundwater and surface water flow and transport modeling, atmospheric contaminant transport modeling, offsite and occupational health effects modeling, ecological impact assessments, and estimates of risk to persons who might live at SRP following the 100-year institutional control period. The EIS provides a comparison of alternative waste management strategies including project-oriented specific actions.
Contaminant migration, fate, exposure, and the resulting risks were assessed for four environmental pathways: groundwater, surface water, atmospheric, and occupational. A simulation model or a group of models was used to calculate, contaminant transport and concentrations, determine dose, and estimate health effects.^
For the groundwater environmental pathway, waste constituents were assumed to migrate to the water table and move to nearby wells (one and 100 meters away) where the water was withdrawn and directly consumed or used to irrigate crops which were then consumed by persons using the well water. Modeling of the groundwater pathway was performed using an analytical model and three-dimensional groundwater numerical flow and transport models. The PATHRAE RAD3 and PATHRAE HAZ4 codes were used at all existing waste sites.
For the surface water environmental pathway, sheet erosion from waste sites, transport of spilled material, and discharges from aquifers to surface streams were calculated using overland flow equations and inputs (of aquifer discharges) from the PATHRAE groundwater modeling. Potential impacts to stream ecology and adjacent wetlands were then estimated for the various EIS options. 37
Estimates of uptake and dose for the groundwater and surface water pathways were determined by combining contaminant concentration equivalent uptake factors and exposure dose factors. The following possible uptakes were modeled: drinking contaminated water, eating contaminated vegetation, drinking contaminated milk, and eating contaminated beef. Occupancy of a house with a basement located on a waste site was also modeled to account for potential direct gamma exposure.
For the atmospheric environmental pathway, modeling considered the inhalation of polluted air, ingestion of contaminated foodstuffs, and eXpO8\ire tO direct gamma radiation. The models utilized were SESOXlP (to estimate the soils contaminant concentration/volatilization as a function of time), MARIAH5 (to estimate suspended dust loading to the air and excavation generated dust loading), and XOQDOQ^ combined with GASPAR? (for atmospheric transport of contaminants and exposure to these contaminants).
Population exposures to contaminants were evaluated using CONEX**, TERREX9, and FOODCHAIN10. CONEX was used to combine XOQDOQ results with population data to estimate inhalation exposures. TERREX and FOODCHAIN were combined with XOQDOQ to estimate population exposures from contaminated foodstuffs. The atmospheric transport codes for radioactive and chemical waste are shown in Figure 2.
For the occupational exposure pathway (i.e., the removal of waste materials from a site), potential worker exposure was estimated based on assumed internal and external exposures. Internal doses from inhalation were assumed for personnel involved in clean up activities; external exposures were assumed for personnel transporting the waste.
The MILENIUM2 code uses a standard box model and the source terms generated by the MARIAH code to calculate unprotected worker doses. The DEGOMH code assumes workers are exposed to an external radiation field at each contaminated area.
Health risk assessments were completed to ensure that residual environmental concentrations of waste constituents did not cause unacceptable health effects.^ Committed effective dose equivalents (mrem/year, 50-year adult exposure level for the year of chronic exposure) were calculated for radionuclides. Daily human doses (the intake of contaminants for all media) were calculated for chemicals. The measures of potential harm were risk conversion factors for radiation exposure, acceptable daily intake for noncarcinogens, and unit carcinogenic risk for carcinogens. Figure 3 illustrates risk assessment components. Atmospheric Transport Codes Radioactive & Hazardous Chemical Waste
RAE Soil or Waste Inventories
Radioactive Gamma Waste Doaknatay Source Terms
DECOM ^XOQDOQ NonRad External ATM I Source Terms co ipGASPAR
MTTnnapafl SutaoaDapoaNon
CONEX TERREXi^ Crop Data
Radioactive ATM Transport • MAXM
ENVIRONMENTAL INFORMATION DOCUMENTS
FIGURE 2 Components of Risk Assessment
GO
UfttimaAvg. DHD
,,__ „ Risk UCRJI Characterization
RADIOACTIVE NON CARCINOGENIC CHEMICAL RISK RISK CARCINOGENIC RISK FIGURE 3 40
SUMMARY
The Department of Energy prepared the "Waste Management Activities for Groundwater Protection, Savannah River Plant" EIS to assess the consequences of the implementation of alternative waste management strategies at SRP. The alternative strategies considered in the EIS are dedication, elimination, and combination. These alternative strategies are based on project-level decisions for closure actions at existing waste sites, the construction of new storage and/or disposal facilities, and the continued discharge of purge water from SRP reactors. The determination of environmental consequences was based on existing data and on impact assessments from modeling studies. The combination strategy as described in the EIS is the Department of Energy's preferred alternative. 41 REFERENCES
1. DOE (U. S. Department of Energy), 1987. Draft Environmental Impact Statement, Waste Management Activities for Groundwater Protection, Savannah River Plant, Aiken, South Carolina, DOE/EIS-0120D, Savannah River Operations Office, Aiken, South Carolina.
2. Stephenson, D. E., C. M. King, B. B. Looney, and M. W. Grant, 1987. Environmental Information Document - Methodology for Predictive Modeling of Environmental Transport and Health Effects for Waste Sites at the Savannah River Plant, DPST-86-710, E. I. du Pont de Nemours and Company, Savannah River Laboratory, Aiken, South Carolina.
3. Merrell, G. B., V. C. Rogers, and M. K. Bollenbacher, 1986. The PATHRAE-RAD Performance Assessment Code for Land Disposal of Radioactive Waste, CORR-86-0400, Report by Rogers and Associates Engineering Corporation for E. I. du Pont de Nemours and Company, Savannah River Laboratory, Aiken, South Carolina.
4. Rogers, V. C., G. B. Merrell, and M. K. Bollenbacher, 1986. The PATHRAE-HAZ Performance Assessment Code for the Land Disposal of Hazardous Chemical Waste, CORR-86-0399, Report by Rogers and Associates Engineering Corporation for E. I. du Pont de Nemours and Company, Savannah River Laboratory, Aiken, South Carolina.
5. Holton, G. A., D. F. Montague, M. P. Johnson, M. D. Mulheim, S. B. Farmer, C. L. Mills, and R. D. Strouse, 1987. Atmospheric Contaminant Transport Analysis and Human Health Risk Assessment of Savannah River Plant Waste Sites, CORR-86-037, Report by JBF Associates, Inc., for E. I. du Pont de Nemours and Company, Savannah River Laboratory, Aiken, South Carolina.
6. Sagendorf, J. F., J. T. Goll, and W. F. Sandusky, 1982. XOQDOQ: Computer Program for Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, NUREG/CR-2919, PNL 4380, Pacific Northwest Laboratory, Richland, Washington.
7. Eckerman, K. F., T. J. Conge1, A. K. Rocklein, and M. J. Pasciak, 1980. User's Guide to GASPAR Code, NUREG-0597, U. S. Nuclear Regulatory Commission, Washington, D. C.
8. Holton, et al., op. cit.
9. Holton, et al., op. cit.
10. Holton, et al., op. cit. 42
REFERENCES (CONT'D)
11. Till, J. E. and R. E. Moore, 1986. DECOM: A Pathway Analysis Approach for Determining Acceptable Levels of Contamination of Radionuclides in Soil, CORR-86-0403, Report by Radiological Assessments Corporation for E. I. du Pont de Nemours and Company, Savannah River Laboratory, Aiken, South Carolina.
12. King, C. M., W. L. Marter, B. B. Looney, and J. B. Pickett, 1987. Environmental Information Document - Methodology and Parameters for Assessing Human tfealth Effects for Waste Sites at the Savannah River Plant, DPST-86-298, E. I. du Pont de Nemours and Company, Savannah River Laboratory, Aiken, South Carolina. 43
Recommendations Concerning Tennessee's Hazardous Waste Management Policies by a Task Force Representing Generators, Environmentalists, and Other Key Constituencies
Presented by:
E. William Coigiazier, University of Tennessee 45
RECOMMENDATIONS CONCERNING TENNESSEE'S HAZARDOUS WASTE MANAGEMENT POLICIES BY A TASK FORCE REPRESENTING GENERATORS, ENVIRONMENTALISTS, AND OTHER KEY CONSTITUENCIES - E. William Colglazier and Mary R. English, Waste Manage- ment Research and Education Institute, The University of Tennessee, Knoxville, TN 37996-0710
The purpose of the Hazardous Waste Communication Workshop was to recom- mend mechanisms for imp.oving communication with the public on key hazardous waste issues in Tennessee. The Task Force was created and sponsored by the Tennessee Department of Health and Environment's Envi- ronmental Policy Group (formerly the Safe Growth Cabinet Council), which has had as two of its charges better water resources management and better hazardous waste management; and by the Waste Management Research and Education Institute, a "center of excellence" at the University of Tennessee.
A steering committee, recommended by the Waste Management Institute and appointed by the Environmental Policy Group, was convened in January 1987 and suggested that a task force of approximately 25 people representing various interests meet together twice for two-day sessions to develop the recommendations. The Task Force included representatives of business, environmental groups, government, local communities, private groups, and universities. The sessions were held in March and May of 1987. As originally envisioned by the steering committee, the workshops were to concentrate on three issues: what message needs to be communicated about hazardous waste in Tennessee, to whom it should be addressed, and how it should be delivered. As these recommendations illustrate, however, mechanisms for involving and listening to the public became a primary focus for the group. The recommendations are given below, and a copy of the complete report is available from the authors.
Recommendation 1: Governor's Roundtable on Hazardous and Solid Wastes
To ensure that Tennessee will have sound policies and plans for hazardous and solid waste management, adequate waste treatment and disposal capacity, and the means to meet the October 1989 deadline for certification of hazardous waste capacity as specified in the 1986 Superfund Amendments and Reauthorization Act, it is recommended that a Governor's Roundtable on Hazardous and Solid Wastes be established. The Roundtable should be composed of two subcommittees, one directed toward hazardous waste issues and one directed toward solid waste issues. Each subcommittee should be composed of from 12 to 15 members representing industry, environmental and public interest organizations, the academic community, and local, state, and federal government.
Each of the Roundtable subcommittees should have the following charges:
(i) To assess the need for waste treatment and disposal within Tennes- see. This needs assessment should include consideration of (a) the 46
adequacy of the data base, (b) the need for waste reduction measures, and (c) the need for integrated planning.
(ii) To examine how many and what types of facilities might be needed over the next 20 years. With respect to hazardous waste, this assessment should include consideration of intrastate and interstate approaches to hazardous waste management.
(iii) To recommend a process for siting needed facilities, including but not limited to recommending siting criteria appropriate to the types of facilities needed. With respect to hazardous waste, a recommendation should also be made about the criteria that should be used by local governments if they choose to exercise their veto power over license applications for storage, treatment, and disposal facilities. (This veto power was extended by ch. 769, Acts of 1986, which amended subsection (g) of T.C.A. ch. 46, sec. 68-46-108, and added subsections (h)-(l)).
In developing its recommendations, the Roundtable should consider (a) the legislative authority needed to implement its recommendations, and (b) the levels of funding needed and their possible sources. With respect to hazardous waste, consideration should be given to possible redirection of the Responsible Waste Disposal Incentive Fund.
The Roundtable should be convened as soon as possible and should report back to the Governor, the Commissioner of Health and Environment, the Commissioner of Economic and Community Development, the Director of State Planning, and the Legislature not later than July 1, 1988 with respect to charges (i) and (ii) and not later than March 1, 1989 with respect to charge (iii), at which time the Roundtable should cease to exist unless it is reauthorized. It should be supported with funds adequate to pay the travel expenses of its members and to hire consultants, facilitators, and other resource personnel as necessary.
The Roundtable subcommittee charged with hazardous waste issues should coordinate with and build upon the findings of the special committee authorized by House Joint Resolution No. 205, whose work is due to be completed by February 1, 1988. (House Joint Resolution No. 205 is reproduced in Appendix C.) The Roundtable was recommended at the second session of the Workshop without knowledge of this resolution's passage, and it appears that the Roundtable1s mandate would be very similar to that of the special committee. Because of this, the Governor and the Legislature may decide that the special committee can handle the addi- tional issues mentioned in this recommendation without creating the Roundtable. If so, the special committee's charter would likely need to be extended beyond February 1988 and be expanded to cover solid waste issues as well.
Recommendation 2: Public Participation in the Hazardous Waste Regulatory Process
To improve opportunities for early public information and participation in Tennessee's RCRA permitting process, it is recommended that DSWM do the following: 47
(i) incorporate a scoping meeting at the beginning of its decision process on any requested hazardous waste facility permit;
(ii) employ a neutral facilitator for all scoping and community meetings;
(iii) announce scoping meetings through articles in local newspapers describing the issues to be discussed; and
(iv) ensure that the local information repository about the proposed permit is opened immediately after the permit application is made and that it contains a copy of that application, together with relevant correspondence.
The addition of a scoping meeting to the permitting process should be incorporated in DSWM's Rules Governing Hazardous Waste Management in Tennessee. A similar approach should be considered for the solid waste permitting process.
The RCRA permitting process currently used by DSWM includes a local information repository, an informal community meeting conducted by a DSWM representative after DSWM completes its review of the license applica- tion, a public comment period, and, if sufficient interest warrants, a public hearing conducted by DSWM. It is recommended that an informal scoping meeting conducted by a neutral facilitator be added early in this process (see Figure 1). The scoping meeting should be held in addition to the community meeting. It should be distinguished from the community meeting in that it should be held prior to the formal permit application and review, as an early forum for information transfer and articulation of community concerns.
The following format should be used for the scoping meeting: (a) The meeting should be opened and facilitated by a disinterested third party (e.g., the League of Women Voters), who would be responsible for main- taining order and direction. (b) A DSWM representative should state the purpose of the meeting, emphasizing that this is a first step for both DSWM and the public in the regulatory process and providing a handout of that process. (c) The applicant should give a full review of the pro- posed project (including a fact sheet handout). This review should include a presentation about siting considerations and alternatives, potential community costs and benefits, etc. as well as a technical description of. the proposed facility. (d) A public discussion period should be conducted by the facilitator, who should reemphasize that the intent of the meeting is to solicit public questions and reactions so that these concerns can be taken into account in the state's evaluation. Written comments to DSWM within two weeks of the meeting also should be encouraged. (e) The meeting should close with a reiteration of the regulatory process and an announcement of the location of the prospective information repository.
Recommendation 3; Superfund Public Involvement Task Force 48
To find ways to ensure that a community affected by a Tennessee Superfund site has early and adequate opportunities for information and involve- ment, it is recommended that a Superfund Public Involvement Task Force be appointed by the Commissioner of Health and Environment. The Task Force should include nine members: two citizens who are experienced on Superfund issues (nominated by the Tennessee Environmental Council); one represen- tative of public interest groups (nominated by the Tennessee Environmen- tal Council); two industrial representatives (nominated by the Tennessee Manufacturers and Taxpayers Association); one city official (nominated by the Tennessee Municipal League); one county official (nominated by Tennessee County Services Association); one environmental contractor; and one representative of the academic community.
The Task Force should be charged with devising and recommending to the Commissioner appropriate public involvement policies and/or regulations for the state's Superfund process. This charge should focus on develop- ing a structure for the Superfund Division's community relations process and for its implementation at state Superfund sites. It should include consideration of when the public should first be informed about a Superfund site; who should have this responsibility; and what information should be conveyed at which points in the Superfund Division's investiga- tory process. Consideration should also be given to ways to improve two-way communication, including information sharing and transfer.
The task force should be supported with funds adequate to pay the travel expenses of its members and to hire a facilitator and other resource personnel as necessary. It should complete its assignment within 90 days of its appointment, at which time it should cease to exist unless it is reauthorized.
As a subsequent charge to the Task Force, the Commissioner should consider extending its responsibilities to include an examination of how Superfund sites should be prioritized and how rigidly that priority list should be followed. For example, one approach would be to have a prioritization method officially adopted by the Solid Waste Disposal Control Board and then applied by the Superfund Division, with variances from the resultant priority list possible only when in accord with policies or regulations that specified permissible emergency circumstances.
Recommendation A: Hazardous Waste Communication -- Techniques, Messages, and Audiences
To improve communication about hazardous waste issues and the comprehen- sive management of hazardous waste in Tennessee, the following is recom- mended :
(i) TDHE should appoint a hazardous waste information officer whose sole responsibility is to target information about hazardous waste to appro- priate groups.
(ii) A Speakers Bureau should be established within TDHE to make avail- able to different groups speakers who are knowledgeable about hazardous waste management in Tennessee. 49 (Hi) Funds for the UT Center for Industrial Services' Hazardous Waste Extension Program should be rest"- to their pre-FY 87 level.
(iv) The possibility of Amnesty Days for household hazardous waste and for small-quantity generators1 waste should be explored, together with the possibility of regional disposal sites for this waste.
(v) A "crisis situation" network should be established to provide speakers and informal consultants for communities affected by hazardous waste management situations.
(vi) Efforts to disseminate information about hazardous waste should incorporate county environmental specialists and the Tennessee Emergency Response Council and Local Emergency Planning Committees mandated by the 1986 Superfund Amendments and Reauthorization Act. In addition, any local advisory boards or assessment committees established as part of a hazardous waste facility siting should be involved in the hazardous waste communication process.
The message to be communicated should emphasize
(i) that the hazardous waste problem is the joint responsibility of all members of our society, since it is a byproduct of our lifestyles;
(ii) that there are many kinds of hazardous wastes, each presenting a different kind of risk;
(iii) that the state has a process for dealing with hazardous waste generation, treatment, and disposal, and the public has a role in this process; and
(iv) that illegal or unwittingly improper treatment or disposal of hazardous wastes imperils the well-being of humans and of the natural environment, leaving a diminished and dangerous legacy for future genera- tions.
People learn best either by exposure to new ideas over long periods of time or on an "as necessary" basis -- not by massive and short-lived public education campaigns. Therefore, public education on hazardous waste should emphasize two avenues: (a) awareness of hazardous waste issues should be incorporated into environmental and public health segments in primary and secondary education; and (b) targeted messages should be directed toward small-quantity generators, household genera- tors, local officials responsible for waste disposal, and the media. The largest investments of time should be put into communicating about hazardous waste when there is an issue at hand; two-way communication in small-group settings should be stressed; and the message communicated should include cost data on the effects of action versus inaction. 50
Proposal idea ^
Informal discussion between business and state regulators-
Decision by business to proceed ^
Business notifies state; state regulatory process begins -p
Scoping meeting, emphasizing general information on the proposed facility and related effects on the community<*
Business files permit application.
State opens local information repository, including permit application and related correspondence-*
State completes its review and makes preliminary decision on permit application^
Community meeting, emphasizing a full review of the state's analysis of the permit application^
Public comment period•
Public hearing to receive public comment held if sufficient demand is evident^
State makes final decision on permit!
Figure 1. Recommended Public Involvement in the RCRA Permitting Process 51
••,/
In Situ Vitrification Demonstration for the Stabilization of Buried Wastes at the Oak Ridge National Laboratory
Presented by:
Gary K. Jacobs, ORNL 53
IN SITU VITRIFICATION DEMONSTRATION FOR THE STABILIZATION OF BURIED WASTES AT THE OAK RIDGE NATIONAL LABORATORY
Gary K. Jacobs, Brian P. Spalding, Environmental Sciences Division, Oak Ridge National Laboratory1, Oak Ridge, Tennessee
J. Gary Carter, Sydney S. Koegler, Process Technology Department, Pacific Northwest Laboratories2, Richland, Washington
ABSTRACT
A demonstration of In Situ Vitrification (ISV) technology for the stabilization of radioactively contaminated soil sites at the Oak Ridge National Laboratory (ORNL) was successfully completed during July 1987. This demonstration is the first application of the ISV process not performed at the Hanford Site, where the technology was developed and patented by Pacific Northwest Laboratory (PNL). The joint ORNL-PNL pilot-scale demonstration was performed on a 3/8-scale trench (2 m deep x 1 m wide x 10 m long) that was constructed to simulate a typical seepage trench used for liquid low-level radioac- tive waste disposal at ORNL from 1951 to 1966. In the ISV process, electrodes are inserted around a volume of contaminated soil, power is applied to the electrodes, and the entire mass is melted from the surface of the soil down through the contaminated zone, thus making a glassy-to-microcrystalline waste form that incorporates the con- taminants. Gases produced during the melting are collected, treated, monitored, and released through an off-gas process trailer. In the ORNL demonstration, a 25-t mass of melted rock approximately 1.2 m thick x 2.1 m wide x 4.9 m long was formed during 110 h of operation that consumed approximately 29 MWh of power. Data obtained on the operational performance of the test and waste-form durability will be used to assess the feasibility of applying the ISV technology to an actual waste trench.
Operated by Martin Marietta Energy Systems, Inc., under contract DE-AC05-840R21400 with the U. S. Department of Energy.
Operated by Battelle for the U. S. Department of Energy under contract DE-AC06-76RL01830. 54
INTRODUCTION
A series of seven seepage pits and trenches (see Fig. 1) were used between 1951 and 1966 for the disposal of approximately 2.5xlO7 gal of liquid radioactive wastes at the Oak Ridge National Laboratory (ORNL). Approximately 200,000 Ci of 90Sr and 600,000 Ci of 137Cs, along with smaller quantities of other fission products, uranium, and transuranium elements, were disposed of in this series of pits and trenches. To facilitate the seepage of liquids, the trenches were constructed on the tops of ridges, were oriented perpendicular to the strike of the bedding of the formation, and were filled with crushed limestone or dolomite (see Fig. 2). As the liquids seeped out, the Cs and Sr remained within, or in close proximity, to the trenches. Cesium is generally irreversibly sorbed by the illite-rich soils at ORNL. Strontium, on the other hand, is poorly sorbed. To reduce the mobility of Sr, the pits and trenches were treated with a highly alkaline solution (NaOH) at the time of disposal. All of the pits and trenches are now covered with asphalt caps to reduce the direct flow of precipitation through the waste. Currently, the pits and trenches do not significantly contribute to surface-water contamina- tion, and most of the Cs and Sr remains in close proximity to the bottom of the pits and trenches. However, the large inventory of 137Cs and 90Sr, the close proximity of the wastes to the surface, and the potential for significant releases in the future necessitates either a long-term site maintenance and monitoring program or some form of remedial action to allow the sites to be permanently decom- missioned.
In Situ Vitrification (ISV) is one possible technology that could be applied to th- pits and trenches (others include grouting and ground densification). ISV, developed and patented by Pacific Norcliwest Laboratory (PNL), involves placing four electrodes in a square array around the contaminated volume of soil, applying power to the electrodes, and melting the entire mass of contaminated soil into in a homogenous and durable glassy-to-microcrystalline waste form. The melting begins at the surface of the soil and progresses downward through the contaminated zone. Gases produced during the high-temperature (1600 to 2000°C) operation are collected through an off-gas hood and scrubbed of possible contaminants in a process trailer. The ISV technology has been extensively tested by PNL at electrode spacings from approximately 0.3 to 6 m. The pits and trenches at ORNL are candidates for vitrification because of their small areal extent and shallow depth (<6 m). The potential for personnel exposure from the high concentrations of 90Sr and 137Cs in the pits and trenches makes an in situ technology highly desirable compared with one that would require excavation of the contaminated zone. 55
ORNL-DWG
M m H ORNL PILOT-SCALE H^
ISV TEST SITE IE]
m ^pMaHM_IH__-____M^H|l ^ 71278^ A w/- W
w :•< i
^^ METERS
i ' ' 0 M 100
Fig. 1. Location of the radioactive liquid-waste disposal pits and trenches at ORNL and the pilot-scale ISV demonstra- tion. 56
ORNL-LR-OWG 62129
3-in. TUBE FOR RADIATION MONITORING • 6-in. PERFORATED METAL PIPE FOR LIQUID SAMPLING
CRUSHED STONE POLYETHYLENE FILM -I. . TO COVER STONE
8-in.OPEN JOINT- . •'-''.J^ DISTRIBUTING PIPE '•'>-!,& (5% SLOPE) ' ::"" ;"
Fig. 2. Construction details of ORNL liquid-waste disposal Trench 7. 57
The pilot-scale demonstration of ISV technology was performed jointly by ORNL and PNL to achieve four main objectives: (1) complete an application of ISV technology away from the Hanford Site to evaluate the feasibility of technology transfer to ORNL, (2) assess the operational performance of ISV for applications in heterogenous, high-carbonate soils and rocks, (3) determine the retention factors (mass in melted soil divided by mass in off-gas) for Cs and Sr under field conditions, and (4) evaluate the durability of the waste form produced in the ORNL s-.cil system. The results from this pilot-scale test will be used to determine the feasibility of applying the ISV technology to an actual waste trench at ORNL.
ISV PROCESS DESCRIPTION
The ISV process as applied to the stabilization of contaminated soils at ORNL involves placing four molybdenum electrodes into a square array of augered holes that bound the contaminated zone. Figure 3 illustrates the sequence of the process. A starter path for electrical current is established by placing a small amount of a mixture of graphite and glass frit between the electrodes on the surface of the soil. Dissipation of power through the starter material creates temperatures high enough to melt a layer of soil, thus establishing a molten, conductive path. This molten zone continues to grow downward and encompass the soil. Less-dense material sometimes creates a layer of rock that floats near the surface of the melt until it is eventually incorporated into the molten mass.
ORNL-DWG 87-15415
Fig 3. Schematic illustration of the ISV operating sequence. 58
At the high temperatures (1600 to 2000°C) created, organic materials pyrolyze, and the pyrolysis products diffuse to the surface and combust. In addition, water vapor and carbon dioxide are released from the soil. The movement of the resultant gases through the raelt can produce some porosity in the final product near the surface of the melt. A hood over the vitrification zone is maintained under a slightly negative pressure to collect off-gases and the small percentage (<0.01 wt%) of particulates that are released with the off-gas from the molten mass. The hood also provides support for the electrodes. The off-gases from the process are collected, treated, and monitored to ensure that only environ- mentally safe levels of potential contaminants are released. The remaining noncombustible materials dissolve or become encapsulated into the molten soil. Thermally induced convective currents within the molten soil help to homogenize the final waste form, which physi- cally resembles natural obsidian or basalt glass.
The principles of ISV are based on developments from work performed at PNL on joule-heated melters for various nuclear waste immobilization projects (Buelt et al. 1979). The joule-heating principle involves internal resistance heating as electrical current passes through the molten media. In ISV, the resistance decreases as the molten mass increases in size. To maintain a power level high enough to continue melting additional soil, the current must be increased. To accomplish the variable current during ISV processing, a power transformer with multiple voltage taps is used. At start-up, the ISV process requires high voltage and low amperage. As the melt progresses and resistance decreases, the lower voltage taps on the power transformer allow increased amperage to be applied to the melt, maintaining a high power level. The process continues until heat losses from the melt approach the energy delivered to the soil via the electrodes or until power is discontinued to the electrodes.
PILOT-SCALE TEST SYSTEM
The pilot-scale test system at ORNL used four electrodes having a 1.2-m separation and consists of a power-control unit and off-gas containment hood over the test site. A cutaway view of the support trailer and off-gas hood are illustrated in Fig. 4. Prior to the ORNL test, this same system had been used on 11 pilot-scale tests at the Hanford site.
Power-Delivery System
The pilot-scale power system uses a Scott-Tee connection to transform a three-phase input to a two-phase secondary load using diagonally opposed electrodes in a square pattern. The 500-kW power supply may be either voltage or current regulated. The alternating 59
ORNL-DWG87-1S417
OK Gaa Una
500 KVA Tr«n»f<»mw [i
Omim AcquiahtoA STi
Fig. 4. Cutaway view of the pilot-scale process trailer and off- gas hood.
primary current is rated at 480 V, 600 A, 3 phase, and 60 Hz. The three-phase input feeds a Scott-Tee connected transformer (Fig. 5), which provides a two-phase secondary load. The transformer has four separate voltage tap settings of 1000, 650, 430, and 250 V. Each voltage tap has a corresponding amperage rating of 250, 385, 580, and 1000 A per phase, respectively. The amount of three-phase input power delivered to the transformer is controlled by adjusting the conduction angle of the thyristor switches located in each of the three input lines. These switches, in conjunction with selectable taps on the transformer secondary, regulate the amount of power deliverable to both secondary phases. The Scott-Tee connection provides an even power distribution among the three primary phases when the molten zone approaches a uniform resistance load. During the test at ORNL, this power system proved effective in maintaining a balanced load to the electrodes. 60
PRIMARY
50% 86.6% QOOOOiOOOQOl
SECONDARY
SCOTT-TEE CONNECTION
Fig. 5. Scott-Tee electrical connection for the pilot- scale ISV system.
Off-Gas Containment and Electrode-Support Hood
The off-gas containment and electrode-support hood, constructed from seven panels of 20-gauge stainless steel bolted together, is 3.1 m wide, 5.5 m long, and 0.9 m high. Four leveling supports are attached to the corners of the hood, which also has a port for viewing (and access to) the surface of the melt. A central off-gas port allows direct coupling of the hood to the processing trailer and off-gas treatment system. The hood is equipped with heat fins installed on the surfaces of panels to help cool the hood to which radiant heat is transferred from the partially molten surface during processing. The hood, designed to withstand a water vacuum of 18 cm, was sealed to the surface of the soil surrounding the molten zone by means of a flexible skirt of tightly-woven, high-temperature-resis- tant fiber attached to the bottom of all side panels. The skirt extended approximately 0.6 m away from the hood to allow for a hood- to-ground seal when covered with a layer a soil. Electrical bus bars connected to the molybdenum electrodes protrude through the hood; these were surrounded by electrically insulated sleeves that allowed adjustment of the electrode positions. The electrodes and bus bars were supported by insulators above the sleeves. The insulators were designed to withstand movement of the molten mass against the electrodes from convective currents and the gravitational and buoyant forces exerted on the electrodes. 61
Off-Gas Treatment System
The off-gas treatment system is shown schematically in Fig. 6. The off-gas passes through a venturi-ejector scrubber and separator, a Hydro-Sonic scrubber, a separator, a condenser, another separator, a heater, two stages of HEPA filtration, and a blower. Liquid to the two wet scrubbers is supplied by two independent scrub recirculation tanks, each equipped with a pump and heat exchanger. The entire off- gas system has been installed in a 13.7-m-long semitrailer to facilitate transportation (see Fig. 4). All of the off-gas com- ponents except the second-stage HEPA filter and blower are housed within a removable containment module that has gloved access and is maintained under a slightly negative pressure to protect workers from potential contamination. Heat is removed from the off-gas by a closed-loop cooling system consisting of an air/liquid heat ex- changer, a coolant storage tank, and a pump. A 1:1 mixture of water and ethylene glycol is pumped first from the storage tank through the shell side of the condenser and the two scrub-solution heat ex- changers, and then through the air/liquid exchanger, where heat is removed from the coolant.
ORNL-OWG 87-15416
COMTAfNMtttr MOOUlf
Fig. 6. Schematic drawing of the pilot-scale ISV off-gas treatment system.
Hydro-Sonic scrubber is a product of Hydro Sonic Systems, Dallas, Texas. 62
The venturi-ejector scrubber serves both as a quencher and high- energy scrubber. The second scrubber is a two-stage Hydro-Sonic scrubber (tandem nozzle scrubber) as illustrated in Fig. 7. The first section condenses vapors, removes large particles, and ini- tiates growth of the finer particles so that they are easily captured in the second stage. Particles are captured when the gas is mixed with fine water droplets produced by spraying water into the exhaust of the subsonic nozzle. Mixing and droplet growth continue down the length of the mixing tube. Large droplets containing the particles are then removed by a vane separator and drained back into the scrub tank. When operated at a differential pressure of 127 cm of water, the unit is designed to remove over 90% of all particles greater than 0.5 (tm in diameter. Efficiency of removal increases with an increase in pressure differential.
ORNL-DWG 87-15418
GAS iNlt I
MAINTENANCE DBAIN MAINTENANCE FIRST STAGE DRAIN DRAIN
Fig. 7. Tandem Nozzle Hydro-Sonic Scrubber (Hydro Sonic Systems, Dallas, Texas).
Additional water is removed from the gas system by a condenser having a heat exchange area of 8.9 m2 and a final separator. The gases are then reheated to approximately 25°C above the dew point in a 30-kW heater to prevent condensate carryover to the HEPA filters. The first stage of filtration consists of two 61 x 61 x 29 cm HEPA filters in parallel. During operation, one filter is used and the other remains as a backup in case the operating filter becomes loaded. The primary filter can be replaced during operation. The second-stage HEPA filter acts as a backup in case a first-stage filter fails. 63
Test Description
The objectives of the pilot-scale demonstration of ISV technology at ORNL were developed to address key differences between the conditions during previous tests of the ISV technology and those anticipated for contaminated sites at ORNL. For example, the waste trenches at ORNL contain large quantities of 137Cs that could volatilize at high temperatures and be carried into the process trailer with the off-gas, resulting in additional operator exposure and excess wastes. Therefore, it was necessary that the retention factor of >10,000 for Cs (Cs in melted soil divided by Cs in off- gas) obtained in engineering-scale tests (Carter et al. 1987) be con- firmed at a larger scale under field conditions. Also, the soils at ORNL are more structurally and chemically heterogenous than those used in previous tests at Hanford. The trench design, with a significant quantity of crushed carbonate rock present, results in a bulk composition of the ISV melt lower in silica and higher in calcium and magnesium than previously studied compositions (Oma et al. 1983). Therefore, the operational performance of the ISV technology as well as the long-term durability of the resulting waste form need to be addressed specifically for sites at ORNL. Some of these issues have been investigated during lab- and engineering-scale tests conducted at PNL during 1985-1986 (Carter et al. 1987). Evaluation of ISV technology on the pilot scale in actual soil at ORNL will provide for more confident scale-up predictions.
Trench 7 (see Figs. 1 and 2) was chosen as a model because of its size, inventory characteristics, and the fact that much charac- terization of the trench has already been accomplished (Olsen et al. 1983). To enable the pilot-scale ISV system to be used, a 3/8-scale model of Trench 7 was constructed in a pristine (i.e., uncontam- inated) portion of ORNL (see Fig. 1). The site, located on top of a ridge in the Maryville Limestone (an interlayered limestone-shale), was chosen for the similarity of its physical and geological charac- teristics to the areas used for seepage disposal in the past at ORNL. After preparation of the site (clearing, leveling, electrical service, etc.), the trench was constructed perpendicular to the strike of the bedding. The 9.2-m-long trench was 1 m wide at the top and tapered to 0.4 m at the bottom. A schematic cross section at the midpoint of the trench is shown in Fig. 8 (see Fig. 10 also). The trench was constructed to a depth of 1.5 m, except for the central section, which was excavated to a depth of 2.5 m to allow for the placement of a vertical array of eight type-K thermocouples (one thermocouple at every 0.31 m depth) for monitoring the depth of the melt. To simulate the contaminated sludge that is present in Trench 7, 526 kg of a mixture of 18 wt% Cs- and 82 wt% Sr-carbonate was placed in the central portion of the trench. These quantities of Cs and Sr were selected to yield a waste form with sufficient concentra- tions of Cs and Sr that their leach characteristics could be 64
CENTRAL CROSS SECTION OF ISV DEMONSTRATKDN TRENCH
MAIN OFF-QAS COLLECTION HOOO
1.5-2-INCH DIAMETER UMESTONE COBBLE
MOISTURE BLOCK THERMOCOUPLE
Fig. 8. Central cross section of the pilot-scale ISV demonstration trench (approximate scale).
determined. The entire trench was then filled from the 0.6- to 1.5-m level with crushed carbonate rock. The upper 0.6 m of the trench was backfilled with original soil. In addition to the array of thermo- couples in the center of the trench, type-K thermocouples were placed at depths of 0.6, 1.2, and 1.5 m along both sides of the trench at distances of 2.1 and 3.1 m from the center of the trench. Three type-R thermocouples, which have a higher maximum operating temperature than type-K thermocouples, were placed in a vertical array at the center of the trench at depths of 0.9, 1.5, and 2 m in an unsuccessful attempt to monitor melt temperatures. Moisture detection cells were placed in the trench at several locations but did not function properly and will not be discussed further. The four molybdenum electrodes (5 cm diameter and 3.7 m long) were placed in graphite sleeves (15 cm O.D.) and placed 1.2 m apart in a square array of augered holes approximately 2.5 m deep. The off-gas hood was then placed over the trench and connected to the off-gas treat- ment system. The electrodes were connected to the power-delivery system. Run data (temperatures, off-gas flow rate and CO and C02 concentrations, electrical parameters, etc.) were recorded every 6 min and logged into a computerized data storage system. Off-gas samples were collected approximately every 2 h (duplicate samples were obtained for analysis at both PNL and ORNL). 65
RESULTS
After one false start on June 26, 1987 (a result of transformer circuitry malfunctions), the ISV test was started on July 15, 1987. The test ran continuously for 110 h until power was shut off on July 19. Soil temperatures and manual probing of the melt with a steel rod confirmed that the desired depth (approximately 2.1 m) of melting had been reached. Final analysis of the test is still in progress — preliminary results and interpretations are presented here.
Figure 9 illustrates key operational parameters as a function of run time. As discussed earlier, the trends of decreasing voltage and increasing amperage during operation are necessary to maintain melting. Tap changes, indicated by the sharp increases in the total power, were made at run times of approximately 10, 20, and 30 h. The total power consumed during the test was approximately 29 MWh. The depths of melting were determined by observing the maximum tempera- ture reached at each thermocouple in the vertical array located at the center of the trench. Upon contact with the melt, type-K thermocouples generally burn out, giving a sharp response on the data-logging system and making depth determinations relatively easy. Based on visual observations of the surface of the soil and tempera- tures recorded by the thermocouples throughout the trench, the final dimensions of the melted mass are approximately 4.9 m long x 2.1 m wide x 1.2 m thick (see Fig. 10). Assuming that approximately 1.2 kWh are required to melt 1 kg of soil at the test site (based on water and C02 content), the estimated mass of soil that was vitrified is 25 t. This power-to-melt conversion factor is an estimate and will be refined through further analysis of the run data and melt characteristics. As of August 28, 1987, the edges of the mass had cooled to temperatures <70cC.
The flow rate of the off-gas at the stack and the concentration of C02 in the off-gas are illustrated in Fig. 11. It is interesting to note that the time (approximately 20 h) of the increase in C02 concentration corresponds to the time that the depth of melting reached 0.6m, where the melt should have first encountered the crushed carbonate rock. Samples of the off-gas scrub solutions are now being analyzed so that the Cs and Sr retention factors can be determined. Samples of the crushed carbonate rock and soil used in the trench, wall-smears from the off-gas conduits, and HEPA filters are also being analyzed for Cs and Sr so that a mass balance for the system can be calculated. Based on results from an engineering-scale (1/12-scale of Trench 7) test (Carter et al. 1987), the retention factors are anticipated to be >10,000 for both Cs and Sr. 66 ORNL-OWG «7-14424 PILOT-SCALE ISV OPERATIONAL PARAMETERS
1UUU
BOO Ul : I 600 s 400 KL 200 \- v -- 0 1 1 50 100 150 50 100 150 RUN TIME (h) RUN TIME (h)
Fig. 9. Voltage, amperage, power, and melt depth as a function of run time. Voltage and amperage are averages of the A and B phases.
The vitrified mass will be cored so that samples of the waste form can be characterized and tested for its durability. Results from the engineering-scale test suggest that the waste form will have a bulk composition (weight percent) approximated by 48% SiO2, 16% A12O3, 16% CaO, 12% MgO, and 5% FeO. Depending on the cooling rate achieved in the pilot-scale mass, the final product may be either a glassy, obsidian-like solid or a cryptocrystalline mixture of mineral phases. Carter et al. (1987) performed heat treatments designed to simulate the slow cooling of a bulk composition similar to that expected in a full-scale test. The resulting product was a microcrystalline mixture of diopside, enstatite, and Al-silicates (likely hosts for Cs and Sr). MCC-1 28-d leach tests on this material resulted in normalized elemental releases of approximately 20 and 4 g/m2 for Cs and Sr, respectively. These values are equal to or lower than values reported for PNL-76-68 glass (a waste form considered for high-level nuclear waste). Values for Si, Ca, and Al are also equal to or lower than those for PNL-76-68 glass. Samples of the pilot-scale waste form will be subjected to a variety of durability and simulated-weathering tests so that the long-term performance of the waste form can be quantified. Results from the off-gas analyses, characterization of the waste form, and durability tests will be used to assess the feasibility of a full-scale applica- tion of ISV to an actual waste trench at ORNL. 67 OUNL-OWO |r-1S40«
REPLACED ORNL SOIL
CRUSHED LIMESTONE
CHEMICAL ADDITION
REPLACED ORNL SOIL
54321 01 3 3 « 5 6
END VIEW LOOK SOUTH TO NOHTH
OBML-DWO •*-!•«)•
OFF-GAS HOOD SOIL , SURFACE
CRUSHED LIMESTONE
CHEMICAL
• '•/«••/• ADOITION '
UNOISTURBEO ORNL SOIL UNDISTURBED ORNL SOIL OPNL _SOIL
/; i i i i i i I i i i i' i i i i I 10 9 8 7 « 5 4 }2 1 0 1 34 587a»'O FEET
SIDE VIEW LOOK WEST TO EAST
Fig. 10. Predicted shape of the pilot-scale ISV mass (overlayed on the original trench dimensions). Solid circles are locations of type-K thermocouples (see dis- cussion on page 12). 68
OFF-GAS FLOW RATE
20 40 60 80 100 120
RUN TIME (H)
CO2 CONCENTRATION (*) :N OFF GAS
20 40 60 80 100 120
RUN TIME (H)
Fig. 11. Flow rate and CO2 content of off-gas from the pilot-scale ISV demonstration. 69
SUMMARY
A demonstration of ISV technology for the stabilization of radioactively contaminated soil sites at ORNL was successfully completed during July 1987. This demonstration is the first applica- tion of the ISV process not performed at the Hanford Site, where the technology was developed and patented by PNL. The joint ORNL-PNL pilot-scale demonstration was performed on a 3/8-scale trench (2 m deep x 1 m wide x 10 m long) that was constructed to simulate a typical seepage trench previously used for liquid low-level radioac- tive waste disposal at ORNL from 1951 to 1966. A 25-t mass of melted rock approximately 1.5m thick x 2.5 m wide x 5 m long was formed during 110 h of operation that consumed approximately 29 MWh of power. Data being obtained on the operational performance of the test and waste-form durability will be used to assess the feasibility of applying the ISV technology to an actual waste trench.
ACKNOWLEDGEMENTS
Staff at ORNL that contributed to the success of the demonstra- tion included C. Abner, C. Brown, C. Bruce, D. Farmer, C. Thomas, R. Thomas, and R. Todd. Staff from PNL who helped to prepare the site and run the test included J. Buelt, K. Eliason, T. Hinkle, M. Longaker, K. Oma, T. Powell, and C. Timmerman. We gratefully acknowledge the help of numerous other persor at ORNL who helped in the preparation of the site. We thank K. L. Von Damm and A. D. Kelmers for their constructive comments that helped to improve this manuscript. Publication No. 3007, Environmental Sciences Division, ORNL. 70
REFERENCES
Buelt, J. L., C. C. Chapman, S. M. Barnes, and R. D. Dierks, 1979. "A Review of Continuous Ceramic-Lined Melters and Associated Experience at PNL," In Ceramics and Nuclear Waste Management, pp. 107-113, CONF-790420, Technical Information Center, Springfield, Virginia.
Carter, J. G., S. O. Bates, and G. D. Maupin, 1987. In Situ Vitrifi- cation of Oak Ridge National Laboratory Soil and Limestone, PNL- 6174, Pacific Northwest Laboratory, Richland, Washington.
Olsen, C. R., P. D. Lowry, S. Y. Lee, I. L. Larsen, and N. H. Cutshall, 1983. Chemical. Geological, and Hydrological Factors Governing Radionuclide Migration from a Formerly Used Seepage Trench: A Field Study. ORNL/TM-8839, Oak Ridge National Laborato- ry, Oak Ridge, Tennessee.
Oma, K. H., D. R. Brown, J. L. Buelt, V. F. FitzPatrick, K. A. Hawley, G. B. Hellinger, B. A. Napier, D. J. Silviera, S. L. Stein, and C. L. Timmerman, 1983. In Situ Vitrification of Transuranic Wastes: Systems Evaluation and Applications Assess- ment. PNL-4800, Pacific Northwest Laboratory, kichland, Washing- ton. Mixed Waste Disposal Facility at the Nevada Test Site
Presented by:
R. L. Dodge, Reynolds Electrical and Engineering Co., Inc. 73
MIXED WASTE DISPOSAL FACULTY AT THE NEVADA TEST SITE - Paul T. Dickman, Science Applications International Corporation, Las Vegas, NV; Eugene W. Kendall, Reynolds Electrical & Engineering Co., Inc., Las Vegas, NV
Background
The Atomic Energy Act (AEA) of 1954 has been the basis for Department of Energy (DOE) self-regulation of radioactive wastes. Under the AEA, the term "by-product material" is defined as any radioactive material generated or made radioactive from the use or production of "special nuc]^ar material" (e.g., plutonium, uranium). Under the "by-products rule," DOE was therefore responsible for self-management and regulation of spent reactor fuel, high-level, low-level, and transuranic wastes, and until 1984, mixed radioactive and hazardous wastes.
In 1984, a law suit brought against DOE by the Legal Environmental Assistance Fund (LEAF) resulted in the requirement that DOE be subject to regulation by the state and U.S. Environmental Protection Agency (EPA) for all hazardous wastes, including mixed wastes. Therefore, all DOE facilities generating, storing, treating, or disposing of mixed wastes will be regulated under the Resource Conservation and Recovery Act (RCRA).
In FY 1985, DOE Headquarters requested DOE low-level waste (LLW) sites to apply for a RCRA Part B Permit to operate radioactive mixed waste facilities. An application for the Nevada Test Site (NTS) was prepared and submitted to the EPA, Region IX in November 1985 for review and approval. At that time, the state of Nevada had not yet received authorization for hazardous wastes nor had they applied for regulatory authority for mixed wastes. A courtesy copy of the application was provided to the state in December 1986 (13 months after submission to EPA) with the assumption that the state would eventually become the regulatory agency for the NTS mixed waste facility.
In October 1986, DOE Nevada Operations Office was informed by the Rocky Flats Plant that some past waste shipments to NTS contained trace quantities of hazardous substances. Under Colorado law, these wastes are defined as mixed. A DOE Headquarters task force was convened by the Under Secretary to investigate the situation. The task force concluded that DOE has a high priority need to develop a permitted mixed waste site and that DOE Nevada Operations Office should develop a "fast track" project to obtain this site and all necessary permits. The task force also concluded that DOE should hold discussions with the state of Nevada.
Status
When NTS applied for a permit, there was no direct involvement by the state of Nevada. A regulatory "limbo" existed as to the state's role because no authority had been granted to the state for mixed wastes. In 74
January 1987, DOE Nevada Operations Office entered into discussions with the state and requested the state to determine if it has authority for mixed wastes. In March, the state informed DOE Nevada Operations Office that they do have regulatory authority and that NTS will be regulated as a "commercial" mixed waste facility subject to disposal taxes and inspection fees.
In June, DOE Headquarters revised the by-products definition under the AEA. The new definition basically states that all radioactive wastes also containing RCRA-listed substances will be dually regulated by both AEA and RCRA. As a result of this change in the definition, DOE Nevada Operations Office submitted new Part A Applications for its defense waste management facilities in an effort to preserve interim status for these sites. The Part A Applications include the 732-acre Radioactive Waste Management Site in Area 5 and the 130-acre bulk waste disposal site in Area 3.
In July, DOE Nevada Operations Office formally submitted the 1985 version of the PCRA Part B Application to the state. At the time of submission, it was stated that NTS intended to revise the application to address issues and waste streams not identified in the 1985 draft. The purpose for submitting the 1985 draft was to establish a basis for discussions between DOE Nevada Operations Office and the state on implementation plans and requirements for mixed wastes at NTS. The Bart B Application was formally submitted to the state on October 1, 1987.
The state has agreed to review the issue of Rocky Flats waste streams and may grant approval for receipt of mixed wastes on a case-by-case basis until the revised Part B Application is submitted.
Issues to be Resolved
NTS is planning a major modification to the NTS Part B Application to incorporate changes resulting from the Rocky Flats problem and the revised by-products definition. Over the next several months, we expect that several issues need to be resolved:
Strategic Alternatives Study: At the direction of the Under Secretary/ DOE prepared a Strategic Alternatives Study (SAS) for management of DOE defense hazardous and mixed wastes. The draft report SAS calls for establishment of three DOE mixed waste disposal sites. Under SAS, the NTS would serve as the western regional site. How SAS will be implemented and its effect on NTS mixed waste plans is not yet defined.
Exemptions Requested: NTS has requested exemptions from the groundwater monitoring and trench liner requirements of RCRA. The state has indicated that it will support the NTS requests, but no assurances can be given that the exemption will be granted nor is their a schedule for determining if or when the requests would be 75
granted. Failure to obtain these exemptions would result in over $2 million in additional design and construction costs for the wriypri waste site and a major modification in the permit application.
Permit conditions: The manner of operation and types of materials to be disposed will be defined in the permit. The conditions of the permit are negotiated between the state and the permittes. The EPA has not yet fully developed health and safety standards applicable to waste disposal and, therefore, operating requirements are determined on a case-by-case basis. NTS has nc assurances that the state will not impose additional restrictions which could impact planned operations and certification procedures.
Mixed Waste Certification Planr.; The critical element in mixed waste facility planning is the permit process. The condition and limitations in the permit will determine the type of operation and acceptable waste materials and forms.
To achieve RCRA requirements, we do not believe any significant changes in disposal operations will be necessary; however, the greatest impact to us and our generators will be in waste characterization and certification.
NTS has prepared a draft of a Mixed Waste Acceptance Criteria (WAC). The WAC addresses the increased sampling, reporting, and quality assurance requirements necessary to meet RCRA. In the past, certification records for low-level wastes were designed primarily for radiological hazards. Under RCRA we will require additional data on chemical content, form, material type, generation source, treatment methods, and packaging and transportation.
The WAC will serve as a focal point for the certification and quality a-ssurance programs. The WAC is currently still in draft form. Wa are awaiting the revisions to DOE Order 5820.2 before firv lizing the WAC.
Conclusion
The NTS mixed waste disposal site is still in the planning stages and progress will be necessarily limited until the revised Part B Application has been accepted by the state of Nevada. Originally, our plans called for having a fully operational and permitted mixed waste site by October 1, 1988. At this time, we believe it is still an achievable schedule, assuming the state approves the Part B in early 1988. The principal difficulty we have encountered has been due to the unfamiliarity of all parties regarding how to proceed. Mixed waste is basically a "new" waste type with dual regulatory requirements. There are no standard procedures for us to follow and therefore each step taken requires careful consultation with all parties involved. The 76 learning process for us, the state, and EPA is necessary and will eventually benefit other DOE facilities. 77
BRIEFING NOTES ON NTS MIXED WASTE ISSUES
ENVIRONMENTAL SCIENCES DEPARTMENT RADIOACTIVE WASTE MANAGEMENT PROJECT 78
NTS LOW-LEVEL WASTE OPERATIONS
AREA 5 PACKAGED WASTE DISPOSED IN EXCAVATED PITS AND TRENCHES. APPROXIMATELY 500,000 CUBIC FEET ANNUALLY RECEIVED FROM 17 DEFENSE GENERATORS. AVERAGE 4-5 TRUCKLOADS PER DAY. OVER 2.5 MILLION CUBIC FEET OF WASTE DISPOSED SINCE 1961. PROVIDE REMOTE HANDLING SYSTEM FOR SHIELDED CASK SHIP- MENTS AND STORAGE SITE FOR LLNL TRANSURANIC WASTES. AREA 3 LANDFILL OPERATION AT U3AXBL SUBSIDENCES. BULK WASTES FROM CLEANUP OF OLD ATMOSPHERIC TEST SITES. APPROXIMATELY 4 MILLION CUBIC FEET DISPOSED. ALSO RECEIVE BULK CONTAMINATED SOILS FROM JOHNSTON ATOLL AND GA TECHNOLOGIES, SAN DIEGO. 79
DOE ANDRCRA
PRIOR TO 1981, DOE'S POSITION WAS TO MEET THE INTENT OF RCRA. EPA AND STATES TO HAVE INPUT, NOT REGULATORY ROLES. IN 1984, DOE LOST LAWSUIT BROUGHT ON BY LEGAL ENVIRONMENTAL ASSISTANCE FOUNDATION (LEAF) AND NATIONAL RESOURCE DEFENSE COUNCIL (NRDC) WITH STATE OF TENNESSEE AS "PLAINTIFF INTERVENER." THE "LEAF DECISION" REQUIRES DOE TO FULLY COMPLY WITH RCRA AND GIVES EPA AND STATES REGULATORY AUTHORITY OVER DOE FOR HAZARDOUS AND MIXED WASTES. IN JUNE 1987, DOE MODIFIES DEFINITION OF "BY-PRODUCT" UNDER ATOMIC ENERGY ACT OF 1954 TO EXCLUDE ALL RADIOACTIVE WASTES ALSO CONTAINING RCRA LISTED SUBSTANCES. NEW BY-PRODUCTS DEFINITION REQUIRES DUAL REGULATION FOR ALL DOE MIXED WASTES. 80
ROCKY FLATS MIXED WASTE PROBLEM
IN OCTOBER 1986, ROCKY FLATS NOTIFIED DOE/NV THAT PAST LLW SHIPMENTS TO NTS CONTAINED TRACE QUANTITIES OF HAZARDOUS MATERIALS. UNDER COLORADO LAW, WASTES MUST BE DECLARED MIXED. THERE- FORE, ROCKY FLATS AND NTS WERE OUT OF COMPLIANCE WITH FEDERAL REGULATIONS. TASK FORCE CONVENED BY UNDER SECRETARY RECOMMENDS ROCKY FLATS CEASE ALL WASTE SHIPMENTS AND NTS "FAST TRACK" DEVELOPMENT OF MIXED WASTE FACILITY. 81
STATE OF NEVADA AND RCRA
EPA REGION IX (SACRAMENTO) IS THE FEDERAL REGULATORY AUTHORITY FOR HAZARDOUS AND MIXED WASTES FOR NEVADA. STATE OF NEVADA HAS BEEN GRANTED AUTHORITY FOR HAZARDOUS AND WILL REGULATE MIXED WASTE UPON APPROVAL OF STATE WASTE MANAGEMENT PLAN (JULY 1987). THE STATE HAS DETERMINED THAT AN NTS MIXED WASTE FACILITY WILL BE REGULATED AS A "COMMERCIAL" SITE SUBJECT TO SEVERANCE TAXES, DISPOSAL AND INSPECTION FEES. 82
DOE/NV POSITION ON MIXED WASTE FACILITY
UNTIL DIRECTED BY HQ OR RCRA PERMIT IS RECEIVED, NV PUNS TO ADHERE TO PRESENT POLICY OF NOT ACCEPTING MIXED WASTES. NV HAS TAKEN THE POSITION THAT DOE MUST DESIGNATE AT LEAST ONE ADDITIONAL MW FACILITY TO BE DEVELOPED. 83
NTS MIXED WASTF PERMIT APPLICATION
•IN JUNE 1985, DOE/HQ REQUESTED ALL FIELD OFFICES APPLY FOR MIXED WASTE PERMITS. •NTS SUBMITTED PART B BY NOVEMBER 1985 TO EPA WITH COURTESY COPY TO STATE. EXEMPTIONS FOR TRENCH LINERS AND GROUND- WATER MONITORING REQUESTED. •DUE TO CHANGE IN BY-PRODUCTS RULE, DOE/NV SUBMITTED NEW PART A'S FOR AREA 5 AND 3 LLW SITES. PART A'S ADDRESS ALL RADIOACTIVE WASTE STORAGE AND DISPOSAL OPERATIONS. •A NEW PART B FOR AREA 5 IS BEING PREPARED FOR SUBMISSION TO STATE BY NOVEMBER 1987. 84
REECO ROLE
REECo WILL SERVE AS MIXED WASTE FACILITY OPERATOR WITH RESPONSIBILITIES FOR INSPECTION AND CERTIFICATION OF WASTES, AND COMPLIANCE WITH PERMIT REQUIREMENTS. PLANNING AND PREPARATION FOR FIVE MAJOR TASKS: — REGULATORY COMPLIANCE AND ENVIRONMENTAL DOCUMENTATION — WASTE SAMPLING AND CERTIFICATION PROGRAM — DATA MANAGEMENT SYSTEMS ~ MIXED WASTE DISPOSAL FACILITY DEVELOPMENT ~ WASTE EXAMINATION FACILITY DEVELOPMENT IMPLEMENTATION SCHEDULE AND FUNDS TO BE DETERMINED BY DOE/HQ AND NV. FOR FY 1987, $530K HAS BEEN RECEIVED. DOE/HQ HAS REQUESTED $3,1 MILLION FOR NTS MIXED WASTE IN FY 1988. 85
rilRRFNT STATUS AND PLANS
•REECo HAS PREPARED AN INTERIM DRAFT REVISION TO NTS WASTE ACCEPTANCE CRITERIA TO ADDRESS MIXED WASTE. AWAITING NEW DOE ORDER 5820.2 BEFORE ISSUING.
•REECo IS ACQUIRING SUBCONTRACTOR SERVICES IN PERFORMING MULTIPLE TASK ASSIGNMENTS. THESE INCLUDE:
— PREPARATION OF REVISED AREA 5 PART B APPLICATION ~ DEVELOPMENT OF MW QA PLAN — LAND USE AND CONCEPTUAL OPERATING PLAN
•DOE/NV HAS OFFICIALLY TRANSMITTED NOVEMBER 1985 PART B APPLICATION TO STATE FOR REVIEW. STATE HAS AGREED TO CONSIDER GRANTING INTERIM STATUS FOR ROCKY FLATS SALTCRETE BY SEPTEMBER.
•STATE WILL PROBABLY NOT GRANT FULL MW STATUS UNTIL REVISED PART B SUBMITTED. MAY CONSIDER INDIVIDUAL WASTE STREAMS ON AD HOC BASIS.
•MAJOR EFFORT WILL BE REQUIRED TO DEVELOP CERTIFICATION PROGRAM BY SEPTEMBER. J / .:=,
/••...
RI/FS Planning Activities at Oak Ridge National Laboratory (ORNL)
Presented by:
Joseph F. Nemec, Bechtel National, Inc. 89 RI/FS PLANNING ACTIVITIES AT ORNL
The Oak Ridge National Laboratory has begun a 15 - 20 year program for environmental restoration. As a first phase, a 5-year Remedial Investigation/Feasibility Study will evaluate 13 contaminated Waste Area Groupings (WAGs) and determine the feasibility and benefits of potential remedial action. The RI/FS and any future remedial action at ORNL will be of national significance and will likely lead to developments that will become models for environmental investigations and cleanups.
Martin Marietta Energy Systems has chosen Bechtel National, Inc. (BNI) to conduct the RI/FS. BNI and a team of subcontractors will work with Energy Systems to conduct intensive field investigations to obtain data required to evaluate the sites. The BNI Team will prepare Alternatives Assessments for remedial actions at each WAG and then will develop an overall Feasibility Study that will serve as a guide for future remedial action at ORNL.
The RI/FS will comply with all regulatory requirements, with intensive attention given to environmental, safety, and health protection, waste management, data management, and quality assurance.
This paper describes current planning activities and the status of the RI/FS project and introduces the project for reports at future model conferences. 91 RI/FS PLANNING ACTIVITIES AT OAK RIDGE NATIONAL LABORATORY (ORNL) - Joseph F. Nemec, Bechtel National, Inc., Oak Ridge, Tennessee; Ken W. Cook, Martin Marietta Energy Systems, Oak Ridge, Tennessee; Thomas S. Wright, Bechtel National, Inc., Oak Ridge, Tennessee. INTRODUCTION When Oak Ridge National Laboratory (ORNL) began its Manhattan Project atomic weapons materials research and development operations in 1943, the planned life for the facility was only one year. This was extended for 2 to 3 more years, and as nuclear research and political climates evolved, ORNL became a permanent facility. As was true at many of the nation's early atomic research centers, when operations at ORNL began, the risks and waste management requirements of radiological science, and production were relatively unknown. Methods of operation, environmental protection, and waste disposal at ORNL have been evolving processes, and many of the standard waste disposal methods now followed did not exist during past operations. Therefore, past practices account for the majority of the potential environmental problems affecting the ORNL Reservation. In response to this situation, the Department of Energy (DOE) and Martin Marietta Energy Systems (Energy Systems) have initiated a program for environmental restoration, the first step of which is the Remedial Investigation/Feasibility Study (RI/FS) project. As its subcontractor for performing the RI/FS, Energy Systems has selected Bechtel National, Inc. (BNI). BNI will be supported by CH2M HILL, EDGe/MCI, and PEER Consultants. The project will be conducted under the regulatory framework of RCRA Section 3004(u). Deliverables will follow the formats required by RCRA but will be modified as necessary to include all pertinent or applicable information required by NEPA and/or CERCLA.
THE NATURE OF THE PROBLEM The ORNL RI/FS project will investigate several areas of ORNL that are contaminated primarily with radioactive materials and, to a lesser extent, with hazardous chemicals. Energy Systems has organized the contaminated areas into Waste Area Groupings, or WAGs. Each WAG contains several Solid Waste Management Units, or SWMUs. The SWMUs for the most part are sites used to collect and store low level waste, such as burial trenches and pits, tanks, and impoundments. The SWMUs also include spill and leak sites identified over the years. 92
So far, 13 WAGs containing about 180 SWMUs have been included in the RI/FS project. Additional areas may be added. The WAGS assigned to the project so far are briefly described below. Note the variety of waste management facilities, forms of waste, and types of contaminated materials encompassed by these groupings. WAG 1 - The ORNL Main Plant Area The Main Plant Area contains almost one-half (99) of the SWMUs identified to date. The number of SWMUs and the complex nature of the Main Plant Area, including the fact that it is still an operating facility, make this one of the most challenging tasks of the RI/FS project. The Main Plant Area is shown in Figure 1.
WAG 2 - White Oak Creek and White Oak Lake White Oak Creek and White Oak Lake and its tributaries are the major drainage system for ORNL and its surrounding area. WAG 2 contains two SWMUs: the stream channels of White Oak Creek and Melton Branch' and White Oak Lake, White Oak Dam, and the embayment. Figure 2 shows these areas and their surroundings, including WAG 6 (see below).
WAG 3 - Solid Waste Storage Area 3 WAG 3 is located in Bethel Valley and is composed of three SWMUs: Solid Waste Storage Area (SWSA) 3; a closed scrap metal area; and a contractor's lendfill. WAG 4 - Solid Waste Storage Area 4 WAG 4 consists of three SWMUs: the Liquid Low Level Waste (LLLW) pipeline north of Lagoon Road; pilot LLLW seepage pits 1 and 2; and SWSA 4. WAG 4 is shown in Figure 3. WAG 5 - Solid Waste Storage Area 5 This WAG contains 22 SWMUs including: 13 LLLW storage tanks; surface facilities for the Old and New Hydrofracture facilities; SWSA 5; the Transuranic (TRU) Waste Storage Area; LLLW leak/spill sites; an impoundment used to dewater sludge; and a radioactively contaminated waste-oil storage tank.
WAG 6 - Solid Waste Storage Area 6 WAG 6 consists of three SWMUs: an emergency waste basin; SWSA 6; and an explosives detonation trench. WAG 6 is shown in Figure 2. 93
WAG 7 - Pits and Trenches WAG 7 contains 10 SWMUs including: 7 seepage pits and trenches; a decontamination facility; three LLLW pipeline leak sites; a storage area; and 7 fuel wells holding the acid solutions containing enriched uranium primarily from the Homogeneous Reactor Experiment (HRE) fuel. WAG 8 - Melton Valley The Molten Salt Reactor Experiment facility and the High Flux Isotope Reactor are located within WAG 8. WAG 8 contains 20 SWMUs including: waste collection basins; LLLW pipeline and leak sites; a hazardous waste storage facility; LLLW collection and storage tanks; a mixed waste storage pad; a sewage treatment plant; and a silver recovery plant.
WAG 9 - Homogeneous Reactor Experiment Area This WAG contains three SWMUs: the HRE pond; LLLW collection and storage tanks; and a septic tank serving the HRE. WAG 10 - Hydrofracture Wells WAG 10 consists of the injection wells and grout sheets from four SWMUs, two of which were experimental sites used in the development of the hydrofracture process at ORNL. The other two sites are inactive operating facilities that were used to dispose of LLLW. Figure 4 shows the old and new hydrofraeture facilities. WAG 11 - White Wing Scrap Yard This WAG includes only the White Wing Scrap Yard, an above-gtound storage area for contaminated equipment. WAG 13 - Environmental Research Areas This WAG includes a cesium-137 contaminated field and a cesium-lav erosion/runoff study area. WAG 17 - ORNL Services Area This WAG includes the photographic waste storage area (two above-ground tanks); a septic tank; and a waste oil storage area containing one above-ground tank, two below-ground tanks, and a tank truck. 94 THE OBJECTIVES OF THE RI/FS PROJECT The RI/FS project will proceed in four phases: Phase I: Initial Planning Phase II: Remedial Investigation Phase ill: Alternatives Assessment Phase IV: Feasibility Study Following the initial planning stage (discussed below), each WAG will be the subject of an intensive investigative effort during the remedial investigation phase of the RI/FS project. The objectives of each remedial investigation are to:
o Define the types and quantities of contaminants present in each SWMU or collection of SWMUs o Provide a quantitative definition of how contaminants exit the site o Gather sufficient data to estimate the temporal and spatial distribution of off-site migration o Obtain engineering data sufficient to evaluate potential remedies for each SWMU or collection of SWMUs Following completion of the remedial investigation for each WAG, a WAG-specific Alternatives Assessment (AA) will be completed during Phase III of the project. The objective of the AA is to identify and screen potential remedial technologies that could be used at a particular WAG, develop a set of feasible remedial action alternatives, and compare the alternatives based on environmental protection, environmental effects, technical feasibility, and costs.
During Phase IV, the AAs for all WAGs will be combined into a comprehensive Feasibility Study. Remedial action scenarios for the ORNL complex will be developed, prioritized, and evaluated, and their costs will be estimated. The end product of this activity will be a documented approach for remedial activities at the ORNL complex that can be- used as the basis for future remediation of the ORNL WAGs. 95 PROJECT STATUS
The RI/FS project presently is concentrating on Phase 1 planning activities and has begun work on Phase II remedial investigation activities on WAGs 1, 6, and 10.
The complexity of the investigations to be performed at ORNL, the possibly hazardous nature of the wastes to be dealt with, the volume of data that already exist and the amounts of new data to be generated - all make Phase I planning nciivities extremely important. During Phase 1, five planning documents and accompanying procedures are being developed to guide the management of the RI/FS project. These documents are:
o Project Management Plan
o Quality Assurance/Quality Control Plan
o Environmental, Safety and Health Plan
o Waste Management Plan
o Data Bzr.e Managem
The Project Management Plan has been submitted and finalized, and the other four documents have been transmitted in draft form and are currently in various stages of revision.
Phase II remedial investigation planning began in August for WAG 1, the Main Plant Area, and WAG 10, Hydrofracture. Planning began in October for WAG 6, SWSA 6. A Remedial Investigation Plan for WAG 1 is being prepared for delivery to Energy Systems at the end of Ociober.
The Remedial Investigation Plan for WAG 10 has already been prepared by Energy Systems. A Remedial Investigation Implementation Plan is now being developed that will concentrate on the sampling plan approach and preliminary alternative assessment for the WAG.
As shown in Figure 5, other remedial investigations are scheduled to b<^g i n shortly. Arlual field work in support of Phase II activities is expected to begin in the spring of 1988.
SUMMARY
Since its beginning in June 1987, the RI/FS project has been proceeding on schedule and within budget. Though work thus 96
far has consisted primarily of planning activities, remedial investigations are now underway and field work will follow shortly. It is the intent of Energy Systems and the BNI Team to present annual updates on the progress of the project at future conferences. As the RI/FS project develops, these updates will include technical papers on the results of field investigations, generic and bench-scale studies, and overall project progress. 95 PROJECT STATUS
The RI/FS project presently is concentrating on Phase I planning activities and has begun work on Phase II remedial investigation activities on WAGs 1, 6, and 10.
The complexity of the investigations to be performed at ORNL, the possibly hazardous nature of the wastes to be dealt with, the volume of data that already exist and the amounts of new data to be generated -- all make Phase I planning ^n Ivities extremely important. During Phase 1, five planning documents and accompanying procedures are being developed to guide the management of the RI/FS project. These documents are:
o Project Management Plan
o Quality Assurance/Quality Control Plan
o Environmental, Safety and Health Plan
o Waste Management Plan
o Data Bane Management Plan
The Project Management Plan has been submitted and finalized, and the other four documents have been transmitted in draft form and are currently in various stages of revision.
Phase II remedial investigation planning began in August for WAG 1, the Main Plant Area, and WAG 10, Hydrofracture. Planning began in October for WAG 6, SWSA 6. A Remedial Investigation Plan for WAG 1 is being prepared for delivery to Energy Systems at the end of Ociober.
The Remedial Investigation Plan for WAG 10 has already been prepared by Energy Systems. A Remedial Investigation Implementation Plan is now being developed that will concentrate on the sampling plan approach and preliminary alternative assessment for the WAG.
As shown in Figure 5, other remedial investigations are scheduled to b<*g i n shortly. Aciual field work in support of Phase II activities is expected to begin in the spring of 1988.
SUMMARY
Since its beginning in June 1987, the RI/FS project has been proceeding on schedule and within budget. Though work thus 96
far has consisted primarily of planning activities, remedial investigations are now underway and field work will follow shortly. It is the intent of Energy Systems and the BNI Team to present annual updates on the progress of the project at future conferences. As the RI/FS project develops, these updates will include technical papers on the results of field investigations, generic and bench-scale studies, and overall project progress. 97 Figure 2 WAG 2, White Oak Creek and White Oak Lake. WAG 6 can be seen in the center of the photo to the left of White Oak Lake. 99 Figure 4 This photo shows WAG 10, the Old and New Hydrofracture Facilities. The newer facility is shown in the foreground. sd/m BHI yod 3ina3H0s 9 3Uf19ld Aams 1N3WSS3SSV S3AUVNU311V
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9 0VM NVld idHI Ib 01 OVM NVld idWI IU I OVM - NVld IU
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'^// "
RCRA Land Unit Closures at the Y-12 Plant Oak Ridge, Tennessee
Presented by:
Sara H. Welch, Y-12 105 ABSTRACT RCRA LAND UNIT CLOSURES AT THE Y-12 PLANT Sara H. Welch Environmental Management Department Y-12 Plant; B. A. Kelly, M. F. P. Delozier, and W. E. Manrod Engineering Division Martin Marietta Energy Systems, Inc.
Eight land-based hazardous waste management units at the Y-12 Plant are being closed under an integrated multi-year program. Closure plans for the units have been submitted and are in \arious stages of revision and regulatory review. These units will be closed by various combinations of irethods, including liquid removal and treatment, sludge stabilization, contaminated sludge and/or soil removal, and capping. The closure of these sites will be funded by a new Department of Energy budget category, the Environmental Restoration Budget Category (EFBC), vtaich is intended to provide greater flexibility in the response to closure and remedial activities. A major project, Closure and Post-Closure Activities (CAPCA), has been identified far EBBC funding to close and remediate the land units in accordance with RCRA requirements. Establishing the scops of this program has required the development of a detailed set of assumptions and a confirmation program for each assumption. Other significant activities in the CAPCA program include the development of risk assessments and the preparation of an integrated schedule. 107 Y/TS-338 Y-12
RCRA LAND UNIT CLOSURES AT THE Y-12 PLANT OAK RIDGE OAK RIDGE, TENNESSEE Y-12 PLANT
MAI #7 TIN MS\ 19I
S. H. Wfelch B. A. Kelly M. F. P. DeLozier W. E. Mfcmrod
OCTOBER 1987
OPERATED BY MARTIN MAMETTA ENER6Y SYSTEMS. INC. FGR THE UNITED STATES DEPARTMENT OF ENERGY 108
-DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, cxpross or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise. does not necessarily constitute or imply itt endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United Sutet Government or any agency thereof. 109 Y/TS-338
RCRA LAND UNIT CLOSURES AT THE Y-12 PLANT OAK RIDGE, TENNESSEE
S. H. Welch1 B. A. Kelly2 M. F. P. DeLozier2 W. E. Manrod3
^Health, Safety, Environment, and Accountability Division, Oak Ridge Y-12 Plant. 2Engineering Division, Oak Ridge Y-12 Plant. Engineering Division, Oak Ridge Gaseous Diffusion Plant.
Presented at Oak Ridge Model Conference Oak Ridge, Tennessee October 13-16, 1987
Prepared by the Oak Ridge Y-12 Plant Oak Ridge, Tennessee 37831 operated by MARTIN MARIETTA ENERGY SYSTEMS, INC, for the U.S. DEPARTMENT OF ENERGY under contract DE-AC05-840R21400 110
CONTENTS
LIST OF FIGURES iii LIST OF TABLES iv SUMMARY 1 GENERAL DESCRIPTION OF THE Y-12 PLANT 2 HAZARDOUS WASTES AT THE Y-12 PLANT 4 RCRA LAND UNITS AT Y-12 4 S-3 PONDS 4 BEAR CREEK BURIAL GROUNDS 7 OIL RETENTION PONDS 11 OIL LANDFARM 13 NEW HOPE POND 17 CHESTNUT RIDGE SEDIMENT DISPOSAL BASIN 20 CHESTNUT RIDGE SECURITY PITS 20 KERR HOLLOW QUARRY 21 ENVIRONMENTAL RESTORATION BUDGET CATEGORY (ERBC) 25 RCRA CLOSURES AND POST-CLOSURE ACTIVITIES (CAPCA) PROJECT . 27 Ill
LIST OF FIGURES
Figure 1. Bear Creek Valley Waste Disposal Area .... 5 Figure 2. Engineered Cap Components 8 Figure 3. Bear Creek Burial Grounds 9 Figure 4. Oil Landfarm Area 14 Figure 5. New Hope Pond 18 Figure 6. New Hope Pond and Chestnut Ridge Sediment Disposal Basin (CRSDB) 19 Figure 7. Geographic Location of the Chestnut Ridge Security Pits 22 Figure 8. Design Plan for Chestnut Ridge Security Pits - Western Area 23 Figure 9. Typical Line Item Funding Cycle 26 Figure 10. Closure Plan Requirements vs. Actual Receipt in Typical Funding Cycle 28 Figure 11. Schedules for Closure of RCRA Land Units, Y-12 Plant 34 112
LIST OF TABLES
Table 1. ERBC Characteristics 29 Table 2. CAPCA Scoping Study Meeting 31 Table 3. Examples of Confirmatory Studies 32 113 RCRA LAND UNIT CLOSURES AT THE Y-12 PLANT Sara H. Welch Environmental Management Department Oak Ridge Y-12 Plant; B. A. Kelly, M. F. P. DeLozier, and W. E. Manrod Engineering Division Martin Marietta Energy Systems, Inc.
SUMMARY
Eight land-based hazardous waste management units at the Oak Ridge Y-12 Plant are being closed under an integrated multi-year program. Closure plans for the units have been submitted and are in various stages of revision and regulatory review. These units will be closed by various combinations of methods, including liquid removal and treatment, sludge stabilization, contaminated sludge and/or soil removal, and capping. The closure of these sites will be funded by a new Department of Energy budget category, the Environmental Restoration Budget Category (ERBC), which is intended to provide greater flexibility in the response to closure and remedial activities. A major project, Closure and Post-Closure Activities (CAPCA), has been identified for ERBC funding to close and remediate the land units in accordance with RCRA requirements. Establishing the scope of this program has required the development of a detailed set of assumptions and a confirmation program for each assumption. Other significant activities in the CAPCA program include the development of risk assessments and the preparation of an integrated schedule. 114 GENERAL DESCRIPTION OF THE Y-12 PLANT
Past and Present Missions The Oak Ridge Y-12 Plant was built by the U.S. Army Corps of Engineers in 1943 as part of the Manhattan Project. The original mission of the Plant was to separate the fissionable isotope of f lium (U-235) by the electromagnetic process. After World War II, the electromagnetic separation process was discontinued in favor of the more economical gaseous diffusion process. Since its early years, the Plant has developed into a highly sophisticated manufacturing and developmental engineering organization. The Plant occupies approximately 800 acres and is located immediately adjacent to the city of Oak Ridge. The total work force consists of approximately 7,200 persons, including employees of the Oak Ridge National Laboratories (ORNL). The Plant has four principal missions: (1) producing nuclear weapons components and supporting the Department of Energy's weapons design laboratories; (2) processing source and special nuclear materials; (3) producing support to other DOE installations; and (4) providing support to other government agencies.
Defense Responsibilities Current, Y-12 is involved in producing components for the various nuclear weapon systems in the nation's defense arsenal. A portion of this effort involves the conversion of U-235 compounds to metal and the appropriate casting, rolling, and machining operations required to produce a finished product. 115 Ma.ior Fabrication and Methods Most of the fabrication work done at Y-12 is performed through the use of portions of one or more of the three basic systems; a wrought products cycle, a cast products cycle, and a powder products cycle. The wrought cycle involves the formation of compacts by vacuum casting, arc melting, electron-beam melting or powder compaction. The compacts are worked into mill products such as sheet and plate, extrusions, or forgings, which then are formed to shape and to approximate dimensions. Finally, the shapes are machined to finished dimensions, certified and possibly consolidated into subassemblies. The cast product cycle is characterized by casting the materials to an approximate shape using vacuum, arc, or sand-casting methods. Shaped item? are then machined, inspected, a'/d assembled. The powder product cycle is characterized by the compaction of various metal or ceramic powders to billels or to approximate shapes using isostatic or die pressing techniques. These compacts are frequently sintered in vacuum, inert gas, or hydrogen at high temperatures, and are then machined, inspected, and assembled. A major contribution at Y-12 is product certification. This capability includes dimensional inspection, physical testing, and analytical measurement. The calibration of the gages and the instruments used in product certification may be traced directly to the National Bureau of Standards. 116 HAZARDOUS WASTES AT THE Y-12 PLANT Hazardous wastes of various types are generated at the Y-12 Plant as part of, or incidental to, main production processes at the plant. These wastes have been stored, treated, and disposed at a number of individual units on the Y-12 Plant site, including container and tank storage areas, wastewater treatment plants, landfills, land treatment units, and surface impoundments. Of these units, some are to be closed rather than permitted. Closure plans have been submitted for these facilities. The remainder of this article will focus on Y-12's eight land units - surface impoundments, landfills, and a land treatment unit - that are being closed under the Resource Conservation and Recovery Act (RCRA). Closure of all these units is required by statute to be initiated by November 1988.
RCRA LAND UNITS AT Y-12 S-3 PONDS Description The S-3 Ponds are located adjacent to the west end of the Y-12 Plant (see Figure 1) at the topographic divide separating the headwaters of Bear Creek to the west from the headwaters of East Fork Poplar Creek to the east. The ponds, located in the Bear Creek Valley Waste Disposal Area, are four unlined impoundments covering an area of roughly 400 feet by 400 feet. They are approximately 17 feet deep and contain from 2 to 5 feet of sludge each. Each pond has a capacity of 2.5 million gallons. The ponds were designed to maximize rates of evaporation and percolation. WASTE-DISPOSAL AREA
FIGURE 1. BEAR CREEK VALLEY WASTE-DISPOSAL AREA 118 The S-3 Ponds were built in 1951 as a disposal site for liquid wastes. In the 1950s, uranyl nitrate solutions containing trace amounts of transuranics and other fission products were placed in the ponds. At later dates, depleted uranium in nitric acid solutions, raffinate, and condensate containing technetium and transuranics, as well as small lots of miscellaneous solid materials, were added. The inventory list includes dilute acids, machine coolants, caustic solutions, biodenitrification sludges, and concentrated acids with a pH of less than 2.0. The volume of wastes was significantly reduced when the nitric acid recovery system became operational in 1976. In 19S3, the quantity of liquid wastes entering the ponds was about 2.7 million gallons. Discharge into the ponds terminated in March 1984.
Treatment of Impoundment Contents Treatment of water in the S-3 Ponds began in 1983 and continued until the spring of 1986. Between May and November 1983, all four ponds were neutralized. During that time, biodenitrification was started and continued through September 1984. After denitrification, the pond contents were allowed to settle, and the supernatant was pumped to the S-3 Ponds Liquid Treatment Facility for removal of trace metals and organics. The treated effluent was discharged to East Fork Poplar Creek starting in the summer of 1985 and completed in the spring of 1986 under an NPDES permit. Closure The closure program will begin by treating any residual water collected in the ponds, if required. Contaminated stream sediments in the vicinity of the S-3 Ponds will be excavated and deposited in the ponds. Bottom sludges and sediment will then be stabilized with rock to provide a firm base for the placement of an engineered cap. A typical cross section of the cap, which is being designed in accordance with current EPA guidance documents, is shown in Figure 2. Two feet of compacted clay will rest above the dike soils which will have been graded in to create an even surface. Cover clay materials will be selected to produce a permeability of equal to or less than the permeability of the natural subsoils. A flexible memorane liner 30 mils in thickness will be placed continuously above the clay layer. A one-foot-thick layer of sand to sandy gravel will be installed above the membrane, followed by a geotextile filter fabric to reduce the likelihood of fine silts and clays clogging the sand filter. A two- foot-thick layer of topsoil will complete the cap.
BEAR CREEK BURIAL GROUNDS Description The Bear Creek Burial Grounds are located on the southwest flank of Pine Ridge approximately 1.5 miles west of the Y-12 Plant in the Bear Creek Valley. This facility consists of several contiguous disposal sites identified as Burial Grounds A, B, C, D, E, and J (see Figure 3). Each burial site consists of a series of trenches used for disposal of solid wastes and in some cases liquid wastes. The bottom 120
TOPSOIL (LIGHTLY TAMPED)
MIRAFI I40N FILTER FABRIC (OR EQUIVALENT) DRAINAGE LAYER
30 mtl FLEXIBLE MEMBRANE
CLAY (COMPACTED)
VARIABLE DIKE MATERIALS
FIGURE 2. ENGINEERED CAP COMPONENTS EXPLANATION T-34 WASTE-DISPOSAL AHEA
l-H 31,000
3-en FIGURE 3. Bear Creek Burial Grounds. 122 of the trenches is reported to be a maximum of 20 feet below the original grade. The first disposal trench, located in Burial Ground A, was excavated in August 1955 for the disposal of solid wastes. In July 1959, the Y-12 Plant was authorized by the Atomic Energy Commission to begin using this facility for the disposal of certain types of liquid wastes. Since that time, several types of wastes have been disposed of in the various burial ground areas including the following (not listed in order of generated volume):
• ferrous metals and uranium • oils and coolants • salts • debris « solvents • asbestos t material contaminated with radioisotopes t mop water
The actual quantity and identity of materials is uncertain, and other materials may have been disposed of that are not listed in any inventory. The largest volume of material disposed in BCBG consists of uranium-contaminated industrial trash (paper, wood, steel, glass, and rubble). Burial Ground A was also used for the disposal of mop waters, oils, and coolants, which were placed, along with solid wastes, into unlined trenches. In 1970, leakage was observed from the ends of the 123 trenches. To collect oils seeping into surface streams, Oil Retention Ponds 1 and 2 were constructed at the southwestern and northeastern corners of Burial Ground A. Burial Ground B was opened in 1962 for the disposal of depleted uranium metal and oxides. Burial Ground C was opened in 1962 for the disposal of beryllium, beryllium oxide, thorium, and solid waste contaminated with these materials; materials contaminated with enriched uranium also were disposed of in Burial Ground C. Burial Ground D was used after 1968 for the disposal of depleted uranium metals and oxides after Burial Ground B had reached capacity. The Walk-In Pits were used for the disposal of uranium saw fines and small laboratory quantities of acids, bases, and unstable crganics.
Closure Closure of Bear Creek Burial Grounds will consist of placement of an engineered cap over the disposal areas. The proposed cap is made up of two feet of compacted clay followed by a one-foot thick layer of sand. A two-foot thick layer of topsoil will complete the cap. Closure of the Walk-In Pits presents technical uncertainties and safety concerns that must be addressed.
OIL RETENTION PONDS Description Oil Retention Pond No. 1 was constructed in May 1971 at the southwest corner of Burial Ground A to collect and contain oils leached into a surface stream flowing along the west boundary of Burial Ground A. A diversion ditch has also been constructed to divert surface water 124 away from the pond, thereby minimizing the volume of water flowing into and through the pond and the chances of pond overflow. In May 1972, a smaller pond (Oil Retention Pond No. 2) was constructed at the northeast corner of Burial Ground A to collect and contain the oils observed seeping into an intermittent stream along the east side of Burial Ground A. Locations of the Oil Retention Ponds are shown in Figure 3. The Oil Retention Ponds are operated as gravity separators which provide for collection of the oils while allowing the water to be released through an inverted pipe through the dike. In 1974 and 1975, approximately 15,000 gallons of oil vtere skimmed and removed from the surfaces of both ponds for disposal on the Oil Landfarm. In early 1975, approximately 5,000 gallons of oil accumulation were sprayed onto nearby trees infested with pine beetles. No significant accumulation of oil has occurred on the surface of Pond No. 2 since 1975. An additional 18,000 gallons of oil were removed from Pond No. 1 in 1979 and stored in the Garage Underground Tanks (S-019). The pond water, oils floating on the surface, and sediments are contaminated with polychlorinated biphenyls (PCB). The Oil Retention Ponds effectively serve to collect oils that seeped from the trenches, thereby reducing the contamination of adjacent streams.
Closure Final closure of the Oil Retention Ponds Nos. 1 and 2 will begin by intercepting seepage of contaminated leachate entering the ponds. Liquids from the pond will be removed and treated prior to discharge through a NFDES monitoring system. The bulk of contaminated soils will 125 be removed and stored pending treatment in the RCRA/TSCA Incinerator at the Oak Ridge Gaseous Diffusion Plant (ORGDP). A proposed multi-layer cap, like that described for Bear Creek Burial Grounds, will then be installed to isolate residual contaminants in the soil from the surface environment. This cap will also minimize the release of contaminants into the groundwater.
OIL LANDFARM Description The Oil Landfarm Area is located approximately one mile west of the Y-12 Plant in the Bear Creek Valley Waste Disposal Area (see Figure 1). The Oil Landfarm Area collectively refers to five waste disposal units: the Oil Landfarm disposal plots, the Boneyard, the Burnyard, the Sanitary Landfill, and the Chemical Storage Area (also referred to as the Hazardous Chemical Disposal Area). These units are shown in Figure 4. Only two of these, the Oil Landfarm and the Chemical Storage Area, are RCRA units.
Oil Landfarm. The Oil Landfarm disposal plots were operated from 1973 to 15)82. As part of an EPA-approved research project, the facility was used for the biological degradation of approximately one million gallons of waste oil and machine coolants via land farming, a process involving the application of waste oils and coolants to nutrient-adjusted soil during the dry months of the year (April to October). After application, the plots were cultivated frequently to maintain aerobic conditions to enhance biodegradation of the wastes. EXPLANATION WASTE-DISPOSAL AREA
OIL LANDFARM BONEYARD/BURNYARD
1 "•.' T-'S. ;•
CHEM8CAL* TORAGE AREA
SANITARY LANDFILL
*RCRA Units 127 Waste was not applied immediately before or after periods of precipitation. Before 1979, waste oils and coolants were not specifically analyzed for contaminants before application to the Oil Landfarm. In 1979, analytical results for oil samples collected from the surface of one of the ponds in the Burial Grounds indicated the presence of PCBs. Thereafter, oils were analyzed for uranium, beryllium, thorium, and PCBs. A maximum permissible concentration level of 5 milligram? per liter (mg/1) was established by the Y-12 Plant for PCBs in waste oils to be land farmed. Oils containing greater than 5 mg/1 of PCBs were shipped for commercial disposal if uranium concentrations were less than permissible limits established for release to the public. If uranium concentrations were greater than permissible limits established for release to the public, waste oils containing greater than 5 mg/1 of PCBs were placed in storage for future incineration at the ORGDP TSCA Incinerator. In December 1981, the analyses of wastes were expanded to included chlorinated hydrocarbons. A maximum permissible concentration of 3 percent was established for concentrations of chlorinated solvents in the waste oils. Experience that has been gained since 1981 in sampling and analysis of waste oils for chlorinated solvents has shown that waste oils contain concentrations of less than 3 percent chlorinated hydrocarbons.
Chemical Storage Area. The Chemical Storage Area received solid, liquid, and gaseous waste materials from 1975 to 1981. It is estimated that during this period, less than five tons of waste per year were 128 delivered to the area. The material was broadly characterized as ignitable, reactive, corrosive, toxic, highly flammable, or in some instances, inert. The chemicals were sorted according to their hazards. Known toxic materials not posing a safety hazard when treated or otherwise handled were taken to other disposal facilities. Generally, the Chemical Storage Area treated waste which posed safety hazards within the Y-12 Plant. The material came from two sources: gas cylinders with leaking or damaged valves and lab chemicals considered to be reactive or explosive. Gas cylinders containing noncorrosive gases were allowed to leak into the atmospherp or were bled off to expedite the process. Those containing corrosive gases were bled through neutralizing slurries. Empty gas cylinders then were either destroyed and removed or transported to another location for repair. The lab chemicals included acids, bases, organics, water-reactive compounds, and explosive compounds such as picric acid, benzoyl peroxide, and ether. Bottled chemicals were broken under water spray in a concrete vessel open to the atmosphere. After the explosion or chemical reaction had taken place, the effluent was discharged into a small unlined surface impoundment and allowed to percolate through the soil. The chemical residue remaining in the concrete vessel was removed periodically and transported to the Bear Creek Burial Grounds.
Closure Soils contaminated with PCB in excess of 25 ppm will be excavated from the landfarm plots and stored in a vault pending treatment in the RCRA/TSCA Incinerator at ORGDP. The plots and the Chemical Storage 129 Area will then be closed as a landfill by covering them with a proposed multilayered cap like that described for the Bear Creek Burial Grounds.
NEW HOPE POND Description New Hope Pond (NHP) is an unlined, man-made pond constructed at the Y-12 Plant in 1962. The surface area and the volume of the pond are 5.2 acres and 1,232,000 ft^, respectively. NHP is located near the eastern boundary of the Y-12 Plant and receives flow from the Upper East Fork Poplar Creek (UEFPC). Flow in the creek is composed primarily of surface runoff, but has included process wastewater discharges. Flow enters the pond through a distribution ditch from which it is directed through any of nine discharge drains. Flow can also be routed through an oil skimming basin, located adjacent to NHP. Pond discharge is to East Fork Poplar Creek (Figure 5). NHP serves to remove suspended sediments from the creek prior to discharge from the Y-12 Plant and originally also served to moderate pH fluctuations. Discharge from the pond is controlled by an NPDES permit. In 1984, a bypass ditch was constructed around NHP (Figure 5). This ditch allows UEFPC flows to be diverted around NHP and will facilitate removal of sediments from the pond. NHP was dredged in 1973 to remove sediment accumulations. The dredged sediments were placed in the Chestnut Ridge Sediment Disposal B^sin (CRSD8), which is located on Chestnut Ridge above NHP (Figure 6). 130
East Fork Poplar Creek
*••— By-Pass Ditch
on Skirmni ng Basin
Pond Inlet East Fork Poplar Creek DistriDution Ditcn Access Road
PCIT «
Figure 5. New Hope Pond. 131
rn"-I Jj / V-j rr r.r.* *3FE .n;
Figure 6. New Hope Pond and Chestnut Ridge Sediment Disposal Basin (CRSDB). 132 Since 1973, sediments have been removed several times from the pond inlet diversion ditch and placed in the disposal basin.
Closure Current plans call for in-place closure of NHP. Liquids will be removed and treated if required, and sludges/sediments will be stabilized. A multi-layer cap will then be installed.
CHESTNUT RIDGE SEDIMENT DISPOSAL BASIN Description The Chestnut Ridge Sediment Disposal Basin (CRSDB) is an unlined, man-made surface impoundment constructed on Chestnut Ridge, south of NHP (see Figure 6); it was designed to hold approximately 30,000 cubic yards of sediments. The CRSDB was constructed during 1972-1973 for the disposal of sediments removed from NHP. The impoundment was first used in 1973 for the disposal of sediments hydraulically dredged from NHP. Since that time, the basin has been used periodically for disposal of sediments excavated from NHP and its appurtenant structures.
Closure Closure of CRSDB will consist of stabilization of sediments, if necessary, and installation of a multi-layer cap.
CHESTNUT RIDGE SECURITY PITS Description The Chestnut Ridge Security Pits (CRSP) consist of waste disposal trenches located south of the main Y-12 Plant area on Chestnut Ridge 133 south of Buildings 9201-1 and 9204-1, as shown on Figure 7. Trenches are located in two adjacent areas. The eastern trench area has three separate disposal trenches, designated as Nos. 1, 2, and 3, that were used sequentially from 1973 until 1982. Associated with these three trenches were six auger holes, each approximately 2 feet in diameter by 10 feet deep, which were used for the disposal of various wastes materials, including powder mixtures. The western area has one inactive trench (No. 5), two active trenches (Nos. 4 and 6), and space for a future trench (No. 7). Each trench is 14 feet wide at the top and 15 to 18 feet deep. The design plan for these trenches is shown in Figure 8. Hazardous waste disposal in the CRSP was stopped in December 1984; however, the CRSP will continue to be used for disposal of nonhazardous classified waste until late 1988 or 1989, when a new classified waste storage facility is scheduled to be completed.
Closure The CRSP will be closed by installing a multi-layer cap like that described for the S-3 Ponds.
KERR HOLLOW QUARRY Description The Kerr Hollow Quarry (KHQ) site was leased in the 1940s to the Ralph Rogers Company, Inc. to provide rock and gravel for construction needs on the Oak Ridge site. Sometime during the 1940s, quarry operations breached an underground water source, the quarry filled with water, and the site was abandoned. oo
7. (ieoyrdphic Location ot the chestnut Hi P-OCC, O-ODN /B«15€, FIGURE 8. Design Plan for Chestnut Ridge Security Pits - Western Area. 136 Sometime prior to 1951, the Y-12 Plant and the Oak Ridge National Laboratory (ORNL) started using KHQ for the treatment of certain potentially explosive chemicals or water reactive metals accumulated by DOE facilities in the Oak Ridge area. Certain gas cylinders having frozen or leaky valves and containing an unknown quantity of gas are vented at the quarry also. The facility is used for the emergency handling of these materials when personnel safety is the primary concern. Water-reactive metals are treated by reacting the metal with the water in the quarry under controlled conditions, rendering the metal non-hazardous and removing the possibility of future reactivity. Gas cylinders are vented by placing the cylinder on the bank of the quarry and puncturing the cylinder wall with rifle fire by trained security guards. Once vented, the empty cylinders are removed from the area and returned to the Y-12 Plant for proper disposal. Potentially explosive chemicals are delivered to the quarry in specially packed containers to minimize shock and possible detonation in transit. The containers are suspended over the water surface and punctured with rifle fire by trained security guards. Surface water discharges from KHQ are subject to a National Pollutant Discharge Elimination System (NPDES) permit. Closure To develop a closure plan and schedule for KHQ, the materials remaining in the quarry must be characterized as to their stability. If these materials are stable, it is expected that closure will consist of discontinuing use of KHQ and continuing groundwater monitoring. 137 In the event that residual unstable materials are present in KHQ, a number of technical uncertainties and safety concerns must be addressed, including the following: t how to stabilize residual materials; 0 how to remove free liquids; and » where to obtain the quantities of rock that would be required for backfilling. ENVIRONMENTAL RESTORATION BUDGET CATEGORY (ERBC) The statutory requirement to begin closure of the above eight land-based waste management units by November 1988 presented some unique problems for Y-12 as a federal facility. Any one of the individual closures is projected to cost in excess of $1.2 million and to require construction of facilities which are considered capitalizable. This requires Line Item funding, which has a planning cycle of at least three years prior to receipt of capital funds (see Figure 9). Further, to justify capital funds, the technical scope and cost estimate must be known in sufficient detail to independently validate the project approximately two years prior to receipt of capital funds. Meanwhile, the technical scope will not be known with certainty until the Tennessee Department of Health and Environment (TDHE) and the Environmental Protection Agency (EPA) approve a closure plan. However, as soon as the closure plan is approved, Y-12 would be Figure 9. Typical Line Item Funding Cycle BY-4 BY-3 BY-2 BY-1 BY BY+ + i i i { i I i | i i i | i i i | i i i | i i i Design & Construction Design Criteria GO Validation I CD Conceptual Design Feasiblity Study Functional Requirements I 139 expected to commence closure within 90 days. The dilemma caused by these conflicting constraints is illustrated in Figure 10. Similar situations at federal facilities throughout the nation caused the Department of Energy (DOE) to establish a new source of funding for Defense Programs environmental restoration activities, known as the Environmental Restoration Budget Category (ERBC). The characteristics of the ERBC are shown in Table 1. The ERBC solves many of the timing problems previously described. However, because many DOE facilities have old waste disposal sites, the competition for the ERBC funds is intense. A nationwide prioritization is being done based on degree of environmental hazard and regulatory constraints. An order-of-magnitude or "ballpark" estimate must be developed as soon as possible to get a site into the priority queue. RCRA CLOSURES AND POST-CLOSURE ACTIVITIES (CAPCA) PROJECT The eight land-based waste management units subject to the statutory requirement for beginning closure by November 1988, along with the post-closure activities associated with those units, have been grouped together for project management effectiveness and are called CAPCA. These are the highest priority closures at Y-12 both from an environmental hazards standpoint (several of the sites have caused groundwater contamination) and due to regulatory constraint (November 1988 start date). The timing constraints both from the regulatory statue and the need to expeditiously enter the funding priority queue precluded the normal RI/FS (Remedial Investigation/Feasibility Study) process. The Figure 10. Closure Plan Requirements vs Actual Receipt in Typical Funding Cycle BY-4 BY-3 BY-2 BY-1 BY BY+ + i i i | i i i j i i i | i i i | i i i | i i i Design & Construction Design Criteria Validation Conceptual Design Feasiblity Study Functional Requirements Approved Closure Plan required jfojr * Actual 141 Table 1 ERBC Characteristics • Funds may be used for both capital and non-capital expenditures 0 Funds may be requested without firm technical scope or detailed cost estimate • Once funds are assigned to a DOE field office, they may be reallocated among approved projects 142 CAPCA project scope and subsequent estimate was determined by a series of meetings between Environmental Management and Engineering personnel as illustrated in Table 2. It is obvious that from a logical project development viewpoint, the process was backwards. It would certainly be preferable to gather all data, analyze it, and perform pathways analyses and risk assessments prior to selecting a design concept. Some amount of risk is being taken in proceeding with a designed concept in parallel with data analysis and environmental risk assessment. The risk, of course, will be less if the project proceeds through design and into construction before all confirmatory studies are complete. A partial list of confirmatory studies is shown in Table 3. The Comparative Cap Design Analysis will involve evaluating different design variations of multi-layer soil caps using the HELP computer model, which has been accepted by EPA and TDHE for use in predicting infiltration rates through caps. The soil or sludge quantity verification merely provides the sufficient data to determine soils or sludge requiring excavation. The design concept is currently based on limited information. Three of the land units will have sludge structurally stabilized in place prior to cap emplacement. The assumption was made to use rock pounded into the sludge for this purpose. Grouting, vitrification, and other sludge stabilization alternatives will be considered for economic analysis. Finally, as.input to the closure plans and as a basis for annual funding requests, schedules for project activities were developed. Schedules could not be developed independently for each of the eight 143 Table 2 CAPCA Scoping Study Meeting Step 1: Extent of environmental problem discussed Step 2: Closure plan reviewed Step 3: Assumptions made for missing data or studies Step 4: Engineered solution developed consistent with Steps 1 through 3 Step 5: Confirmation program established to verify assumption in Step 3 Step 6: Risk assessments performed to ensure that proposed fixes provide the benefit expected 144 Table 3 Examples of Confirmatory Studies 1. Cap Demonstration Facility 2. Verifying Quantities of Contaminated Soils and Sludges 3. Alternate Sludge Stabilization Technique 145 sites. The sites are in relatively close proximity; will use two common areas for borrow soil; and will use the same road systems for hauling soil, sand, rock, and other materials. Once soil, sand, and other commodity quantities were estimated for each site's engineered closure concept, traffic studies were conducted to determine the logistic constraints on the physical movement of materials. The schedules (shown in Figure 11) were constrained to start all closures by November 1988; however, they may be limited by the availability of funds through the priority ERBC system. A Remedial Action Program Description (RAPD) document is being prepared to describe the technical scope, cost estimate, and schedule for the eight RCRA closures and their post-closure activities. The RAPD also details the assumptions made in developing the design concepts and outline the confirmatory studies to verify the assumptions. The RAPD will be updated annually to incorporate the results of confirmatory studies and will be used as the justification for the ERBC prioritization. Several other environmental remedial measures, including some decontamination/decommissioning needs have been identified as future ERBC projects and will be handled in a similar manner. 5-3 P0ND5 ^DESIGN =1 DESIGN ^STRUCTURflLLr STflBILIZE COP EMPLRCEHENI t 3CflP EHPlflCEHEHt OIL RETENTION PONPS RESIGN ihi CONSTRUCT SUPPORT FRCILITIES riCONSIRUO SUPPORT FKILITIES EMPTY I DREDGE =JEMPtlT 1 QREDGE CPP EMPLBCEHENT CflP EMPLHCEHENT _C BEfifi CREEK BURIRL GROUND JJESIGN 3DESIGN .CONSTRUCTION-flREH "fl" HCOHSTHUCTIOH-fiREfl 'fl~ CON5 TRUCTION-flfiEfl "B" CaNSTmCTiOM-flREA "8" C= CONSTRUCTIQN-flfiEH "C" CONSTRUCT IQH-flRER 'C IONSIRUCTION-HREfl "0" CONSTRUCT ION-WEB -p- OIL LfiNO FflRH DESIGN 3RESIGN CTi ^CONSTRUCT SOIL VBULT 3CONSTRUCT SOIL VflULT Cni> EMPLRCEHENI CUT EtfLRCEHEHT C CHESTNUT RIDGE SECURITY PIT III II,tl 3 DESIGN I lili'.IKill 1 KIN CONSTRUCTION C NEW HOPE POND 1)1 '.ll.N _ ]DESIGN (III. M IHMI K DEMOLITION I lOIL SKIHHER DEMOLITION i 3ENPTT POND suwii ut t. top SIBBILIZE I Cflf C CHESTNUT RIDGE SEpiMENT DISPOSAL BflSIN DESIGN DESIGN STRUCfyRfU STflHIl ] STRUCTURAL ST0BILI2RTION CRP EMPLHCEMENI 3 CflP EHPLKEMEN1 FIGURE 11. Schedules for Closure of RCRA Land Units, Y-12 Plant. 147 ORGDP RCRA Facility Investigation Program: Plans and Content Presented by: J. L. Haymore, ORGDP 149 \ (£0 K/HS-191A J. L. Haymore Oak Ridge Gaseous Diffusion Plant Operated by Martin Marietta Energy Systems, Inc. for the U.S. Department of Energy ORGDP RCRA Facility Instigation Pragma: PIMI and Contest ABSTRACT Preparation of RCRA Facility Investigation (RFI) plans for thirty four 3004(u) sites at the ORGDP will be accomplished during FY-8? and FY-$8. The plans will be written to guide the sampling and analyses of the sites to determine the extent, if any, of contamination. This investigation will then be the cornerstone for design of corrective measures for site remediation. The RFI plans at the ORGDP are being prepared by two Martin Marietta Energy Systems, Inc., project teams. The organization of the teams, the schedules, and the costs associated with preparation of the documents will be discussed. The contents of the general RFI plan document and a typical site-specific plan will be shown and the contents and methodology of each section will be highlighted. Th* MfamtMd manuwtpt hm bun Mherad by « mint of *» us. 0o»«n>'i»W undv contact No. K- Icmi n pukM or p farm of It* oo •tow oltti to ds te,«« us. purpeto' 151 K/HS-191 ORGDP RCRA FACILITY INVESTIGATION PROGRAM: PLANS AND CONTENT J. L. Haymore Oak Ridge Gaseous Diffusion Plant Operated by Martin Marietta Energy Systems, Inc. for the U. S. Department of Energy The submitted manuscript has been authored by a contractor of the U.S. Government under Contract No. DE- AC05-84OR21400. Accordingly, the U.S. Government retains a nonexclusive, royalty-free license to publish or repro- duce the published form of this contri- bution, or allow others to do so, for U.S. Government purposes. 152 The RFI Process Includes Six Steps * Site Identification * Preparation of an RFI Plan * RFI Plan Implementation * Feasibility Study and Design of Corrective Measures * Implementation of Corrective Measures * Verification of Cleanup DWG. NO. K/G-8/-IJ 153 REMEDIAL ACTION FLOWCHART IDENTIFY AND CHARACTERIZE SOLID WASTE MANAGEMENT UNITS (SWMUs) RCRA FACILITY NO INVESTIGATION FY87 {RFI) REQUIRED PREPARE RFI PLAN FY88 IMPLEMENT RFI PLAN, REPORT RESULTS CORRECTIVE NO CONTINUE T -- MEASURES (CM) •• MONITORING, FY89 REQUIRED POSSIBLE CAP DESIGN AND IMPLEMENT CORRECTIVE MEASURES e.g., grout curtain, exhume, pump & treat ground water I CONTINUE MONITORING TO VERIFY FIX 154 ORGDP RCRA FACILITY INVESTIGATION (RFI) SITES K-1070-A Old Contaminated Burial Ground K-1070-B Old Classified Burial Ground. K-1407-A Neutralization Pit, K-1407-B Pond. and K-1700 Watershed K-1070-C/D Classified Burial Ground K-901-A Holding Pond K-1064 Burn Area Peninsula Storage K-770 Scrap Metal Yard & Contaminated Debris K-1420 Oil Storage K-1410 Neutralization Pit K-1420 Mercury Recovery Room K-1401 Acid Line K-1232 Treatment Facility K-1413 Neutralization Pit K-1420 Process Lines K-1G04 Area Lab Drain K-1070-F Old Contractors Burial Ground K-1099 Blair Quarry K-1085 Old Firehouse Burn Area K-1007-P1 Holding Pond K-720 Fly Ash Pile K-1004-L Vaults K-1503 Neutralization Pit K-1095 Waste Paint Accumulation Area K-1031 Waste Paint Accumulation Area K-1413 Process Lines K-725 Beryllium Building K-1410 Plating Facility K-1007 Gas Tank Cooling Towers K-1401 Degreaser Tanks K-1414 Gas Tanks K-1421 Incinerator K-1070-G Burial Ground 155 ORGDP RFI Program Status * Plans to be Complete by 12-31-! * Site Sampling and Analyses to Begin in FY-88 * Corrective Measures Program to Begin in FY-89 * Expense Funding: FY-88 $ 1,000.000 FY-89 588,750 FY-90 626,100 * Capital Funding: FY-89 450,000 FY-90 1.475.000 * Total Funding: $4,139,850 156 ORGDP RFI Plan Status Schedule * 28 RFI Plans are Required * EPA Schedule: 7 (25%) in CY-87, 21 (75%) in CY-88 as required by ORNL Part B Permit * ORGDP Working Schedule: 11 in CY-87, 17 in CY-88 Status * General Document and 4 Site-Specific Plans Have Been Submitted * 8 Additional Plans are in Progress Funding * FY-88 $800,000 FY-89 111,250 FY-90 23,900 157 Two Documents Support Each Site Investigation * "RCRA Facility Investigation Plan, General Document, Oak Ridge Gaseous Diffusion Plant, Oak Ridge, Tennessee," K/HS-132 * A Site-Specific Plan ibQ RFI Team Engineering Tim Hale Analytical Chemistry Rick Zingg John McCall Statistics Jack Z< yniak Jeff Bock Environmental Joe Haymore Risk Assessment Robin White* Vickie Brubeck Consultants Pam Dalfonso* Paul Craig 'Team Leaders 159 General Document Contents 1.0 Introduction 2.0 Objectives of RCRA Facility Investigation Planning 3.0 Description of Current Conditions 4.0 Characterization of the Environmental Setting 5.0 Identification of Potential Pathways of Migration and Potential Receptors 6.0 Statistical Sampling Plan 7.0 Sampling and Analytical Methodology 8.0 Data Management Procedures 9.0 Health and Safety Procedures 160 Site-Specific Plan Contents 1.0 Introduction 2.0 Objectives of RCRA Facility Investigation Planning 3.0 Description of Current Conditions 4.0 Characterization of the Contaminant Source 5.0 Characterization of the Environmental Setting 6.0 Identification of Potential Receptors 7.0 Existing Monitoring Data 8.0 Sampling Plan 9.0 Data Management Procedures 10.0 Health and Safety Procedures 161 1.0 Introduction * Overall ORGDP RFI Schedule * General Information in "General Document* * Identifies the Site * Outlines Site-Specific Document 162 2.0 Obiectives of RCRA Facility Investigation Planning 2.1 Objectives * Identify extent of contamination in soils, surface water, groundwater, air, and vegetation pathways 2.2 Evaluation Criteria * Maximum levels of contamination in the various pathways 2.3 Schedule for Specific RFI Activities * Duration for each sampling activity, data analyses, and data reporting 2.4 Feasible Alternatives * Possible range of corrective measures to deal with the various mediae 2.5 Risk Assessment * Evaluation criteria required for risk assessment 163 3.0 Description of Current Conditions 3.1 Geographical Information * Location map and photograph * Description of site terrain 3.2 Historical Information * Information regarding dates of operation 3.3 Operational Information * u >w the facility was operated * uviaterials that were handled at the facility 164 4.0 Characterization of the Contaminant Source * Details of the materials that were handled at the facility * Location maps of disposal areas * Available source characterizations (i.e. sludges and sediments) 165 5.0 Characterization of the Environmental Setting 5.1 Hydrogeology * Geology * Groundwater movement 5.2 Surface Water * Surface water pathways 5.3 Air * Air flow and quality specific to the site 166 6.0 Identification of Potential Receptors 6.1 Potential Pathways of Migration * Soils * Groundwater * Surface water * Air 6.2 Potential Receptors * Human Population * Terrestrial Flora and Fauna 167 7.0 Existing Monitoring Data * Groundwater * Surface water (NPDES) * Air * Soils 168 8.0 Sampling Plan 8.1 Sampling and Analytical Strategy * Types of Samples and analyses required * Material of concern 8.2 Statistical Set-up for Sampling * Statistically determined locations of samples for the mediae outlined * Types and quantities of samples from the various locations 8.3 Field Sampling * Site preparation required * Sampling equipment required * Sampling procedures referenced 8.4 Analytical Protocol * Analyses required for the various samples 8.5 Sample Analyses * Analysis procedures 169 9.0 Data Management Procedures Statistical test Statistical models 170 10.0 Health and Safety Procedures 10.1 Introduction * ORGDP emergency response organizations 10.2 Known Hazards and Risks * substances of safety and health concern 10.3 Level of Protection * Designation of level of protection (A, B, C, or D) * Monitoring parameters 10.4 Designation of Work Area Zones 10.5 Exposure Limits * Explosion potential * Airborne pollutants * Radiation RFI Plan Concerns & Developments * Number of Sites Have Increased from 19 to 34 * Number of Plans Have Increased from 16 to 28 * Two Teams Have Been Established to Meet Plan Schedule * EPA Has Agreed to Review Only One Site Plan This Year. Schedule for RFI Activities and Subsequent Remedial Action Activities May be Impacted. 173 ••/ How Clean is Clean - A Review of Superfund Cleanups Presented by: Charles F. Saes III, ORNL 175 HOW CLEAN IS CLEAN - A REVIEW OF SUPERFUND CLEANUPS1 C. F. Baes III G. Marland Environmental Sciences Division Oak Ridge National Laboratory Oak Ridge, Tennessee 37830 The Superfund Amendments and Reauthorization Act (SARA) requires that remedial actions assure "protection of human health and the environment" and identifies (1) Maximum Contaminant Level Goals (MCLGs) set under the Safe Drinking Water Act and (2) water quality criteria established under Sections 303 and 304 of the Clean Water Act as appropriate and relevant standards for cleanup. We examined whether the standards specified in SARA are being attained by reviewing 42 recent Records of Decision (RODs) for Superfund cleanups. In addition to the technical, legal, and financial criteria set forth in SARA, we reviewed the following issues involved in determining cleanup levels for hazardous constituents in soils and groundwater: What does the EPA expect? What standards are being enforced? What are the boundaries between containment and cleanup? What are the impacts of site size, complexity, pollutant composition, and pollutant volume? What are the impacts of involvement of potentially responsible parties (PRPs)? How and when are waivers to applicable or relevant and appropriate regulations (ARARs) used? We also analyzed for temporal trends and consistency in cleanup standards across regions. Finally, we focused on the policy and political issues involved in setting cleanup standards and on public and Congressional reactions and perceptions, e.g., the EPA's use of Maximum Contaminant Levels (MCLs) rather than the more stringent MCLGs in setting cleanup standards. This paper will present the results of our review and analysis. lThis research was sponsored by the U.S. Department of the Navy, Facilities Engineering Command, under Interagency Agreement No. 1791--1791-A1 with the U.S. Department of Energy, under Contract No. DE-ACO5-84OR214OO with Martin Marietta Energy Systems, Inc. 177 HOW CLEAN IS CLEAN - A REVIEW OF SUPERFUND CLEANUPS -- Charles F. Baes III and Gregg Marland, Environmental Sciences Division, Oak Ridge National Laboratory, Oak Ridge, Tennessee 37831-6036 INTRODUCTION The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or "Superfund") and its reauthorization, the Superfund Amendments and Reauthorization Act of 1986 (SARA), have instituted a national program to clean up sites contaminated by hazardous chemical wastes. During the first six years under CERCLA, 14 sites on the National Priorities List (NPL) have been cleaned up, and remedial actions have been initiated at 143 NPL sites. Under SARA, efforts are underway to clean up the 888 sites currently on the NPL and to identify the potential 60,000 remaining abandoned hazardous waste dump sites in the United States (Harlow, 1987). The issue most critical to this monumental cleanup effort is: How clean is clean? That is, when is remedial action completed and what levels of cleanup must be achieved for a site to be released for unrestricted use? The SARA statute provides a framework for how cleanups are to be performed and specifies levels of cleanup that Congress and the President said must be achieved. The actual cleanup process to be taken at a NPL site is described in a document, the Record of Decision (ROD), which is released into the public domain. We have been examining a number of RODs signed in late fiscal year (FY) 1986 and in early FY 1987 in order to better understand the criteria and issues involved in determining how "clean" clean is and to compare actual cleanup levels proposed with levels specified in SARA,. This paper presents a brief overview and interpretation of the cleanup process as laid out under SARA and discusses the results of our analysis of RODs. THE SARA MANDATE Section 121 of SARA addresses cleanup standards. Section 121[a] provides a framework for selecting remedial actions. It states that remedial actions must be "appropriate" yet "cost-effective." Further, in evaluating whether an action is appropriate, both short-term and long-term costs must be considered. It is no accident that the first criterion mentioned for cleanup under SARA is cost. Although $8.5 billion was allocated for this effort, Congress recognized that only a small number of potential hazardous waste dump sites have been identified and, therefore, cost would be a limiting factor. As will be shown, cost is an overriding factor in determining cleanup level. Section 121[b] gives additional criteria for selecting remedial actions. The Section specifies a preference for "treatment" over "disposal" and further states that treatments should "permanently and significantly" reduce the "volume, toxicity or mobility" of the hazardous waste. It goes on to state that alternative treatment options must be assessed regarding their long-term effectiveness; 178 their costs (again); their potential for failure; the physical, chemical, and biological properties of the hazardous materials; and the potential threat to human health and the environment associated with excavation, transportation, redisposal, or containment of the contaminant. Finally, the Section states that the selected remedial action must be "protective of human health and the environment." These directives capture recent trends in waste management and provide a protocol for determining how clean i.s clean. First, options that involve digging up contaminated material at one site and dumping it at another site are strongly discouraged. Cleanup means either treating or destroying the contaminant. Second, a site-specific risk assessment is required for each alternative to evaluate its impacts on health and the environment. The selection of a cleanup option will be based on how well it achieves an acceptable level of risk considering cost and technical feasibility. Section 121[d] of SARA specifically addresses the question of how clean is clean. "Clean" is any cleanup or control level that "assures protection of human health and the environment" (implying that the standard is risk-based) and is "relevant and appropriate under the circumstances presented by the release or threatened release" (on a site-specific basis). The Section states that residual levels of contaminants must comply with any legally applicable or relevant and appropriate regulations (ARARs). Further, it declares that (groundwater) cleanup "shall require a level or standard of control which at least attains Maximum Contaminant Level Goals [MCLGs] established under the Safe Drinking Water Act [SDWA] and water quality criteria established under Section 304 and 303 of the Clean Water Act [CWA], where such goals or criteria are relevant and appropriate under the circumstances of the release or threatened release." For state standards to be considered ARARs, SARA requires that the standards be promulgated after public comment and be more stringent than federal standards. However, potential state ARARs need not be considered by the EPA if o state standards are not identified to the EPA by the state in a timely manner during the remedial process, o the remedial action is an interim measure, o the remedial action required to achieve the state standard poses a greater risk to human health or the environment than alternative actions, o the state has inconsistently applied the standard in the past, o the remedial action required under the state standard is technically impractical, 179 o an alternative remedial action achieves an equivalent standard of control or protection of human health and the environment, or o the cost of the remedial action required under the state standard is disproportionate to the hazard posed at the cleanup site. Recently, the EPA clarified the ARAR evaluation process (EPA, 1987). Potential ARARs are evaluated on a site-specific btsis using two-tiered criteria. First, potential federal and state ARARs are determined to be legally applicable or not. Failing the legally applicable test, potential ARARs are then evaluated as to whether they are, nevertheless, relevant or appropriate under the circumstances. Together, the waivers to state ARARs in SARA and the ARAR evaluation process give the EPA enormous latitude in cleaning up to levels less stringent than standards imposed by other federal and state statutes. The provision of SARA Section 121fd]{2}{A} that MCLGs are ARARs has recently become the center of controversy (HUN, 1987). The EPA has taken the position that Maximum Contaminant Levels (MCLs), not MCLGs as specified by SARA, are the standards for cleanup at Superfund sites (Thomas, 1987). The SDWA defines MCLGs as "nonenforceable goals" based only on considerations of health protection. On the other hand, MCLs are legally enforceable standards, which are set as close to MCLGs as possible taking cost and feasibility into account. The EPA's position is that MCLs are ARARs because they consider cost and feasibility as prescribed in Sections 121[a] and [b] of SARA. Environmental advocacy groups and some members of Congress disagree. This controversy will likely continue, although Superfund cleanups rarely achieve the MCL standards, much leps the MCLGs. THE REAL WORLD EXPERIENCE Our review of RODs underscores the difficulty in applying uniform standards of cleanup to the diversity of circumstances at Superfund sites. In real situations, costs primarily, but also complexity of the site and the technology available for cleanup set the cleanup standard (Table 1). Public interest in the cleanup, the involvement of responsible parties, and legal entanglements (law suits) also play a role in setting the standard. Given the interplay of these variables, it is difficult to predict what levels of cleanup will be achieved. That is, because each site is unique, exceptions to the generalizations in the following discussion are many. Our review suggests that final cleanup levels at the less complex Superfund sites can be expected to be one of the following: o cleanup of soil to background levels of the contaminant; o cleanup of groundwater to a federal standard (SDVA MCLs or CWA water quality criteria); o cleanup of soil and groundwater to a state standard; or 180 Table 1. Examples of cleanup levels achieved in Superfund cleanups. Site Cost ($) Cleanup level* Comments Ordnance 642,000 10~6 risk "Low cost alternative meets CERCLA goals" Newport 914,000 ACL, 10-6 risk State standard not cost-effective Petro-Chem 1,266,524 Level practical First phase remedial action only Brighton 2,799,000 MCL No source control, new city water supply Mid-South 3,500,000 Max. background Heavy public pressure Ottati/Goss 15,192,500 10~s risk Heavy public pressure Bonfouca 59,900,827 Level practical Cap and 30-y ground- water monitoring Hardage 70,000,000 Undetermined First phase remedial action (excavate to bedrock, incineration) **MCL = Maximum Contaminant Level set under the Safe Drinking Water Act. ACL = Alternate Concentration Limit. o cleanup of groundwater to an alternate concentration limit (ACL) based on a risk assessment showing that' the ACL is equivalent to a risk level of 10~6 or 10~5. At the more complex Superfund sites, cleanup can be expected to be phased in stages called "operable units." Operable units are discrete response measures that often begin before selection of the final remedial action. The first operable units are those that lend themselves to immediate corrective action (e.g., removing barrels, erecting fences, providing alternate water supplies, etc.). Final cleanup levels will likely be defined by the operable units. In other words, cleanup often will be "to the extent practically achievable" within the context of the particular response measure taken. If immediate response measures are not readily apparent, the cleanup level to be achieved often will be deferred until a later date. Finally, the design and execution of remedial actions can be expected to be negotiated with responsible parties and revised in response to public pressure or law suits. The following discussion will examine more closely the various issues that are involved in determining cleanup levels and remedial responses. 181 DETERMINING CLEJ SUP LEVELS AND REMEDIAL RESPONSES Cost is the ove /helming factor in setting cleanup standards. For example, cost was cJarly a key factor in determining the remedy at the West Virginia Ordnance Works site. At this site, nitroaromatic compounds remained in soil following cessation of TNT manufacturing n the 1940s. The kest Virginia Ordnance ROD describes 11 alternatives for site remediation (Table 2). The remedy selected (Option 2) took advantage of existing restrictions on access to the site, which is located in a wildlife sanctuary, and sought to reduce residual nitroaromatic compounds to 50 ppm in soil, a value purported to be associated with an excess individual lifetime cancer level of 10~6 for frequent visitors to the site. The two options (Options 7 and 11) that were consistent with the SARA mandate for on-site volume reduction (incineration) were more expensive than the option selected by factors of seven and 35. After on-site torching of extremely contaminated soil;*, all areas with concentrations greater than 50 ppm were to be covered with 2 ft. of soil and seeded. Technical feasibility is also an important factor in determining cleanup levels. For example, the 55-acre Bayou Bonfouca site in Louisiana is an abandoned creosote works where asphaltic materials and polynuclear aromatic hydrocarbons (PAHs) contaminate surface soils, the adjoining bayou, a creek, river bottom sediments, and groundwater. Both the surface aquifer and a shallow artesian aquifer are contaminated. Surface soils contain up to 16,000 ppm PAH, and 100 ppm PAH were found in waters of the surface aquifer. The EPA set an "action level" of 100 ppm PAH in soil (the basis for which is unclear). However, for groundwater, the EPA is at a loss as to what cleanup level is technically achievable. The ROD states: "The current criteria by the Clean Water Act for drinking water only suggests a contamination level no greater than 3.1 ng/L for PAHs. The technical feasibility of cleaning the groundwater to this level is unknown. The groundwater treatment system currently envisioned will extract and treat to the extent technologically practicable. This aspecc of the remediation plan is in essence a pilot study. Until groundwater extraction starts, it is not known exactly what type of cleanup levels can be expected." Although groundwater cleanup at this site is based on whatever level is technically feasible, the cleanup of contaminated soil at the Bayou Bonfouca site does reflect both the impact of public concern and the requirements for treatment in SARA. The original remediation plan, announced in August 1985 (before passage of SARA), envisioned removal of 5000 yd3 of creosote waste and creosote contaminated debris to an off-site landfill. Intense public interest in the cleanup required an extension of the period for public comment. In the interim, SARA was enacted, and the EPA was obligated to reevaluate its remedy selection. The final remedy provided for on-site incineration of the creosote wastes. 182 Table 2. Alternatives for remedial action at the West Virginia Ordnance Works Superfund site. Option Cost ($) Remedy Cleanup level" 1 0 No action Not applicable 2b 984,000 Soil cover 10~6 risk level 3 1,777,000 On-site landfill 10-6 risk level 4 1,790,000 Multimedia cap 10~6 risk level 5 3,777,000 Removal 10~6 risk level 6 6,537,000 Multimedia cap Detection limit 7 6,586,000 On-site incineration 10~6 risk level 8 7,893,000 On-site landfill Detection limit 9 21,875,000 Removal Detection limit 10 32,677,000 Off-site incineration 10~6 risk level 11 34,736,000 On-site incineration Detection limit "Detection limit = 2 ppm. Risk level of 10~6 = 50 ppm. ^Option selected The influence of public opinion on cleanup standards can work in both directions. Two post-SARA RODs that illustrate the power of public opinion are the New Brighton/Arden Hills and Mid-South Wood Products sites. At the New Brighton/Arden Hills, Minnesota site, a groundwater aquifer is contaminated with volatile organic compounds, notably trichloroethylene (TCE). Two wells supplying drinking water to the local community are contaminated. The remedy initially recommended by the EPA was to construct an activated carbon treatment facility, pipe water from the contaminated wells to the facility, and treat the water to the (then) proposed SDWA MCL for TCE. In response to public pressure, the proposal was modified to connect a third well in anticipation of its eventual contamination and to assure an adequate water supply for periods of high demand. At the Mid-South Wood Products site in Arkansas, soil, surface water, and groundwater were heavily contaminated with arsenic, chromium, and PAHs from wood treating operations. Initially, cleanup of soil to average background levels for arsenic (3 ppm) and 300 ppb PAH, estimated to be equivalent to a 1Q~6 risk level, was proposed. The final proposal was relaxed to maximum background levels for arsenic (5.6 ppm) and 3 ppm PAH (10~s risk level) after public hearings and negotiations with the responsible party. The overwhelming public concern, in fact, was the potential economic impact to the community if the EPA closed the wood treatment facility. CONCLUSIONS The Sierra Club maintains that the EPA is "a disorganized, confused bureaucracy making seat-of-the-pants, poorly documented decisions [on cleanup] that fail to protect public health and violate the law" (Early, 1987). They believe that cleanup standards are being abused, inconsistently and illegally applied, and are subject to negotiation 183\\i>\ with the responsible parties. We believe that this assessment of the EPA's performance in cleaning up Superfund sites is overly harsh. However, the Sierra Club's perception that cleanup standards vary on a site-specific basis and that most Superfund cleanups fall short of returning sites to a pristine condition is correct. Uniform standards cannot be achieved in each cleanup because most sites present terribly complex cleanup problems, and cleanup to federal or state standards is not practical. Remedies to reduce the toxicity, volume, or mobility of hazardous wastes without land disposal are exceedingly expensive, technically difficult, and sometimes unavailable. This situation leaves the EPA with the task of opting for a practical solution, such as providing an alternate water supply, restricting future use of the land, monitoring groundwater, and erecting barriers to prevent off-site migration, while at the same time, defending their actions with carefully crafted narratives or explanations that seek to minimize regulatory, legal, and bureaucratic entanglements or repercussions, As a result, selecting a cleanup level requires the EPA to balance the ideals set forth in SARA against the realities of a complex world. "Clean" becomes whatever can be done at a reasonable cost with the technology available and that the public will accept. REFERENCES Early, A. B., 1987, "Statement before the Subcommittee on Superfund and Environmental Oversight Senate Committee on Environment and Public Works, June 25, 1987," Sierra Club, 330 Pennsylvania Avenue, S.E., Washington, D.C. 20003. EPA (Environmental Protection Agency), 1987, "Superfund program; interim guidance on compliance with applicable or relevant and appropriate requirements; notice of guidance," Federal Register 52: 32496-32499. Harlow, G., 1987, "Superfund update," presented at the International Congress on Hazardous Materials Management, June 8-12, 1987, Chattanooga, Tennessee. HWN (Hazardous Waste News), 1987, "Congress, EPA clash on MCLs for ground water at NPL sites," June 29, 1987, p. 245. Thomas, L., 1987, letter to Senator Frank Lautenberg, May 21, 1987 (reported in Hazardous Waste News, June 1, 1987, p. 205). ACKNOWLEDGMENT This research was sponsored by the U.S. Department of the Navy, Facilities Engineering Command, under Interagency Agreement No. 1791-1791—Al with the U.S. Department of Energy, under Contract No. DE-AC05-84OR21400 with Martin Marietta Energy Systems, Inc. 185 W, V Case Study: FUSRAP in New Jersey (1980-1987) Presented by: James R. Kannard, Bechtel National, Inc. 187 CASE STUDY: FUSRAP IN NEW JERSEY 1980 - 1987 Presented by: James R. Kannard Bechtel National, Inc. The State of New jersey brings to mind a number of images, most of which are associated with its proximity to New York City. It is not strictly, however, a state of big city problems and industrialization. It is a state of striking contrasts; and in a similar way, DOE's Formerly Utilized Sites Remedial Action Program (FUSRAP) in New jersey is a program of contrasts. FUSRAP in New Jersey consists of five sites, representing 17% of all sites in the FUSRAP program. Two of those sites, Kellex in Jersey city and DuPont in Deepwater, have not been included in recent program activities, and the case study will concentrate only on the other three - one in Middlesex, one in Wayne, and one in Maywood. Each of these is being used as an interim storage site for contaminated material from vicinity properties. Each also represents a distinct stage of completion of interim remedial action. Middlesex is complete, Wayne is nearing completion, and Maywood is still in the characterization stage with some remedial action also having been accomplished. Contrasts range from drastically different attitudes in the public and local government sector to significant differences in quantities of contaminated materials, and the mechanisms by which these migrated to vicinity properties. And, in each case, the main concern on the part of the public is lack of a location for permanent disposal. These issues along with the history, objectives, and accomplishments for each site are discussed. 189 CASE STUDY: FUSRAP IN NEW JERSEY, 1980 - 1987 James R. Kannard and Thomas M. Dravecky, Bechtel National, Inc., Oak Ridge, TN The U.S. Department of Energy (DOE), through its Formerly Utilized Sites Remedial Action Program (FUSRAP), is responsible for evaluating and decontaminating 29 sites in 12 states, as necessary. These sites were primarily associated with the former Manhattan Engineer District (MED) program dating back to World War II and remain radiologically contaminated above levels currently considered acceptable for unrestricted use. Bechtel National, Inc. (BNI) is the project management contractor for DOE. FUSRAP in New Jersey con- sists of five sites, or 17 percent of all FUSRAP sites. Two of these sites, Kellex in Jersey WAYNE/PEQUANNOCK City and DuPont in Deepwater, have not been included in recent program MIDDLESEX »• THE FORMER MIDDLESEX MUNICIPAL LANDFILL SITE activities. Remedial THE FORMER MIDDLESEX SAMPLING PLANT action at Kellex was completed in 1981, and is planned for the future at DuPont. This presentation will concentrate on the other three sites - one in Middlesex, one in Wayne, and one in Maywood (Figure 1). Each of these is being used as an interim storage site for contaminated material from vicinity properties, and each represents a distinct stage of completion of Figure 1 - Active FUSRAP Sites interimremedial action. in New Jersey Middlesex is complete, Wayne is nearing completion, and Maywood is still in the characterization stage, although some remedial action has been performed. The State of New Jersey brings to mind a number of images, most of which are associated with its proximity to New York city. It is not only, however, a state of big city problems and industrialization. It is a state of striking contrasts, and similarly, FUSRAP in New Jersey is a program of contrasts. These contrasts range from drastically different attitudes towards FUSRAP by the public and local governments 190 to significant differences in the quantities of contaminated materials and the mechanisms by which these materials migrated to vicinity properties. But in each case, the main concern of the public is the lack of a permanent disposal site. These issues as well as the history, objectives, and accomplishments at each site are described in this paper. MIDDLESEX, NEW JERSEY The MED established the Middlesex Sampling Plant (MSP) (Figure 2) in 1943 as a facility for the sampling, storage, and/or shipment of uranium, thorium, and beryllium ores. Ores received at the facility were routinely packaged, weighed, and shipped to processing facilities. Operation of the MSP was terminated in 1955 by the Atomic Energy Commission (AEC), successor to the MED. Later, the AEC used the site for the storage and limited sampling of thorium residues. All AEC activities at the MSP Figure 2 - Location of MSP/MML ended in 1967. On-site and Vicinity structures were decontaminated, and the site was certified for unrestricted use under the guidelines in effect at that time. In 1968, the AEC returned the MSP site to the General Services Administration, which transferred the property to the Department of the Navy. The site served as a reserve training center for the U.S. Marine Corps from .1969 to 1979. In 1980, the MSP was returned to DOE custody (a successor to the AEC). That same year DOE initiated remedial action to clean up properties in the vicinity of the MSP. The Middlesex Municipal Landfill (MML) site was first used as a landfill in the mid-1940s. In 1948, dirt contaminated with pitchblende (high-grade uranium ore) was removed from the MSP and placed en top of the existing fill at the MML. During the course of subsequent landfill operations, layers of cover material were placed over the contaminated material 191 at various depths. The landfill has not been used for solid waste disposal since 1974. FUSRAP objectives at Middlesex were to decontaminate 44 vicinity properties, provide interim storage for the waste material from these properties, transport the material to a permanent disposal site, and decontaminate the MSP to permit its release for unrestricted use. The remedial action at Middlesex was performed over a period of years. In 1980, 15 residential and commercial properties were decontaminated, and 9,400 yd3 of waste were transported to the MSP for interim storage. The contaminated soil was transported to the MSP where it was placed in an interim storage area (Figure 3). Twenty-nine additional properties were Figure 3 - Construction of Interim Storage Pile at MSP decontaminated in 1981 and 1982 and added 25,700 yd3 of waste to the interim storage pile. The remedial action at the MML in 1984 and 1986 (Figure 4) resulted in 31,000 yd3 of contaminated waste, bringing the total amount of waste material transported to the MSP to 66,100 yd3. Although remedial action at the vicinity properties is complete, no further remedial action can be performed at the MSP until a permanent disposal site is selected. At that time, the contaminated materials will be transported to the permanent disposal site, and th° site itself will be decontaminated. Until then, DOE will conduct environmental monitoring to ensure the integrity of the interim storage facility. 192 Figure 4 - Excavation at MML WAYNE, NEW JERSEY The Wayne Interim Storage Site (WISS) (Figure 5) was established in 1984 to provide interim storage for low- level radioactive contamination found in the vicirity of the former Rare Earths, Inc./W.R. Grace plant located in Wayne, New Jersey. From 1948 through 1971 these companies processed monazite sand for thorium used in manufaccur ing industrial products such as mantles for gas lanterns. During Figure 5 - WISS and Vicinity this time, process wastes from the thorium operations were buried un-site, and 193 some were released to a local storm drain as liquid effluent. The storm drain empties into Sheffield Brook, which overflows its banks during periods of heavy rain. Contamination has consequently spread to nearby low-lying areas over the years. In 1948, Rare Earths, Inc. began processing monazite sand at its Wayne Township, New Jersey, facility to extract thorium and rare earths. In 1954, after the Atomic Energy Act was passed, Rare Earths, Inc., received an AEC license to conduct these operations. The Davison Chemical Division of W.R. Grace and Company acquired the facility in 1957, and processing activities continued until July 1971. Wastes and residues from the processing operations included ore tailings, yttrium sludges, and sulfate precipitates. Liquid effluent streams were treated in an on-site waste treatment plant, neutralized, and discharged into Sheffield Brook. Residues were disposed of in an on-site sludge dump. Aft-r processing ceased in 1971, the facility was licensed for storage only. The site was partially decontaminated by W.R. Grace in 1974. Some buildings were razed; the rubble and processing equipment were buried on the property. The remaining buildings were decontaminated, and the on-site disposal areas were covered with clean fill. In iy/4, the U.S. Nuclear Regulatory Commission (NRC) assumed licensing responsibilities formerly held by the AEC. The storage license for the W.R. Grace plant was terminated in 1975 following site decommissioning. The remedial action objectives at Wayne are similar to those in Middlesex: prepare the site as an interim storage facility, decontaminate 16 vicinity properties, provide interim storage for materials from vicinity properties, remove material to a permanent disposal site, and decontaminate the site and a railroad siding in nearby Pequannock, New Jersey. Preparation for interim storage was accomplished in 1984 (Figure 6). In 1985, an on-site building was demolished, a building adjacent to the site was demolished and replaced, and a township park was decontaminated. These activities resulted in 4,000 yd-* of contaminated soil and rubble. In 1986, 19,000 yd-3 of contaminated soil were excavated from Sheffield Brook (Figure 7), which runs off the site and behind some nearby residences; remedial action along the brook has continued into 1987 and is expected to result in an additional 11,000 yd-* of contaminated soil. Interim remedial action should be complete by October 1987. 194 Figure 6 - Construction of Interim Storage Pile at WISS Figure 7 - Excavation at Sheffield brook 195 MAYWOOD, NEW JERSEY The Maywood Interim Storage Site (MISS) (Figure 8) was estab- lished to provide an interim storage site for contaminated materials found in the vicinity of the former Maywood Chemical Works. From 1916 through 1956, the Maywood Chemical Works processed monazite sand for thorium used in manufacturing industrial products such as mantles for gas lanterns. During this time, slurry containing process wastes from the thorium operations was pumped to diked areas west of the plant. Some of these process wastes were removed from the Maywood Chemical Works for use as mulch and fill on nearby properties, thereby contaminating them with radioactive Figure 8 - MISS and Vicinity thorium. In 1932, New Jersey Route 17 was built through this disposal area. In 1954, the AEC issued a license to the Maywood Chemical Works, thereby allowing it to continue to possess, process, manufacture, anc distribute radioactive materials under the auspices of the Atomic Energy Act of 1954. The Maywood Chemical Works stopped processing thorium in 1956 after approximately 40 years of production. The Maywood Chemical Works was sold to the Stepan Company (SC), formerly the Stepan Chemical Company, in 1959. Based on AEC inspections and information regarding the property on the west side of New Jersey State Route 17, the SC agreed to take certain remedial actions. The cleanup began in 1963. In 1966, 8,360 yd3 of waste were removed from the area west of Route 17 and buried on-site in an area now overlain by grass. In 1967, 2,050 yd3 of waste were removed from the same general area and buried on-site in an area which is now a parking lot. In 1968, the SC obtained permission from the AEC to transfer an additional 8,600 yd3 of waste from the south end of the property 196 across Route 17 and bury it on-site in an area where a warehouse was later built. At the request of the SC, a radiological survey of the south end of the property across Route 17 was conducted by the AEC in 1968. Based on the findings of that survey, clearance was granted for release of the property for unrestricted use. At the time of the survey, the AEC was not aware that contaminated materials were present in the northeast corner of the property. In 1968, this portion of the SC property was sold to a private citizen who in turn sold it to a real estate developer. In 1980, the U.S. Nuclear Regulatory Commission (NRC) was notified of elevated radiation levels on this property. This information prompted the NRC to conduct a survey in late 1980 and then request a comprehensive survey to assess the radiological condition of the property. The survey was performed in February 1981 by Oak Ridge Associated Universities with the assistance of a representative from the Region I office of the NRC. In addition, an aerial radiological survey of the SC site, the property across Route 17, and the surrounding area was conducted by EG&G Energy Measurements Group for the NRC in January 1981. This aerial radiological survey resulted in the discovery of other anomalies. In 1984, Oak Ridge National Laboratory surveyed the Lodi area, which is to the south of Maywood; several properties, known as the Lodi vicinity properties, were found to be contaminated with materials from the former Maywood Chemical Wo r k s. The 1984 Energy and Water Appropriations Act authorized DOE to conduct a decontamination research and development project at the site of the former Maywood Chemical Works and properties in its vicinity. During that year, DOE negotiated with the SC to obtain a lease on the land on which the MISS would be established for the interim storage of contaminated materials removed from these properties. The land was transferred to DOE ownership in September 1985 to provide the interim storage site for the waste from vicinity properties (other than the SC) until such time as a decision is made regarding its final disposition. The MISS is the least complete of the New Jersey FUSRAP sites. Although one of the remedial action objectives at the MISS is also to decontaminate vicinity properties in surrounding communities, the number of residential and commercial properties to be decontaminated cannot be firmly established yet because characterization work is still in progress. As with Middlesex and Wayne, this site will 197 provide interim storage for materiais from the vicinity properties (Figure 9), the material will be removed from MISS when a permanent disposal site is selected, and the site will be decontaminated. Figure 9 - Construction of the Interim Storage Pile at MISS To date, 27 residential and commercial properties in the Maywood area have been decontaminated (Figure 10). Eighteen were completed in 1984 resulting in 4,700 yd3 of waste, and an additional 30,200 yd3 were excavated from nine properties in 1985. Table 1 shows the planned and actual totals of commercial, residential, and municipal properties characterized in 1986 and 1987. 198 Figure 10 - Restoration of Residential Property: Foundation was completely removed and replaced during remedial action. TABLE 1 CHARACTERIZATION RESULTS - 1986 AND 1987 Number of Type of Properties Acres Property Planned Actual Planned Actua 1 Commercial 16 14 104.5 104.0 Residential 11 25 3.6 10.0 Municipal 4 3 6.2 4.2 TOTAL 31 42 114.5 118.4 CONTRASTS Although there are similarities between these three sites, e.g., in the approach to the work and the type of work being done, there are important contrasts that affect the planning and execution of the work. Contrasting attitudes toward FUSRAP are apparent among property owners and among the various levels of local government. There are technical 199 contrasts as well, e.g., the manner in which contamination has migrated off of each of the sites has resulted in contrasting patterns of contamination at vicinity propert ies. The home owners whose properties are contaminated have been the most cooperative. The cleanup, or planned cleanup, of these properties has eased the home owners' perceived concern about health, and has eliminated concerns about property values and the ability to sell their homes. Because these concerns are considered the most significant, remedial action at residential properties is always given a high priority. Commercial property owners generally seem to have felt more threatened by remedial action activities, and their attitudes have been mixed: cooperative from the standpoint of wanting their properties certified clean, but cautious in not necessarily believing that everything would go as planned and concerned about the disruption to their operations and thus profitability. Although unspoken, commercial property owners have an additional concern about the potential for lawsuits from employees because of exposure to radioactivity. The group most resistant to remedial action activities, however, has been those local residents not directly affected by these activities. Their response has ranged from a total distrust of the federal government to a general fear of all things nuclear - in particular, having a "radioactive waste dump" in their community with no permanent solution in sight. While resistance to interim storage is intense within municipal boundaries, it increases when discussing transporting contaminated materials across municipal boundaries. The overwhelming opinion is to remove the material away from the local area. Contrasts also exist at the various levels of state and local government. The local levels have shown the most contrast. For example, at Middlesex and Wayne, there has been a very cooperative attitude by local elected officials. At these sites, officials have cooperated with DOE/BNI in community relations, planning, and completing the work. They have consistently aided our efforts by maintaining an atmosphere of confidence and cooperation. As a result, they have generally had the support of their respective constituencies in expediting and completing the work. In contrast to the cooperation in these communities, the situation in Maywood has been different. Through a totally open approach to conducting borough affairs, the mayor and council meetings have provided a monthly, public forum for resistance to every aspect of the work. Even 199 contrasts as well, e.g., the manner in which contamination has migrated off of each of the sites has resulted in contrasting patterns of contamination at vicinity properties. The home owners whose properties are contaminated have been the most cooperative. The cleanup, or planned cleanup, of these properties has eased the home owners' perceived concern about health, and has eliminated concerns about property values and the ability to sell their homes. Because these concerns are considered the most significant, remedial action at residential properties is always given a high priority. Commercial property owners generally seem to have felt more threatened by remedial action activities, and their attitudes have been mixed: cooperative from the standpoint of wanting their properties certified clean, but cautious in not necessarily believing that everything would go as planned and concerned about the disruption to their operations and thus profitability. Although unspoken, commercial property owners have an additional concern about the potential for lawsuits from employees because of exposure to radioactivity. The group most resistant to remedial action activities, however, has been those local residents not directly affected by these activities. Their response has ranged from a total distrust of the federal government to a general fear of all things nuclear - in particular, having a "radioactive waste dump" in their community with no permanent solution in sight. While resistance to interim storage is intense within municipal boundaries, it increases when discussing transporting contaminated materials across municipal boundaries. The overwhelming opinion is to remove the material away from the local area. Contrasts also exist at the various levels of state and local government. The local levels have shown the most contrast. For example, at Middlesex and Wayne, there has been a very cooperative attitude by local elected officials. At these sites, officials have cooperated with DOE/BNI in community relations, planning, and completing the work. They have consistently aided our efforts by maintaining an atmosphere of confidence and cooperation. As a result, they have generally had the support of their respective constituencies in expediting and completing the work. In contrast to the cooperation in these communities, the situation in Maywood has Deen different. Through a totally open approach to conducting borough affairs, the mayor and council meetings have provided a monthly, public forum for resistance to every aspect of the work. Even 200 mundane activities like hauling clean fill material on-site are reported with accusations that DOE is bringing in more contamination. As a result, no remedial action has been conducted this year, and none is planned for next year. At the state level, officials originally were resistant to suggestions that FUSRAP materials be disposed of within the State of New Jersey. This reluctance was understandable given the public resistance they have encountered regarding a solution to radium contamination problems with another State of New Jersey project. Through continued negotiations between DOE representatives and state officials, a spirit of cooperation has evolved and a joint effort to identify a repository within the state has been initiated. Another contrast between these sites is in the quantity of contaminated material that is present on-site, and the quantity that has migrated to off-site vicinity properties. Where nature has provided the mechanism, investigations have been relatively straightforward. Man's intervention, on the other hand, has spread contamination into the vicinity properties and shown no logical pattern. Identifying these pathways of contamination is a constant technical challenge. Table 2 provides these quantities. TABLE 2 QUANTITIES OF CONTAMINATED MATERIAL ON-SITE VERSUS QUANTITIES THAT HAVE MIGRATED OFF-SITE Volume (yd3) Off-Site Natural Man- Site On-Site Pathways Moved Total Middlesex 22,000 33,000 33,000 88,000 Wayne 70,000 35,000 0 105,000 Maywood 7 3,000 25,000 247,000 345,000 Total 165,000 93,000 280,000 538,000 FUTURE PLANS FOR THE FUSRAP SITES IN NEW JERSEY The interim storage sites in New Jersey will continue to be maintained, and surveillance and maintenance at these sites will continue to ensure that the contamination is contained. Work will continue in Maywood to resolve the problems that prevent the completion of interim remedial action. A major effort will be to select a permanent disposal site in New Jersey. After this situation is resolved, the material at each of the sites can be transported to the permanent disposal site, the sites decontaminated, and then released for unrestricted use. Hazardous Waste Minimization Practices Presented by: Bruce E. Boggs, Engineering-Science, inc. HAZARDOUS WASTE MINIMIZATION PRACTICES D. C. Lane, P.E. Engineering-Science, Inc. Atlanta, Georgia and B. E. Boggs Engineering-Science, Inc. Atlanta, Georgia Amendments, In 1984, to the Resource Conservation and Recovery Act require generators of hazardous waste to certify that those generators are evaluating methods to minimize the production of those wastes. Hazardous waste minimization has obvious economic benefits as well as environmental and regulatory compliance aspects. This paper reviews waste minimization practices of several industries and government agencies. These practices which are reviewed range from "up front" process changes, which reduce the nature or amount of waste generated, to recycling practices utilizing the waste generated and thereby removing it from the universe of wasted resources. 207 OAK RIDGE MODEL CONFERENCE OCTOBER, 1987 WASTE MINIMIZATION OAK RIDGE MODEL CONFERENCE TECHNICAL PAPER BRUCE E. BOGGS ENGINEERING-SCIENCE ATLANTA,GA. ENGINEERING-SCIENCE 208 OAK RIDGE MODEL CONFERENCE OCTOBER, 1987 WASTE MINIMIZATION • WHAT IS IT? • WHY DO IT? WHO NEEDS IT? HOW TO DO IT ENGINEERING-SCIENCE 209 OAK RIDGE MODEL CONFERENCE OCTOBER, 1987 DEFINITIONS OF WASTE MINIMIZATION WHAT IS IT? THE USEPA SAYS WASTE MINIMIZATION IS: • WASTE RECYCLING • WASTE SEGREGATION • VOLUME REDUCTION AFTER GENERATION (Such as Dewatering, Evaporation, Etc.) • SOURCE CONTROL - PRODUCING LESS WASTE • ALTERNATIVE TREATMENT (Except Incineration) EPA ALSO ALLOWS 'TOXICITY REDUCTION" AS A CERTIFICATION SINCE BOTH 'MINIMIZATION' AND 'TOXICITY REDUCTION' ARE MANDATED. • PRODUCT SUBSTITUTION • TREATMENT TO REDUCE TOXICITY (Chemical Treatment) • TREATMENT TO EFFECT IMMOBILIZATION (Fixation) • CONCENTRATION REDUCTION OFFICE OF TECHNOLOGY ASSESSMENT SAYS: • IT IS ONLY SOURCE CONTROL* •THIS DISAGREEMENT s A/ BE RESOLVED BY LEGISLATION OR REGULATIONS. ENGJNEERING-SC1ENCE 210 OAK RIDGE MODEL CONFERENCE OCTOBER, 1987 WHY MINIMIZE WASTES? MANDATES IN RESOURCE CONSERVATION AND RECOVERY ACT • CERTIFICATIONS ON MANIFESTS • PART B PERMIT PARAMETER • BI-ANNUAL REPORT DETAIL ITEM LIABILITY REDUCTION • SARA/CERCLA ACTIONS ILLUSTRATE "LINGERING LIABILITY' • EMPLOYEE EXPOSURE REDUCTION • TRANSPORTATION EXPOSURES COST/ COMPETITIVENESS • REDUCED COSTS IN TREATMENT/DISPOSAL • PRODUCTIVITY IMPROVEMENTS • INSURANCE COST REDUCTION • GREATER MARKET SHARE PUBLIC RELATIONS • PUBLIC IMAGE • EMPLOYEE'S EVALUATION • EPA/AGENCY IMAGE ENGINEERING-SCIENCE 211 OAK RIDGE MODEL CONFERENCE OCTOBER. 1987 LIABILITY FOR FAILURE TO COMPLY OR FALSE CERTIFICATION Failure to comply with the waste minimization requirements or submitting a false certification on a manifest may lead to civil or criminal sanctions. For example, certifying that a waste minimization program is in place when you know it is not, may result in imprisonment for up to two years. On the other hand, civil penalties for failure to implement a waste minimization program may result 1n a fine of up to $50,000 per day. ENGINEERING-SCIENCE J 212 r WASTE MINIMIZATION AND/OR TOXICITY REDUCTIONNl! STEP 1 DEVELOP DATA BASE YOU CAN'T MINIMIZE THE UNKNOWN. 'EXAMPLE DATA BASE DEVELOPMENT STEP 2 SELECT MODE/AREA OF MAXIMUM IMPACT. FOR EXAMPLE: Pre-Process In Process End of Pipe DAW PROCESS TREATMENT KAW AND AND DISPOSAL MATERIALS OPERATIONS OR RECYCLE Options Options Options *Raw Material Sources •Housekeeping Bulk Disposal Product Substitution Waste Segregation Volume Reduction •Maintenance Toxicity Reduction Batch to Continuous (Fixation) Drum to Bulk •Recycle/Reuse •Equipment Changes •Materials of Con- struction •Process Changes •Example Project •Example Project •Example Project Low Vanadium Oil SPCC Project incor- Gypsum Substitution as fuel. porating all the Reuse. above. STEP 3 IMPLEMENT (REMEMBER ECONOMICS START FROM A NEGATIVE POINT - WASTE REDUCTION IS A "CREDIT" OPERATION) STEP 4 MAINTAIN DATA BASE TAKE CREDIT FOR YOUR EFFORTS •Vignettes noted by asterisk. ENGINEERING-SCIENCE' 213 OAK RIDCE MODEL CONFERENCE OCTOBER, 1987 SAMPLE WASTE MINIMIZATION PRACTICES SUMMARY OF INFORM* STUDY IN ORGANIC CHEMICALS INDUSTRY EFFECT OF COMPANY MINIMIZATION PRACTICE CHANCE IN WASTE ATLANTIC Process change in manufacture of dyes 305,000 fl/Yr Reduction CIBA-GEIGY (a) Process change in catalyst for mano- 100% Reduction facture of dyes (b) Process change 25% Reduction Prevents chromium loss (c) Process optimization of pH conditions 10-10% DOW Waste segregation and reuse MERCK (a) Process change w/solvent recovery 2.6 million#/Yr Reduction (Methylene Chloride) (b) Process change w/solvent recovery 123,000 #/Yr Reduction (Isoamyl Alcohol) (c) Process change w/solvent recovery 230,000 I/Yr Reduction (Acetone) (d) Recycle of HCL gas MONSANTO Process change from batch to 99.7% continuous PERSTOP Product change 100% SHERWIN WILLIAMS (a) Recycle of TCB OVER ALL RESULTS INDUSTRY Process Changes 18 out of 16 WIDE PRACTICES Operational Changes 11 out of 16 Equipment Changes 9 out of 16 Product Reformulations 3 out of 16 Chemical Substitution 2 out of 16 * From Cutting Chemical Wa^es 1985 Inform ENGWEERING-SCIENCE' OAK RIDGE MODEL CONFERENCE OCTOBER, 1987 Tatici;;- r*i-jiij.-. is .-.craally acec-opiished by on* or acre of .'our ii;ir trcrcac-.es. r-.ese four approaches ire: Cptic.-- ' - 3»?lace3er.t of toxic aaterial with a.-.othsr less toxic Satenal. r?tic= I - C-esical, physical or Siolccical conversion of the toxic c-capep.er:t to less toxic f orris . :?tior. 2 - O.eiical or physical isacbilizaticn of the toxic :ca- pcne-t without a C-.ar.ce m c.".«=icai fora. Cpticn 4 - Ktcsvtv isd ze\is» of t-"-.« taxio ccopcn«nt. C?tiO7. " is :cs: sfttn investigated vitivin tn« research and -e- •.•eljceer.t facilities c.1 isiustriii corporacior.s since it nay iwcl-'e crcduct i = = act concerns. lotions I i.-.rough 4 are areas m wr.icr. £ngi.-e*ri.-.5-3ci»r.oe *as cor.siierasie axpertisa anc aora specifically, areas I ind 3 are addressed ir- t>.is paper. Prefect examples discussed -elow i-vclve icth c.-.eanal conversion ar^i fixation. aiolocical Cnejical Conversicr. ts Reduce Toxicity ihgmeennq-Science conducted a texicity reduction evalu.it study for an organic cneaicals manufacturer i.i Georgia, 're first pYz.- of tne study vas to conduct a coaplate cnesicai analysis o! z'r.e discharge to identify pcssiole toxic ccopounds. Pros tnis testir.c un-ioni2ed aononia was identified as the causative reagent. Next, iiaassays were conducted to conjim th« un-ionised asoonia toxicity. T?>a3« tests consisted of removing un-ionized aoiaonia either by nitn- ficationr pH ad^uststent, or air stripping and then spiking the effl-t.:r K to the original ammonia concentration. T?ie -C-o data collected fo: - .^ amraonia toxicity was very siaila.v to the t-"-a dita presented in '_ie literature- T^ie study reccaaended increasing the sludge age to ach^ve nitrification and reducing the effluent toxicity. Recoraendations nave now been implemented to lower effluent aoatoni* concentration. Physical Immobilization to Seduce Toxicity af Inorganic Arsenic A waste high ia arsenic content produced as a Sy-product in acid manufacture was treated Sy various fixation techniques and then leached by two mchods to evaluate effectiveness of fixation alternatives and effect of EP versus TCX.P leaching procedures. A raatrix to evaluate cost, technical effectiveness, operational parameters and other con- siderations was developed to select the best method of toxicity reduc- tion. J 215 I',} I (^ Y-12 Plant Waste Minimization Strategy Presented by: Michael A. Kane, Y-12 217 Y-12 PLANT WASTE MINIMIZATION STRATEGY Michael A. Kane Health, Safety, Environment, and Accountability Division Oak Ridge Y-12 Plant* Martin Marietta Energy Systems, Inc. Oak Ridge, Tennessee 37831 ABSTRACT The 198A Amendments to the Resource Conservation and Recovery Act (RCRA) mandate that waste minimization be a major element of hazardous waste management. In response to this mandate and the increasing costs for waste treatment, storage, and disposal, the Oak Ridge Y-12 Plant developed a waste minimization program to encompass all types of wastes. Thus, waste minimization has become an integral part of the overall waste management program. Unlike traditional approaches, waste minimization focuses on controlling waste at the beginning of production instead of the end. This approach includes: (1) substituting nonhazardous process materials for hazardous ones, (2) recycling or reusing waste effluents, (3) segregating nonhazardous waste from hazardous and radioactive waste, and (A) modifying processes to generate less waste or less toxic waste. An effective waste minimization program must provide the appropriate incentives for generators to reduce their waste and provide the necessary support mechanisms to identify opportunities for waste minimization. This presentation will focus on the Y-12 Plant's strategy to implement a comprehensive waste minimization program. This approach consists of four major program elements: (1) promotional campaign, (2) process evaluation for waste minimization opportunities, (3) waste generation tracking system, and (A) information exchange network. The presentation will also examine some of the accomplishments of the program and issues which need to be resolved. *Operated for the U.S. Department of Energy by Martin Marietta Energy Systems, Inc., under contract DE-AC05-8AOR21A00. 219 Y-12 PLANT WASTE MINIMIZATION STRATEGY MICHAEL A. KANE OAK RIDGE MODEL CONFERENCE OAK RIDGE, TENNESSEE OCTOBER 14, 1987 MAFtTilV MARIETTA Oak Ridge Y-12 Plant Operated by Martin Marietta Energy Systems, Inc. for the U.S. DEPARTMENT OF ENERGY under contract DE-ACO5-84OR21400 220 OBJECTIVES OF THE Y-12 PLANT WASTE MINIMIZATION PROGRAM 0 FOSTER A PU\NT-WIDE PHILOSOPHY TO CONSERVE RESOURSES AND CREATE A MINIMUM OF WASTE AND POLLUTION IN ACHIEVING Y-12 PLANT STRATEGIC OBJECTIVES 0 PROMOTE THE USE OF NONH/ZARDOUS MATERIALS IN Y-12 PLANT OPERATIONS TO MINIMIZE THE POTENTIAL RISKS TO HUMAN HEALTH AND THE ENVIRONMENT 0 REDUCE OR ELIMINATE THE GENERATION OF WASTE MATERIALS THROUGH PROCESS CHANGES JO ACHIEVE MINIMAL ADVERSE EFFECT ON THE AIR, WATER, AND LAND 0 SATISFY THE REQUIREMENTS FOR WASTE MINIMIZATION SET FORTH IN THE RESOURCE CONSERVATION AND RECOVERY ACT AND DEPARTMENT OF ENERGY POLICIES 221 INCENTIVES AND DISINCENTIVES FOR WASTE MINIMIZATION 0 INCENTIVES - INCREASING COSTS OF WASTE TREATMENT, STORAGE, AND DISPOSAL - FUTURE LIABILITY - DIFFICULTIES IN MANAGING HAZARDOUS WASTE - REGULATORY 0 DISINCENTIVES - ATTITUDE TOWARD UNFAMILIAR METHODS - UNAVAILABILITY OF INFORMATION - CONCERNS WITH PRODUCT QUALITY - REGULATORY 222 WHAT IS WASTE MINIMIZATION? 0 WASTE MINIMIZATION IS THE REDUCTION IN QUANTITY AND TOXICITY OF WASTE GENERATED. TECHNIQUES INCLUDE: - PROCESS INNOVATION AND IMPROVEMENT - MATERIAL SUBSTITUTION - RECYCLE/REUSE - WASTE SEGREGATION 0 WASTE MINIMIZATION IS NOT: - TREATMENT OF WASTE FOR DISPOSAL - MECHANICAL VOLUME REDUCTION BY SHREDDING OR COMPACTION 223 MULTIMEDIA APPROACH TO WASTE REDUCTION 0 POLLUTION CONTROL DEVICES FOR ONE ENVIRONMENTAL MEDIUM OFTEN RESULT IN WASTE BEING TRANSFERRED TO ANOTHER MEDIUM. 0 AN EFFECTIVE WASTE MINIMIZATION PROGRAM MUST INCLUDE A MULTIMEDIA APPROACH TO REDUCING WASTES GOING INTO THE AIR, WATER, AND LAND. 224 Y-12 PLANT WASTE MINIMIZATION STRATEGY THE Y-12 PLANT STRATEGY JO IMPLEMENT A COMPREHENSIVE WASTE MINIMIZATION PROGRAM CONSISTS OF THE FOLLOWING ELEMENTS: - WASTE MINIMIZATION INCENTIVE CAMPAIGN - COMPREHENSIVE WASTE TRACKING SYSTEM - INFORMATION EXCHANGE NETWORK - PROCESS EVALUATIONS FOR WASTE MINIMIZATION OPPORTUNITIES 225 WASTE MINIMIZATION INCENTIVE CAMPAIGN 0 PROMOTE WASTE MINIMIZATION PHILOSOPHY - POSTERS - NEWSLETTERS 0 RECOGNIZE OUTSTANDING ACHIEVEMENTS 0 OBTAIN AND DEMONSTRATE MANAGEMENT COMMITMENT 0 EXPAND DIRECT CHARGING OF GENERATORS FOR WASTE TREATMENT AND DISPOSAL 226 COMPREHENSIVE WASTE GENERATION TRACKING SYSTEM A COMPREHENSIVE WASTE GENERATION TRACKING SYSTEM WILL PROVIDE THE MECHANISM JO IDENTIFY TRENDS AMD MEASURE ACHIEVEMENTS. SUCH A SYSTEM WILL INCLUDE THE ABILITY TO: - TRACK AIR EMISSIONS, WASTEWATERS, AND SOLID WASTE - IDENTIFY WASTE STREAMS BY .GENERATOR - IDENTIFY WASTE STREAMS BY SPECIFIC WASTE CATEGORIES - MONITOR HAZARDOUS MATERIAL PURCHASES - PROVIDE WASTE GENERATION BASELINE 227 INFORMATION EXCHANGE NETWORK THE LONG-RANGE GOAL IS TO ESTABLISH AN INFORMATION EXCHANGE NETWORK WHICH WILL: - IDENTIFY EXAMPLES OF WASTE MINIMIZATION SUCCESSES - REPORT NEW CONCEPTS IN WASTE MINIMIZATION 228 PROCESS EVALUATION FOR WASTE MINIMIZATION OPPORTUNITIES 0 PRIORITIZE WASTE STREAMS 0 CONDUCT WASTE AUDITS AND IDENTIFY OPPORTUNITIES 0 EVALUATE ALTERNATIVES 0 FOCUS RESOURCES OH AREAS OF GREATEST REWARD 0 REVIEW NEW CAPITAL INITIATIVES FOR WASTE MINIMIZATION OPPORTUNITIES 229 WASTE MINIMIZATION ACTIVITIES AND ACHIEVEMENTS WASTE MINIMIZATION ESTIMATED ACTIVITY WASTE TYPE REDUCTION WASTE ACID REDUCTION MIXED 280,000 GAL/YR LOW-LEVEL RAD TRASH RADIOACTIVE 135,000 CU. FT SEGREGATION REUSE NITRIC ACID RADIOACTIVE 9000 GAL/YR PICKLING BATH TILE REMOVER SUBSTITUTION HAZARDOUS 400 LB/YR 230 ISSUES TO BE RESOLVED 0 ALTERING CHARACTERISTICS OF WASTEWATERS TO BE TREATED 0 MEASURING WASTE MINIMIZATION ACHIEVEMENTS AGAINST PRODUCTION FLUCTUATIONS 0 DEFINING WASTE MINIMIZATION 231 SUMMARY 0 AN EFFECTIVE WASTE MINIMIZATION PROGRAM MUST PROVIDE: - INCENTIVES TO REDUCE WASTE - SUPPORT MECHANISMS TO IDENTIFY OPPORTUNITIES AND MEASURE ACHIEVEMENTS 0 THE Y-12 PLANT STRATEGY CONSISTS OF FOUR IMPORTANT ELEMENTS: - INCENTIVE CAMPAIGN - WASTE GENERATION TRACKING SYSTEM - INFORMATION EXCHANGE NETWORK - PROCESS EVALUATIONS 233 Process for Volume Reduction of Solution Recovery Raffinate for the Portsmouth Gaseous Diffusion Plant (PORTS) Presented by: R, D. Bundy, ORGDP 235 K/QT-126A PROCESS FOR VOLUME REDUCTION OF SOLUTION RECOVERY RAFFINATE FOR THE PORTSMOUTH GASEOUS DIFFUSION PLANT (PORTS) R. D. Bundy and R. B. Alderfer Systems and Equipment Technology Department Quality and Technical Services Division Oak Ridge Gaseous Diffusion Plant Oak Ridge, Tennessee 37831 Operated by Martin Marietta Energy Systems, Inc. for the United States Department of Energy ABSTRACT A direct calcination process is being developed for the disposal of raffinate waste at PORTS. The present raffinate disposal process is a multistep treatment, which creates large volumes of solid waste. A one-step process should have lower operating costs and reduce waste volumes considerably. The flowsheet for the direct calcination process contains an evaporator for concentrating the raffinate, a condenser for condensing the water that is evaporated, a condensate cooler, a rotary kiln calciner, a water scrubber for removing the N0x formed by the decomposition of nitrates during calcination, a refrigerated condenser for drying the gas leaving the water scrubber, chemical traps, and a HEPA filter. The feasibility of the direct calcination process was demonstrated in a bench-scale pot calcination system. The two primary requirements of the process were satisfied at a calcination temperature of 715°F: virtually all of the technetium was retained in the calcined solids while all of the nitrates were decomposed to oxides. The results of the bench-scale tests are being verified using a laboratory- scale rotary kiln calciner. The submitted manuscript has been authored by a contractor of the U.S. Government under Contract No. DE- AC05-84OR21400. Accordingly, the U.S. Government retains a nonexclusive, royalty-free license to publish or repro- duce the published form of this contri- bution, or allow others to do so, for U.S. Government purposes. PROCESS FOR VOLUME REDUCTION OF SOLUTION RECOVERY RAFFINATE FOR THE PORTSMOUTH GASEOUS DIFFUSION PLANT R. D. BUNDY R. B. ALDERFER SYSTEMS AND EQUIPMENT TECHNOLOGY DEPARTMENT QUALITY AND TECHNICAL SERVICES DIVISION OAK RIDGE GASEOUS DIFFUSION PLANT OPERATED BY MARTIN MARIETTA ENERGY SYSTEMS, INC. FOR THE T* .**«, ™™ H., ^ U.S. DEPARTMENT OF ENERGY authored by a contractor of the US ZSSSSEa&Z: ASJV.I Si P. O. BOX P, OAK RIDGE, TN 37831 Govwnnwm retains a nonaxckniv*. royaltv-ff«a licansa to putjlrth or rgproducs the pubfelwd lotm ol this contribution, or •low oth«M to do so, (or U.S. Government Durposas." 0 a z o PROCESS FOR VOLUME REDUCTION OF SOLUTION RECOVERY RAFFINATE FOR THE PORTSMOUTH GASEOUS DIFFUSION PLANT BACKGROUND K oo PROPOSED PROCESS BENCH-SCALE POT CALCINATION STUDIES ROTARY-KILN CALCINATION TESTS i*tA*fry-in/ m/\ffi INTRODUCTION SOURCE OF RAFFINATE - WASTE FROM CHEMICAL AND DECONTAMINATION OPERATIONS COMPOSITION OF RAFFINATE - VARIABLE - CONTAINS MANY HAZARDOUS AND RADIOACTIVE MATERIALS CO PRESENT PROCESS FOR RAFFINATE TREATMENT IS MULTISTEP - HEAVY METALS PRECIPTATION - FILTRATION - ION EXCHANGE - BIODENITRIFICATION PRESENT PROCESS GENERATES A LOT OF SOLID WASTE /HA* FT TIM MARIETTA TYPICAL RAFFINATE COMPOSITION COMPOSITION SUBSTANCE ppm URANIUM 38 (9% U-235) TECHNETIUM 28 CADMIUM 8 LEAD 56 ALUMINUM 9700 IRON 4500 S NICKEL 540 NITRATE 212,000 SULFATE 2200 MERCURY 2 STRONTIUM 3 COPPER 490 ZINC 150 FLUORIDE BLOCK FLOW DIAGRAM FOR DIRECT RAFFINATE CALCINATION FLOWSHEET • COOLING P WATER z 0 0 © REFRIG. VAPOR 0 CONDENSER 13 PSIA CONDENSER GAS^—' NON COND. GAS 12.5 PSIA 0 1BLOWER o EVAPORATION CONDENSATE RAFF. FEED 14.3 PSIA 50,000 L/Mo CONDENSATE COOLER CaCO3 COOLING CaCO3 WATER TRAP 15 PSIA SPENT CaCOo CGNC. RAFF.SOLN. PUMP 0 HEPA FILTER CONTAMI- NATED FILTERS CALCINER © OFF GAS SCRUBBER 14 PSIA LIQUID OFF GAS (PACKED PRODUCT COLUMN) VENT © 13 PSIA SOLIDS FLOWSHEET DEVELOPMENT DETAILED MATERIAL BALANCES WERE CALCULATED FOR ALL COMPONENTS ROUGH DESIGNS WERE DONE FOR ITEMS OF PROCESS EQUIPMENT - AID IN DEFINING PROCESS PROBLEMS AND UNCERTAINTIES - RELATE BENCH-SCALE RESULTS TO FULL-SCALE PROCESS - PERMIT BETTER COST ESTIMATES - GIVENINK/QT-105 MA FT TIN IMA HIS FLOWSHEET DEVELOPMENT- MATERIAL BALANCES • PROCESS ASSUMPTIONS - PROCESS 50,000 L/mo OF RAFFINATE - USE 2 LINES OPERATING 40 h/wk - 75% ON-STREAM EFFICIENCY - CLOSED PROCESS ro - CALCINATION TEMPERATURE: 715°F CO - TECHNETIUM DISTRIBUTION • CALCINATION ASH: 89% • NITRIC ACID PRODUCT: 5.5% • OFF GAS (BEFORE TREATMENT): 5.5% FLOWSHEET DEVELOPMENT- MATERIAL BALANCES (CONTINUED) FLOW RATES/LINE - RAFFINATE: 237 kg/h - REUSABLE 27 vvt % NITRIC ACID: 227 kg/h - calcination ash: 2.3 kg/h - VENT: 8 hg/h OXYGEN - Tc CONTAMINATED LIMESTONE: 3.3 kg/h (5.1 MT/yr) o ADVANTAGES OF DIRECT CALCINATION PROCESS SUBSTANTIAL REDUCTION IN SOLID WASTES ro POTENTIALLY LOWER OPERATING COSTS RECYCLE OF NITRATES IS IMPORTANT 0 B z p 9 TECHNICAL UNCERTAINTIES NATURE OF EMISSIONS (BOTH PARTICULATE AND GASEOUS, E.G., NOx) NEED FOR AND TYPE OF POLLUTION ABATEMENT MATERIALS OF CONSTRUCTION RATE AND EXTENT OF PRECONCENTRATION NATURE OF CALCINED SOLIDS MATERIAL BALANCES OPERATING CONDITIONS BENCH-SCALE POT CALCINATION TESTS WOULD ANSWER MANY OF THE UNCERTAINTIES RELATIVELY INEXPENSIVE WERE CONDUCTED AT ORGDP BENCH SCALE SYSTEM FOR DIRECT CALCINATION OF RAFFINATE WASTE STAINLESS TUBE DRYERS o p 2 o-'o • (» 0 " 1 r- "I 1 ,», ,1" '• FOGGING NOZZLE ; •' 5'x 15' t 0 = 4" • * I* EXHAUST t N2PURGE ANDERSON SILICA GEL IMPINGERS PHOTOGRAPH OF BENCH-SCALE POT CALCINATION SYSTEM FLUSH LINE LABORATORY CONDENSERS E DRY GAS METER POT CALCINER REFRIGERATED COLLECTION BATH FLASK CONTAINING IMPINGEBS SCRUBBER RECYCLE PUMP REFRIGERATION SYSTEM BENCH-SCALE POT CALCINATION STUDIES SEVEN CALCINATION TESTS: 2 EVAPORATION ONLY TESTS ONE TEST OF EACH TYPE USED SIMULATED RAFFINATE: THE REMAINDER USED ACTUAL TYPICAL RAFFINATE DURING ONE TEST, THE CONDENSER WAS NOT USED DURING THE CALCINATION PHASE; DURING ANOTHER TEST, THE SCRUBBER WAS NOT USED DURING THE EVAPORATION PHASE. en o EVAPORATION PHASE - PRESSURE: 7-10 IN. Hg VACUUM - LIQUID TEMPERATURE: 216-231°F - PERCENT EVAPORATED: 51-82 (60-66 FOR MOST TESTS) CALCINATION PHASE - PRESSURE: 6-9 IN. Hg VACUUM - TEMPERATURE: 600-1200°F (1000°F FOR MOST TESTS) RESULTS - EVAPORATION TESTS SOLIDS PRECIPITATED FROM THE CONCENTRATED RAFFINATE BELOW 65°C. ALL OF THE Tc WAS RETAINED IN THE POT. SOME METALS AND NITRATE WERE CARRIED OVER WITH THE CONDENSATE; THE PROPORTIONS CARRIED OVER INCREASED WITH THE FRACTION EVAPORATED. SEVERAL PERCENT OF THE U ESCAPED FROM THE POT AND SCRUBBER INTO THE OFF GAS. ABOUT TWO-THIRDS OF THE NITRATES WERE DECOMPOSED DURING THE EVAPORATION PHASE WHEN 80% OF THE RAFFINATE WAS EVAPORATED. RESULTS - CALCINATION TESTS THE WEIGHT OF CALCINED SOLIDS WAS 4-5% OF THAT OF THE RAFFINATE FED FOR CALCINATION TEMPERATURES FROM 700-1000°F. A SINGLE TEST AT 715°F INDICATED THAT VIRTUALLY ALL OF THE TECHNETIUM WAS RETAINED IN THE CALCINED SOLIDS WHILE ALL OF in THE NITRATES WERE DECOMPOSED TO OXIDES. WITH CALCINATION TEMPERATURES OF 1000°F, OR MORE, PART OF THE Tc ESCAPED FROM THE CALCINATION POT TO THE SCRUBBER. AT CALCINATION TEMPERATURES MUCH BELOW 700°F, NOT ALL OF THE NITRATES WERE DECOMPOSED TO OXIDES. RESULTS - CALCINATION TESTS | (CONTINUED) g THE MAJORITY OF THE URANIUM REMAINED IN THE POT SOLIDS EXCEPT DURING THE TEST AT THE HIGHEST CALCINATION TEMPERATURE (1200°F). MOST METALS WERE RETAINED IN THE POT SOLIDS. en THE CALCINATION TEMPERATURE HAD AN EFFECT ON THE DISTRIBUTION OF to MOST METALS. SIGNIFICANT AMOUNTS OF Al, Cd, Fe, Pb, Sr, U, AND Zn WERE FOUND IN THE CONDENSER LIQUID WITH THE HIGHEST CALCINATION TEMPERATURE. ALL OF THE Hg WAS COLLECTED IN THE CONDENSER FLASK FOR THOSE TESTS THAT IT WAS USED. RESULTS - OFF GAS TREATMENT THE REMOVAL EFFICIENCY OF THE WATER SCRUBBER WAS 93.5% (SD = 6.5%) FOR NITRATES. THE REMOVAL EFFICIENCY OF THE SCRUBBER WAS HIGH FOR MOST METALS. THE REMOVAL EFFICIENCY OF THE SCRUBBER WAS LOW FOR URANIUM AND SULFATE. g THE REMOVAL EFFICIENCY OF THE SILICA GEL CHEMICAL TRAP WAS MODEST FOR MOST MATERIALS. THE REMOVAL EFFICIENCY OF THE LIMESTONE CHEMICAL TRAP WAS LOW FOR MOST MATERIALS. NEITHER THE LIMESTONE NOR THE SILICA GEL CHEMICAL TRAPS REMOVED ANY URANIUM. RESULTS - CORROSION THE POT CALCINER WAS MADE FROM 309 STAINLESS STEEL. - SIMILAR TO HH TYPE 2 STEEL - 25%Cr-12%Ni REMAINDER OF SYSTEM WAS MADE FROM 304L STAINLESS STEEL en en THERE WERE NO VISABLE SIGNS OF CORROSION. MATERIAL BALANCES DO NOT INDICATE THAT SIGNIFICANT AMOUNTS OF Cr, Ni, OR Fe WERE LEACHED FROM THE METAL COMPONENTS OF THE SYSTEM. WEIGHT LOSS OF POT CALCINER CORRESPONDS TO A UNIFORM CORROSION RATE OF 20 MILS IN 2 YEARS OF 40 HOUR/WEEK OPERATION. 0 REASONS FOR ROTARY KILN TESTS VERIFY POT CALCINER RESULTS. - OBTAIN ADDITIONAL DATA. - ANY DIFFERENCES BETWEEN THE RESULTS FOR A POT CALCINER AND FOR A ROTARY KILN CAN BE OBSERVED. § OBTAIN ADDITIONAL DATA ON THE PERFORMANCE OF THE OFF-GAS TREATMENT SYSTEM. INVESTIGATE FEED PROBLEMS AND FEED RATE EFFECTS. SCHEMATIC DIAGRAM OF ROTARY KILN CALCINATION SYSTEM o CONC. RAFF 2 FLOWMETER 0 7. T TRACING 0 ^V^2nd. POT (CONC. STORAGE) J CLAMSHEELHEATER FLUSH FILL GAS TRACING EMERG. EXHAUST H -«-CALCINER / 2° FLOW METER DRY GAS 0- CLAM METER SHELL CONDEN- HEATER SATION jj^JLrjv- SCRUBBER (220V) TO ROOF_ FLOW SCRUBBER OvEN-^ \LHEAT TRACING METER EVAPORATOR H2O DRAIN -H2OPUMP ( }*~SOLIDS FLOWMETER V COLLECTION LABORATORY-SCALE ROTARY KILN CALCINER SYSTEM on CD OWG. NO. K/G-B7-1739 259 LABORATORY-SCALE ROTARY KILN CALCINER COMPONENTS OF LABORATORY-SCALE ROTARY KILN CALCINER 3.5-in. ROTATING CALCINER BARREL ro d o STATIONARY CALCINER 3/4-in. INTERNALS SCRAPEr CENTER BLADES TUBE DWG. NO. K/G-S7-1740 261 CONCENTRATED RAFFINATE STORAGE POT /•*>»/? 7-//V IWAft I ETTA STATUS OF ROTARY KILN CALCINATION STUDY SYSTEM HAS BEEN SHAKEN DOWN USING WATER AND SIMULATED CONCENTRATED RAFFINATE. FIRST TEST USING ACTUAL RAFFINATE IS IN PROGRESS. ntA rr TIN, I*TA* m/E- TTA CONCLUSIONS DIRECT CALCINATION OF PORTSMOUTH RAFFINATE WASTE IS FEASIBLE NITRATES ARE DECOMPOSED AND Tc IS RETAINED IN THE CALCINED SOLIDS ~ AT A CALCINATION TEMPERATURE OF ABOUT 700°F. ^ ROTARY KILN CALCINATION TESTS TO VERIFY THE RESULTS OF THE POT CALCINATION EXPERIMENTS ARE IN PROGRESS. 265 ' The Compaction of Baled Low Level Radioactive Waste Presented by: H. W. Arrowsmith, Scientific Ecology Group, Inc. 267^ THE COMPACTION OF BALED LOW LEVEL RADIOACTIVE WASTE H. W. ARROWSMITH THE SCIENTIFIC ECOLOGY GROUP INC The Scientific Ecology Group, demonstrated the feasibility of further volume reducing low level radioactive waste which was previously baled to reduce its initial volume. The waste supplied for the evaluation consisted of 30" x 42"x 60" bales which were composed of paper, plastic, cloth, metal, glass, drums, and other miscellaneous materials contaminated with uranium 238 and trace amounts of uranium 235. The baled waste was processed by shredding the bales to reduce the size of the waste to fit into crushable innerpack boxes, compaction using SEG'S 5000 ton Ultra-compactor, and overpacking into a 44 cubic foot burial module for transportation and burial. The resulting volume reduction factor was 3.3:1 over the volume of the baled waste and 33:1 over the initial loose waste at the generators site. The use of Ultra-compaction reduces the volume of waste that must be buried, improves the environmental performance of the waste after burial and extends the life of the burial site by burying less waste per year. If this program were fully utilized on one clients low level waste streams, it would require 42,000 cubic feet less burial ground space and would save an estimated $210,000 to $477,000 per year. 269 PROCEEDINGS PAPER NOT AVAILABLE AT TIME OF PRINTING Environmental Experience and Potential, Using TVA's Coal Gasification Facility Presented by: Phebus C. Williamson, Tennessee Valley Authority 273 ABSTRACT Environmental Experience and Potential Using TVA's Coal Gasification Facility by Phebus C. Williamson and Doye B. Cox During 1980 and 1985, TVA conducted a program in a 200-ton-per-day coal gasification facility to determine technical, economic, and environmental aspects of using coal to produce ammonia. This paper discusses the environmental findings of the study including the levels of materials of environmental concern in the gaseous, liquid, and solid discharges. Worker health and safety and fugitive emission in the workplace are discussed. The paper also presents a novel approach to destruction of hazardous and industrial wastes through the gasification process. In this concept, hazardous materials including polyaromatic compounds and chlorinated hydrocarbons are fed to the reactor, either with or independent of the normal coal feed, where decomposition takes place at elevated temperature in a reducing atmosphere. The design of the gasifier allows for feed of the material as an aqueous solution, and in some cases, as a sludge or a solid. 275 ENVIRONMENTAL EXPERIENCE AND POTENTIAL USING TVA'S GOAL GASIFICATION FACILITY by Phebus C. Williamson Waste Technology Development Center Waste Management Institute Tennessee Valley Authority Muscle Shoals, Alabama 35660 and Doye B. Cox Waste/Materials Training and Information Center Waste Management Institute Tennessee Valley Authority Chattanooga, Tennessee 37402 Mention of companies and trade names for processes, equipment, and commercial products does not constitute an endorsement by TVA or the U.S. Government. This article is a U.S. Government publication and not subject to copyright. For Presentation at Oak Ridge Model Conference Oak Ridge, Tennessee October 14-16, 1987 276 ENVIRONMENTAL EXPERIENCE AND POTENTIAL USING TVA'S COAL GASIFICATION FACILITY The Ammonia from Coal Project was initiated as a research and development project to determine the technical, economic, and environmental aspects of substituting coal for natural gas as feedstock to manufacture ammonia. The facility was first operated in October 1980. A 2-year period of plant modifications and trial operation followed that culminated with the successful production of ammonia in November 1982. As expected, several process and mechanical problems had to be solved before ammonia was produced. With successful production of ammonia, the emphasis of the project shifted away from the operating problems (although certainly some problems still existed) toward the collection of operating data from a variety of feedstock sources. A series of test runs was conducted to gasify the residues from the Exxon Donor Solvent (EDS) process for direct liquefaction of coal. This operation was followed by test runs using Utah, Illinois No. 6, Kentucky No. 9, and an Eastern U.S. high ash fusion coal. Operation with each feedstock produced a unique set of operating data and process related information. However, the stream components of environmental concern varied little with each run. This paper discusses the environmental findings of the study. Also, a novel approach to destruction of hazardous and industrial wastes is discussed using the gasification process. Plant Description The coal gasification and gas processing facility was designed to gasify about 200 tons (181 metric tons) of coal per day to produce about 10 million cubic feet (283,170 m3) of carbon monoxide (CO) and hydrogen (H2) sufficient to produce about 150 tons (136.07 metric tons) per day of ammonia. The plant design uses the Texaco coal gasification process and is based on use of Illinois No. 6 coal. Sufficient flexibility is designed into the plant for test operation using coals with different heat, ash, and sulfur contents, and with different grinding characteristics. Figure 1 shows a flow schematic of the process. Coal is pulverized in disc mills as required for the gasifier operation. Water is added to the disc mills to form a coal-water slurry containing about 60 percent or more solids. The slurry is pumped to a feed tank and then metered to the reactor at the process WATER COAL SCRUBBING COAL HANDLING WET GRINDING GAS IFI CAT I ON •H WATER & PREPARATION SEPARATOR OXYGEN LOCKHOPPER AIR AIR SEPARATI ON PLANT CLARIFIER SLAG WASTE WATER TREATMENT NITROGEN WATER CO SHIFT COS ACID GAS FINE SULFUR SYN GAS TO CONVERTER HYDROLYSIS REMOVAL REMOVAL AMMONIA PLANT WASTE C02 CO a TO VENT SULFUR PRODUCT CO2 RECOVERY SULFUR CO2 TO UREA PLANT FIGURE 1 AMMONIA FROM COAL PROJECT 278 rate of 8 tons of coal per hour. Gaseous oxygen from an air separation plant is fed to the reactor at about 8 tons per hour through a metering system interlocked with the coal slurry feed. The gasification process takes place in the reactor at a pressure of about 510 psig and at a temperature of around 2500°F. The carbon in the coal is reacted with steam to produce carbon monoxic* and hydrogen. Oxygen is injected to burn part of the coal to carbon dioxide to provide heat for this endothermic reaction. Sulfur compounds in the coal are gasified in the reducing atmosphere to produce primarily hydrogen sulfide (H2S) and some carbonyl sulfide (COS). Small quantities of other compounds such as ammonia and methane also are formed. Table I shows the composition of the raw gas from the gasification section. Slag produced from the ash in the coal is removed from the reactor through a lockhopper system. Trucks are used to transport the solids to a disposal area. The gas leaving the reactor is water-quenched and particulate matter (fly ash) is removed in a scrubber. A blowdown to control dissolved solids is taken from the water recirculating loop and pumped to a wastewater treatment facility, which uses both chemical and biological treatment processes. The process gas from the quench scrubber flows to 2 carbon monoxide shift converters. The CO content of the gas entering the converter is about 22 percent (wet basis). After shift, the CO content is about 2 percent (wet basis) which matches the CO content of the gas entering the low-temperature shift converter in the ammonia plant. The COS produced during the gasification process is not affected by the sulfur recovery system that is used to recover H2S from the off-gas streams of the acid gas removal (AGR) system. Therefore, the quantity of COS must be decreased to meet the sulfur emission limitations. To accomplish this, a COS hydrolysis unit is provided between the CO converter and the acid-gas removal (AGR) system to promote the reaction: COS + H20 -> C02 + H2S The process gas from the COS hydrolysis unit flows to the AGR system, which uses Norton Company's Selexol process (a physical absorbent system) to remove the CO2, H2S, and the remaining COS from the process gas. In actual operation, this system has decreased the total sulfur in the synthesis gas stream to less than 1 ppmv. Two reject acid gas streams are produced during regeneration of the Selexol solvent. One stream containing up to 4 percent H2S is sent to a 279 TABLE I RAW GAS FROM GASIFICATION SECTION 3 Flow rate, m /min (SCFM)* 527 (18,607) Temperature, °C (°F) 232 (450) Pressure, kPa (psig) 3,275 (475) Major components, vol % Hydrogen 17. 4 Carbon monoxide 22. 7 Carbon dioxide 9 Argon 0. 4 Nitrogen 0. 2 Water vapor 50. 0 Sulfur species, vol % Hydrogen sulfide 0. 4 Carbonyl sulfide 150 ppmv Hydrocarbons, vol % Methane <0.1 *tn3/min at 15.5°C and 1 atm. (SCFM at 60°F and 29.92 in Hg) 280 Stretford sulfur-recovery system. The Stretford system uses a proprietary solution containing an oxidized form of vanadium salts. The H2S is oxidized in the solution to produce elemental sulfur. The Stretford solution is regenerated by blowing air through it. This operation also floats the elemental sulfur to the surface. The sulfur is skimmed off and filtered to produce a wet granular cake. The tail gas from the Stretford system was to contain about 160 ppmv H2S and less than 30 ppmv COS. The second stream from the AGR solution regeneration system is relatively pure CO2. This gas is also sent to a Stretford unit and then to a sulfur guard containing zinc oxide to decrease the total sulfur content to less than 0.5 ppmv to meet requirements for urea manufacture. Nitrogen from the air separation plant is added to the process gas from the AGR system to produce a H£:N2 ratio of 3:1. The gas then flows through a zinc oxide sulfur guard to decrease the sulfur content to less than 0.1 ppmv. Deaerated boiler feedwater is added to produce a steam to dry gas ratio of 0.44:1. The gas is then heated to about 600°F before entering the existing ammonia plant at a point immediately upstream of the low-temperature CO shift converter. The pressure of the gas at the battery limits is about 380 psig. The composition of the gas at the battery limits is shown in Table II. Additional details of the gasification process and operating experience can be found in papers by J. R. Watson^D and P. C. Williamson<2). Environmental Results Environmental studies were conducted in the following three general areas: • Permitted streams. These included solid discharges, wastewater, and gaseous discharges. • Fugitive emissions. Leakages from the process to the workplace were determined and worker health and safety were monitored. • Trace contaminants. Slag, wastewater, and process gas streams were examined with regard to components of concern including metals, organics, and sulfur specie. 281 TABLE II PRODUCT GAS AT BATTERY LIMITS Flow rate, mJ/min (SCFM)* 324.8 (11,472) Temperature, °C (°F) 316 (600) Pressure, kPa (psig) 2,620 (380) Major components, vol % Hydrogen 43.3 Carbon monoxide 1.8 Carbon dioxide 9.1 Argon 0.4 Nitrogen 14.8 Water vapor 30.6 Sulfur species, ppmv Total sulfur <.l Hydrocarbons, vol % Methane <0.1 *m3/min at 15.5°C and 1 atm. (SCFM at 60°F and 29.92 in hg) 282 Permitted Streams Operating permits were issued by the State of Alabama that placed limits on particulate matter (coal dust) emitted from the coal handling operation and on total sulfur emitted from the sulfur recovery system. These emission points and the flare used during startup periods are the only permitted afmospheric emission points at the facility. Coal dust emissions were held to an average of about 4 pounds per hour, well below the 12 pounds per hour permitted limit, by use of a dust suppression spray system on each transfer point and a wet scrubber on the discharge from the primary coal crusher. Sulfur emissions were a problem throughout the operation. Typical composition of the vent gas is shown in Table III. Emission limits exceeded the TVA contract limit of 190 ppmv total reduced sulfur (H2S and COS) during all but a fraction of the operation. However, the State permit limit of 12 pounds of sulfur as S0£ per hour was met during the last runs in 1985 even though the concentration exceeded the TVA specified 190 ppm. During the last runs, the CO shift reactors were bypassed, thereby producing less CO2 and less total gas flow to the sulfur recovery system. Wastewater discharges did not meet permit limits during early operation. Actual and design compositions of streams to and from the unit are shown in Table IV. Most of the troubles with the wastewater treatment facility were due to design problems. The unit was designed for a maximum of 50 gallons per minute, but actual flows were nearly twice this value. Through process changes to decrease the water flow rate and through equipment changes in the wastewater treatment unit, effluent limits were met with the exception of ammonia and chemical oxygen demand (COD). Additional modifications would have brought these values within specifications. Solids discharge (slag) from the process were not under operating permits as such. Since only limited data were available when the project was begun, a decision was made to treat the slag as a hazardous waste until data could be evaluated to determine conclusively its characteristics. Tests were made using slag produced from several coals, Illinois Ho. 6, Utah, Pittsburgh No. 8, and a high-ash fusion Eastern U.S. coal. These tests showed that the slag met the Resource Conservation and Recovery Act (RCRA) tests as nonhazardous. As a result, the slag disposal basin which had been constructed with an impervious lining of compacted clay has been removed from the hazardous waste classification. 283 TABLE III GASEOUS EMISSIONS TO THE ATMOSPHERE Component Value Flow rate, m3/min (SCFM)* 124.6 (4,401) Temperature, °C (°F) 37.8 <100) Pressure, kPa (psig) 41.4 (6) Major components, vol % Hydrogen 1.0 Carbon monoxide < 0.1 Carbon dioxide 53.5 Nitrogen 41.0 Water vapor 4.5 Sulfur species, ppmv Total sulfur 190-900 ppmv Hydrocarbons, vol X Methane < 0.1 *m3/min at 15.5°C and 1 atm. (SCFM at 60°F and 29.92 in hg). TABLE IV TYPICAL WASTEWATER STREAM ANALYSES Stream Component To Unit From Unit Actual Desixn Avg Max Suspended solids, mg/l 389 26 30 45 Airanonia-N, mg/l 475 110 19 54 COD, mg/l 485 138 130 290 Sulfide, mg/l 31 0.1 - 5 Cyanide, mg/l 25 2.0 - 15 Oil and grease, mg/l 5 5 15 20 Formate, mg/l 568 5 - 150 BOD (5-day), mg/l 21 5 30 45 PH 6.9 8.1 6-9 - 284 Fugitive Emissions Fugitive emissions to the workplace were measured throughout the facility. Measurement techniques included sampling for the most logical components, CO and hydrogen, in the workplace. Also, plastic bags were placed over equipment, particularly valves and fittings, that are generally prone to leakage. Results of these studies indicated very low emissions occurred during norma1 operation. Most of the leaks that were found were present only during startup, mainly during a cold startup. Only 1 incident of worker exposure to high levels of CO occurred during the 5-year operation. This occurred when the worker was opening a valve that leaked excessively. The worker was treated with oxygen for about 30 minutes before returning to work. Worker Health and Safety Other than the above case, no other serious or long-term injury occurred during the operation. Extensive medical evaluation of the assigned workers before plant startup and at the conclusion of the test program uncovered no unusual problems. Trace contaminants Each of the gasifier output streams, slag, wastewater, and process gas were analyzed for trace components including metals and organics. Table V shows analysis of RCRA Extraction Procedure metals leached from the slag. All values are below the accepted drinking water standard, also shown in Table V. No organic priority pollutants or other organic peaks were found in the slag. Unconverted carbon was present in the slag in the range of 10 to 30 percent. Table VI lists selected components in the blowdown water from the gasifier to wastewater treatment. Although there was organic carbon in the wastewater sample, there were no organic compounds detected by the gas chromatograph-mass spectrometry system. This is indicative of the very low molecular weight substances such as formate which are not observable with the gas chromatography-mass spectrometry system. Table VII lists trace contaminants in the gasifier outlet gas stream. Except for the iron, the values were below the detection limits as determined by the DC argon plasma emission spectrometry. Organic compounds in the gasifier product gas stream are listed in Table VIII. Most of the compounds that were analyzed for were undetectable. Those that were found included benzene, ethylbenzene, toluene, acenaphthene, anthracene, naphthalene, and phenanthrene. As Table VIII shows, these concentrations are very low and are not environmentally significant. 285 TABLE V SLAG ANALYSIS - EPA RCRA EXTRACTION PROCEDURES Component Value.. (tiR/1 Standard, nvR/1 Ag < 0.01 0.05 As < 0.05 .05 Ba 0.43 1.0 Cd < 0.01 0.01 Cr < 0.05 0.05 Hg < 0.0002 0.002 Pb < 0.05 0.05 Se < 0.05 0.01 TABLE VI ANALYSIS OF UASTEWATER FROM GASIFIER Component Value, ppm 4. 3 NH3 159 Total N 161 Formate 595 Phenol <1. 0 As 0. 06 Cd 0. 02 Fe 10, 0 Hg 0. 06 Ni 0. 05 Pb 0. 14 V 0. 11 286 TABLE VII TRACE COMPONENTS IN GAS FROM GASIFIER Component Value, ppm Iron carbonyl < 0.02 Nickel carbonyl < 0.02 As < 0.002 Cd < 0.001 Fe 0.01 Hg < 0.001 Ni < 0.002 Pb < 0.001 V < 0.003 TABLE VIII ORGANIC COMPOUNDS IN GAS FROM GASIFIER Component Value, mg/m Benzene 210+35 Ethylbenzene 7±1 Toluene 23+1 Acenaphthene 4+1 Anthracene 4+1 2-4 - Dimethylphenol 5+1 Naphthalene 75+5 Phenanthrene 4+1 287 As has been shown, the entrained flow gasifier operating at elevated temperatures of around 2500°F produces very small quantities of materials of environmental concern. For this reason, it is believed the gasifier offers a promising method for destroying harmful organic materials. Gasification of Hazardous Wastes Thermal destruction of hazardous wastes in a coal gasification process appears to be an attractive addition to available waste destruction technologies. As discussed earlier, operation at a nominal 2500°F at the relatively long retention times inherent with the process effectively converts carbonaceous materials to single carbon molecules. Since the process operates under a reducing atmosphere, essentially all sulfur and nitrogen compounds are converted to hydrogen sulfide and ammonia which are then recovered. Contrary to the incineration process, no sulfur dioxide or nitrogen oxides reach the atmosphere to contribute to the acid rain problem. Also, the gasification process can accept without severe penalties significant quantities of aqueous solutions and low-flash-point liquids, as well as solids and slurries. In the case of the Texaco gasification process, wastewaters can be used to make up the coal-water slurry. With dry feed systems such as the Dow, Shell, and Krupp-Koppers, the aqueous wastes could be injected directly into the reactor. In any case, large quantities of wastewater, 20 to 50 nercent of the coal feed, could be disposed of in this manner. For liquid or solid hydrocarbons, the limiting factor will likely be the halogen content. Otherwise, 10 percent or more of the Btu feed to the gasifier could be from the waste materials which would be converted to useful hydrogen and carbon dioxide. Residues (ash) from the gasification are expected to be tied up in a vitrified material that will pass the US/EPA/RCRA extraction procedures. The process is also expected to be able to accept the residue from incineration processes and convert this material to a nonhazardous form suitable for landfill or other uses such as road base materials. An important consideration in destruction of hazardous materials is the need to "quench" the gas stream components once decomposition has occurred to prevent reformation of carbonaceous compounds. Figure 2 shows a comparison of the time versus temperature curves for the gasification and incineration processes. The figure shows the reaction zone between the high-temperature zone where rapid decomposition takes place and the low-temperature zone where reaction rates are slowed to the point where they can be ignored. The incineration process normally has a longer retention time at the reactive zone, which makes it more prone to reform compounds that may be of environmental concern. GASIFICATION DECOMPOSITiON INCINERATION REACTION CO CO QUENCH TIME Figure 2 REACTION TIME VERSUS TEMPERATURE, GASIFICATION and INCINERATION 289 This discussion is not to indicate that gasification will replace incinerators for hazardous waste destruction. In some cases, incineration is the only method of choice. For instance, the pressurized ?,asification process cannot accept bulky items such as drums and containers, whereas these are routinely fed to the incinerator. Also, it is not expected that gasifiers will be built solely for hazardous waste destruction. It is believed that the gasification concept is feasible. TVA is planning a study jointly with the University of Tennessee Space Institute, Tullahoma, Tennessee, to prove the technical and environmental feasibility of the process. TVA's coal gasification facility would then be used for environmental and economic studies and for process development and demonstration on a commercial scale. The study will have safeguards built in to ensure worker health and safety and to ensure that the environmental impacts are determined and understood. Once the feasibility is proven, it is expected that gasifiers built for other purposes, either power production or chemical production, will be used to gasify waste material as a "piggy back" feed for economic reasons and at the same time produce a useful product while helping solve the hazardous waste problem. 290 References 1. Watson, J. R., McClanahan, T. S., and Weatherington, R. W. "Ammonia Production from Coal by Utilization of Texaco Gasification Process," presented at the Sixth Miami International Conference on Alternative Energy Sources, Miami Beach, Florida, December 12-14, 1983. 2. Williamson, P. C, "A Review of Experience Gained on TVA's Ammonia from Coal Project," presented at the Fertilizer Institute Environmental Symposium 1984, Kissimmee, Florida, October 24-26, 1984. 3592p 291 r Replacement of Chlorinated Solvents at the Oak Ridge Y-12 Plant Presented by: L. M. Thompson, Y-12 293 Y/DV-662 Extended Abstract REPLACEMENT OF CHLORINATED SOLVENTS AT THE OAK RIDGE Y-12 PLANT L. M. Thompson R. F. Simandl Materials Engineering Department H. L. Richards Instrumentation and Characterization Department Development Division Date of Issue: September 30, 1987 Extended Abstract for submission to: Oak Ridge Model Conference Analysas Corporation Oak Ridge, Tennessee October 13-16, 1987 Prepared by the Oak Ridge Y-12 Plant Oak Ridge, Tennessee 37831 operated by MARTIN MARIETTA ENERGY SYSTEMS, INC. for the U.S. DEPARTMENT OF ENERGY under contract DE-ACO5-84OR21400 OPERATED BY MARTIN MARIEnA ENERGY SYSTEMS, INC. FOR THE UNITED STATES DEPARTMENT OF ENERGY 294 DISCLAIMER This repor' Mas prepared is an account of vwork sponsored by an agancy of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privatefy owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. COPYRIGHT NOTICE BY ACCEPTANCE OF THIS ARTICLE, THE PUBLISHER AND/OR RECIPIENT ACKNOWLEDGES THE U. S. GOVERNMENT'S RIGHT TO RETAIN A NONEXCLUSIVE ROYALTY-FREE LICENSE IN AND TO ANY COPYRIGHT COVERING THIS PAPER. REPLACEMENT OF CHLORINATED SOLVENTS AT THE OAK RIDGE Y-12 PLANT L. M. THOMPSON R. F. SIMANDL MATERIALS ENGINEERING DEPARTMENT H. L. RICHARDS INSTRUMENTATION AND CHARACTERIZATION DEPARTMENT DEVELOPMENT DIVISION OAK RIDGE MODEL CONFERENCE ANALYSAS CORPORATION OAK RIDGE, TENNESSEE OCTOBER 13-16, 1987 Oak Ridge Y-12 Plant Operated by MARTIN MARIETTA ENERGY SYSTEMS, INC. for the U.S. DEPARTMENT OF ENERGY under contract DE-AC05-840R21400 296 REPLACEMENT OF CHLORINATED SOLVENTS AT THE OAK RIDGE Y-12 PLANT L. M. Thompson R. F. S imandl Materials Engineering Department H. L. Richards Instrumentation and Characterization Department Development Division, Oak Ridge Y-12 Plant* Oak Ridge, Tennessee 37831 ABSTRACT Due to environmental and health concerns, both EPA and OSHA have announced their intent to further restrict the use of chlorinated sol- vents. In order to comply with these upcoming regulations, the Cak Ridge Y-12 Plant is conducting a survey or the use of these solvents and possible alternatives. The main use of these solvents has been found to be for cleaning purposes. This includes vapor degreasing as well as squirt bottle usage for removal of machining oils and coolants. One alternative which has been successful is the use of ultrasonic cleaning with aqueous detergents. Several studies have been conducted using X-ray Photoelectron Spectroscopy (XPS/ESCA) to evaluate the surface cleanliness and the effect of this cleaning technique on the surface chemistry. Studies have also been conducted to optimize various factors which influence this cleaning technique. Although this tech- nique has been useful in several areas, some problem areas still exist with replacing chlorinated solvents. These areas are currently being addressed and will continue to be addressed in the future. *Operated for the U.S. Department of Energy by Martin Marietta Energy Systems, Inc., under contract DE-ACO5-84OR21400. 297 REPLACEMENTS FOR CHLORINATED SOLVENTS AT THE Y-12 PLANT - L. M. Thompson, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee; R. F. Simandl, Martin Marietta Energy Systems, Inc., Oak Ridge, Tenn- essee; H. L. Richards, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee, 37831 As is widely known, the future for the use of chlorinated solvents appears bleak. Both EPA and OSHA have announced their intent to further restrict usage of chlorinated solvents using the National Emission Standard Hazardous Air Pollution Act (NESHAP). Rising concern over the erosion of the ozone layer may also bring about restrictions regarding the use of Freons. Due to these concerns, the Oak Ridge Y-12 Plant has conducted a survey on the use of chlorinated solvents. Only four chlo- rinated solvents were found to be used in the plant. These solvents were perchloroethylene (81,675 gal/yr), Freon 113 or Freon TP-35 (29,700 gal/yr) methyl chloroform (9,515 gal/yr), and methylene chloride (915 gal/yr). The major use of these solvents was found to be for cleaning operations. These included operations such as vapor degreasing of metal parts, cleaning machining coolant off of parts with squirt bottles, general cleaning by wiping off fingerprints, dust, etc., cleaning out meter-mix machines or spray guns for urethanes or rubber jel, and metal chip cleaning and packing operations. Some replacements for these chlorinated solvents have been or are currently being implemented. One such replacement is the use of a propylene glycol, water, and borax mixture as a machining coolant in place of perchloroethylene. This brought down our perchloroethylene use from 81,675 gal/yr to 9,625 gal/yr. Another replacement being implemented is the use of ultrasonic cleaners with aqueous solutions to clean metal parts instead of vapor degreasing. Ultrasonic cleaning consists of immersing a part in a liquid medium, agitating the liquid with high frequency sound, rinsing the part, and drying the part. This type of cleaning has been proven to be a viable option to replace chlorinated solvents. In some cleaning applications, ultrasonic cleaning has been proven to be better than chlorinated solvents. Figure 1 shows a comparison between vapor degreasing and ultrasonic cleaning. This study consisted of taking eight samples of U-6Nb. All samples were cleaned ultrasoni- cally for eight hours in a detergent, isopropanol, and demineralized water solution at 50 C, thoroughly rinsed in demineralized water, fingerprinted, and handled thoroughly. One sample was set aside as the control sample while the others were dipped in a rust-inhibiting oil and allowed to dry. Table 1 is a description of the treatments each of the samples received. The samples were analyzed using Electron Spectroscopy for Chemical Analysis (ESCA). This technique is capable of looking at several monolayers to partial monolayers. A ratio of the carbon peak to the uranium peak, which is referred to as a cleanliness ratio, was cal- ulated for each sample. Figure 1 is a comparison of these ratios for each of the treatments. As one can see, the ultrasonic cleaning techniques did much better than the isopropanol-vapor degreasing and did slightly better than the perchloroethylene degreasing. C(1s):U(4f) RATIO I 9.4 1.2-1 CO 0.4-1 CLEANING TREATMENT FIG. 1. CLEANING OF U-6Nb SAMPLES 299 Table 1. Description of cleaning treatments for U-6Nb samples. Treatment Description Initial All samples were cleaned ultrasonically for eight hours in 5 vol % detergent/20 vol % isopropanol/ 75 vol % demineralized water at 50 C. All samples were thoroughly rinsed in demineralized water. Control Fingerprinted and handled thoroughly Subsequent Treatment After receiving the above treatment, the remaining samples were dipped in a rust-inhibiting oil and dried. They then received the following cleaning treatments. Isop Degrease Degreased for 30 min. in isopropanol vapor Perc Degrease Degreased for 30 min. in perchloroethylene vapor. Detergent Flushed for 20 min. with 2 vol % detergent/ 98 vol % demineralized water at 40 C. Rinsed with demineralized water. US/Detergent Cleaned ultrasonically for 20 min. in 2 vol % detergent/98 vol % demineralized water at 40 C. Rinsed. US/Detergent/Isop Cleaned ultrasonically for 20 min. in 2 vol % detergent/20 vol % isopropanol/78 vol % demineral- ized water at 40°C. Rinsed. US/Detergent/Plasma Cleaned ultrasonically for 60 min. in 2 vol % detergent at 40 C. Rinsed in demineralized water, dried, and cleaned in argon plasma for 15 min. US/Detergent/Isop/8 Cleaned ultrasonically for 8 h in 5 vol % detergent/20 vol fc isoproganol/75 vol % demineralized water at 50 C. Rinsed. 300 Ultrasonic cleaning has also been shown to have enough power to replace labor-intensive cleaning techniques. Figure 2 is a comparison between ultrasonic cleaning and a labor-intensive operation. In this study, samples of 304L stainless steel were formed using a drawing fluid, cleaned, and analyzed. The first sample was treated with drawing fluid "A" which is very difficult to remove, cleaned in an ultrasonic cleaner in a detergent solution at 50 C for five minutes, and rinsed ultrasoni- cally in demineralized water. The second sample was treated with drawing fluid "B" which is somewhat easier to remove, cleaned in a labor-intensive fashion which included hand cleaning in methyl chloro- form, vapor degreasing in perchloroethylene, hand cleaning in acetic acid, and rinsing in demineralized water. The third sample was treated with drawing fluid "B", ultrasonically cleaned in a detergent solution for five minutes at 50 C, and rinsed ultrasonically in demineralized water. The samples were analyzed using ESCA and a carbon-to-chromium peak cleanliness ratio calculated. Figure 2 is a comparison of these peak ratios. The ultrasonic cleaning technique on drawing fluid "B" was the most consistent and effective cleaning method. For the cleaning applications at Y-12, detergent cleaning alone would not suffice. The power of ultrasonics is also needed. Figure 3 shows a comparison between ultrasonic cleaning in detergent and detergent cleaning alone. In this study, five type 304L stainless steel cylinders were machined in a machining fluid and degreased in perchloroethylene. The first sample was used as a control sample. The second sample was cleaned by immersion in a stirred bath of detergent "A" for 20 min. at 55 C, rinsed under flowing water, and sprayed with acetone to aid drying The third sample was cleaned in ultrasonic cleaner "1" using detergent "A" at 74 C for four minutes, rinsed in flowing demineralized water, and sprayed with acetone to aid drying. The fourth sample was cleaned in ultrasonic cleaner "2" using detergent "A" at 68 C for four minutes, rinsed ultrasonically in demineralized water, and sprayed with alcohol to aid drying. The fifth sample was degreassd an additional 20 min. in perchloroethylene. These samples were analyzed using ESCA and a carbon- to-chromium peak ratio was calculated. Figure 3 is a comparison of these peak ratios for each cleaning technique. The ultrasonic cleaning technique again was more consistent and effective than detergent cleaning alone and degreasing. There are several factors which can influence the effectiveness of ultrasonic cleaning. These include the frequency obtained by the ultrasonic transducers, the liquid medium used in the ultrasonic system, and the coupling of the equipment with the cleaning medium. The optimum frequency level is dependent upon the cleaning applica- tion. If one is cleaning small electronic components which can be damaged easily, a higher frequency (-40 kHz) is required. If a good, aggressive cleaning action is required, a lower frequency (-20 kHz) is required. The lowar the frequency, the greater the intensity of the radiating wave, thus the greater the cavitation intensity. However, the frequency must be at least 18 kHz in order to get any C(te):Cr(2p) RATIO 15 10- CO o 5- - 5.23 + 1.69 4.08 + 2.62 J. 1.55 + 0.57 0- .—, 1 •• 1 FLUID A/US FLUID B/CS FUJID B/US CLEANING TREATMENT FTG.Z REMOVAL OF DRAWING RJJID FROM TYPE 304L STAINLESS STCEL C(1s):Cr(2p) RATIO 25-i 25.1140.5 20- 15- 11.7 to o 10- IS3 5- I 1.55 + .38 i 1-77 + .3S CLEANING TREATMENT RG. 3. CLEANING OF 304L STAINLESS STEEL CYUNDERS 303 cavitation of the liquid.1 One drawback with the lower frequencies is that the noise level increases as the frequency decreases. Therefore, with the lower frequency required for aggressive cleaning action, the noise level is irritating, necessitating ear protection for any operator near the ultrasonic unit. The optimum liquid medium for use is also dependent upon the cleaning application. A liquid must be chosen which will clean the type of contamination present: organic, inorganic, or particulate. The liquid must also have good viscoelastic properties so that proper cavitation can be achieved. Water has been shown to have excellent cavitation properties.2 One must also be aware that cavitation is affected by temperature of the liquid. Due to the cavitation properties of water and the ability of detergents to clean several different types of contamination, aqueous systems are an excellent choice for use in ultrasonic cleaning. Several factors must be considered in choosing a detergent-based aqueous system. These include the type of emulsifier, type of wetting agent, type of corrosion inhibitors, and the cloud point of the detergent. The emulsif ier must be able to disperse the dirt so that cleaning can take place. The wet- ting agent must reduce surface tension so that the surface can be wetted properly and the detergent will undercut the dirt. Corrosion inhibitors must be present in cleaning metals in particular to prevent corrosion. A detergent must also be chosen which will not cloud at the temperature which is required for cleaning. Clouding indicates that the detergent is no longer capable of cleaning as required. Figure 4 shows an example of the type of impact the detergent has on cleaning ability. In this study, samples of type 304L stainless steel were contaminated with a low viscosity drawing lubricant. Several samples were then flushed with or soaked in detergent "A" at 50 C. Some samples received the same treatment with detergent "B" while some were vapor degreased in perchloroethylene. The samples were analyzed using ESCA, and carbon-to- chromium peak ratios were calculated. Figure 4 is a comparison of these peak ratios for each cleaning technique. As one can see the detergent does have an obvious effect on the cleaning ability.1 One other factor which can effect the cleaning ability of ultrasonic equipment is the coupling between the equipmtnt and the liquid medium. Sometimes the equipment can have the right frequency but will not couple with the liquid, thus giving poor cleaning action. This coupling can vary greatly between equipment brands. One test which is useful in comparing brands of ultrasonic equipment is the aluminum foil erosion test.1 This test consists of placing a piece of aluminum foil in the ultrasonic cleaner. If the cleaner is capable of a good, aggressive cleaning action, holes will actually be chewed out of the foil. Although ultrasonic cleaning has been proven as a good cleaning technique, there are some disadvantages. Unlike solvent cleaning operations where the solvent evaporates, the ultrasonic cleaning pro- cess requires a rinse step. This step requires adv tional equipment :(te):Cr(2p) RATIO B- 6- 4- • 5.24 + 3.54 T + 3.00 + 0.32 2- 1.03 + 0.68 0- l i l DETERGENT A DETERGENT B PERK CLEANING TREATMENT RG.4. REMOVAL OF DRAWING FLUID FROM TYPE 304L STAINLESS STEEL 305 and time. The equipment and set up for ultrasonic equipment can be very expensive, which is another consideration. However, due to future restrictions, chlorinated solvents may become too impractical and expensive to use, so even with its disadvantages, ultrasonic cleaning is a viable option. 306 References: 1. Maurice O'Donoghue, "The Ultrasonic Cleaning Process," Micro- contamination . October/November 1984, pp. 63-67. 2. B. Niemezewski, "A Comparison of Ultrasonic Cavitation Intensity in Liquids," Ultrasonics. May 1980, pp. 107-110. 3071; Charging Generators for Waste Management Costs Presented by: J. B. Berry, ORNL 309 CHARGING GENERATORS FOR WASTE MANAGEMENT COSTS J. B. BERRY F. J. HOMAN Oak Ridge National Laboratory P. 0. Box X Oak Ridge, Tennessee 37831 By acceptance of this article, the publisher or recipient acknowledges the U.S. Government's right to retain a nonexclusive, royalty-free license in and to any copyright covering the article. 310 CHARGING GENERATORS FOR WASTE MANAGEMENT COSTS* J. B. Berry F. J. Homan Oak Ridge National Laboratory P. 0. Box X Oak Ridge, Tennessee 37831 Introduction The Department of Energy (DOE) has recognized the need for waste management which incorporates improved waste handling techniques and more stringent regulatory requirements to prevent future liabilities such as Superfund sites. DOE-Oak Ridge Operations (DOE-ORO) has recognized that an effective waste management program focuses on control at the source and that the burden for responsible waste management can be placed on generators by charging for waste management costs. The principle of including the waste management costs in the total cost of the product, even when the product is research and development, is being implemented at Oak Ridge National Laboratory (ORNL). Optimizing processes to reduce waste generation and improve waste management can be expected to occur in three phases: (1) Initial phase: Easy fixes. Waste management practices are changed in areas where the cost is low and gains are large; (2) Development phase: Process changes. Frequently, capital funds are required. Analysis of costs and benefits occur during this phase; and (3) Mature phase: Waste reduction approaches technological, political, or cost-effective limits.1 Charging waste management costs to generators creates an incentive to optimize processes so that less waste is produced and provides a basis for determining the cost effectiveness of ^Research sponsored by the Office of Defense Waste and Transportation Management, U.S. Department of Energy, under contract DE-AC05-840R21400 with Martin Marietta Energy Systems, Inc. 311 capital improvements so Chat the "mature phase" of waste management can be attained. Improving waste management practices requires a long-range commitment and consistent administration. Making this commitment and providing adequate funding for proper waste disposal are more cost-effective measures than the alternative of paying for remedial actions after improper disposal. This paper summarizes (1) a plan to charge waste generators, (2) the administrative structure of the plan, (3) a comparison between the rate structure and changes in waste disposal operations, and (4) issues that have surfaced as the plan is implemented. Plan to Charge Generators for Waste Management A logic network outlining planning and implementation of charging waste management costs to ORNL waste generators is shown in Fig. 1. In April 1986 an initial set of assumptions, programmatic costs and the implementation plan were approved by ORNL and DOE-ORO management. Gradually increasing costs to allow generators to include waste management costs in the budget cycle for research projects was an important aspect of the plan. The goal of recovering all waste management operational costs from generators by FY 1989 was pursued. OKMl OWQ •>•]•* PLANNING AND IMPLEMENTATION OF A PROGRAM TO CHARGE GENERATORS FOR WASTE MANAGEMENT Fig. 1 Logic network for charging generators for waste management costs 312 The rate structure was based on actual waste management operational costs with a surcharge levied on high-activity or high-toxicity wastes. Capital project costs were not included in the rate calculations. The plan assumed that capital projects would continue to be sponsored by current funding sources and that Defense Program and Surplus Facilities Management Program would continue to pay for maintenance/surveillance of inactive diposal units, processing/packaging of stored TRU waste, and management of legacy wastes. A difficult decision was to charge only for current yeai costs, including interim storage, in the year the waste is generated. New disposal facilities are being constrvicted at ORNL; charges for disposal of waste were postponed until the facilities are available. This decision defers development of a method to collect the cost of disposal of stored waste to future management. Rate Schedule Charges for hazardous waste, liquid low-level radioactive waste (LLLW), process waste, solid low-level radioactive waste (SLLW), contact-handled transuranic waste and remote-handled transuranic waste before and after a comprehensive plan to charge waste generators was implemented are shown in Table 1. The amount of waste generated during 1986 for each category is shown.^ An increase in the rate can be attributed to the cost of improving waste handling techniques, improving disposal practices, and incorporating more stringent regulatory requirements including increased operating costs fcr tracking, safety, quality assurance (QA) documentation, audits, and reviews. The primary impact on cost for each waste category is summarized in Table 1. Administration of the Plan Improving waste management practices requires consistent administration. A waste-tracking system is needed to improve waste management practices and to determine charges to waste generators. Tracking of waste streams includes (1) waste stream identification, (2) waste stream characterization, (3) waste disposition, (4) documentation, and (5) audit/oversight. Waste generators are responsible for waste stream identification, characterization, segregation and proper disposition. Waste Management Operations and the Environmental Monitoring and Compliance Department at ORNL work together to develop and implement administrative requirements to ensure that generators use responsible waste handling practices. New waste 313 Taole 1. Comparison of rates before and after implementation of plan to recover waste management costs Waste catego-y Amount Rate before plan Rate after plan Reason for charge Haiaraous 353,000 Ib/y Flat rate p*r pound Variable rate depending on level Increased requirements ROM laiaraoui 106,000 Ib/y depending on nuwer of of hazard and on-site or off- for waste characterija- pounds collected ptr site disposal. Range i0.35-*10/ib tion and segregation. month. Liquid low-level 10,750 gal/w* No charge. S4/gal. Expected to increase to More accurate estimates raa:oact Process waste 5 x 10 gal/mo Mo charge. M.063/jal starting in 1988. More accurate estimates (siightly Expected to increase to for liquid waste radioactive) M.085/gsl by 1989. soldif(cation costs. Process waste 8 x 10 gal/ma No charge. S0.003*O.01°/gel starting in More accurate estimates (metai *m o-gmic 1988. Rate depends on for treatment costi. contaminants) contaminant. 3 3 Waste-specific equation. Increased inspection. Solid low-level 96,000 ft /y *<0.40/ft S/ft • base • pathway * irv.i-aasM use of reaionctive Adjustment for high storage/dispotal • adjustment13 engineered barriers. wait* activity waste. lase.t1J.75/ft Range VU/ft for storage to *413/ft for hign activity disposal Contact-handled 1,593 ft /y No charge. Cost depends on packaging and . Charge for transuranic treatment. SS-gal drum lUO/ft" storage and certification wast* *x4x6ft box *31/ft records me/jgmaent. box witfi 5:1 volume reduction *17/ft Remote-handled 816 ft /y No charge. Cort depends on packaging. Charge for packaging, transuranic treatment and disposition. segregation, treatment. wast* Repackaged 55-gal drum 11275/ft NOA/NOE and certifi- drum with 5:1 volume reduction cation records tt60/ft . Stored wast* »35/ft . management. Pathway includes actual cost for handling, certification, treatment and overpacking; storage/disposal cost charged depending on disposition; adjustments Include special credits or cojts which are waste-form specific. i> NOA/NOE • Nondestructive assay/nondestructive examination. 314 streams are identified through a formal activity or project description which is reviewed for potential environmental impact and proper waste disposition. Waste management plans are required in advance of project construction/initiation. The Environmental Protection Manual outlines procedures for handling and disposing of materials to maintain compliance with regulations. The Health Physics Manual outlines procedures for handling and disposing of radioactive materials. Employees receive training on waste minimization, Resource Conservation and Recovery Act (RCRA) regulations, and waste acceptance critieria including segregation of RCRA waste and SLLW. In addition to administrative requirements, a tracking structure has been established. A waste generator certification official has been assigned to each waste generation area. This official insures that waste streams are properly disposed, and participates in deciding on waste management issues such as waste minimization. Waste acceptance criteria for SLLW, transuranic waste and hazardous waste are enforced through the use of waste disposal forms which insure that the wastes are disposed of properly. Forms are completed by the waste generator certification official and sent to Waste Management Operations. Information is entered into a data base, a determination is made regarding proper disposal, the waste is inspected and transferred to storage for future disposal or shipment off site, or it is disposed of on site. A key component of the solid waste handling strategy is to return containers that fail inspection; the generator is required to pay for handling and inspection and to repackage the waste. Waste disposal forms are used to calculate the monthly charge for hazardous waste and SLLW. Liquid waste generation is tracked. Waste acceptance criteria for treatment of process waste are being established. Flow monitors record the volume of process waste generated by a group of facilities. On-line monitors will be used to route process waste to appropriate treatment (i.e., removal of radioactivity, removal of residual metals, removal of organic contaminants). The liquid level in each LLLW tank is monitored continuously at the Waste Operations Control Center. A weekly report on the volirne of LLLW and process waste generated by each facility is sent to the manager of each facility and is used to calcuate the monthly bill for liquid waste generation. Issue Identification/Resolution As the practice of charging the waste generators for waste management has been implemented, several issues have been encountered. An oversight and review committee was established to resolve controversial issues. The committee represents a 315 cross-section of ORNL programs; delegates are from waste management, major waste generators, and finance management. Several issues are currently under consideration. An attempt was made to administer costs to reward waste minimization, (i.e., unit costs would not increase due to reduction in volume). However, an equitable algorithm has not bsen approved. Proposals for decoupling waste volume and cost to generators include (1) using a fixed cost plus variable cost per unit of waste to calculate charging rate; and/or (2) basing charge on species of concern (i.e., radioactivity level, solids content). Issues involving the definition of appropriate costs to include in the rate are under consideration. "Nonproductive" costs associated with waste management including safety, training, QA documentation updates, audits, capital project planning, monitoring, analytical support, and reporting are currently not included in the rate caculation; however, these activities represent a significant portion of the waste management budget. Decisions made by the oversight committee to date suggest a trend toward not billing generators for costs such as capital project planning, QA program development, safety documentation upgrades, alternatives assessments, and development of documentation required to comply with DOE Orders covering waste management (such as DOE Order 5820.2). Acceptable charges include costs associated with tracking of waste for regulatory compliance and billing purposes. Appropriate financial management of the funds will be determined by the oversight and review committee. Questions which have not been answered include: (1) Can funds collected in one year be used to pay future costs? (2) Can funds collected to pay for one waste category be used to fund activities associated with another waste category? Another issue involves defining wastes that are part of current operations vs wastes that are produced due to legacies from the past (i.e., division of generator responsibility vs ORNL responsibility). For example, the collection and treatment of groundwater and surface water due to deteriorating equipment could be charged to the user of the equipment (generator) or to waste management programs (ORNL). A consensus regarding this controversial issue is being finalized. Facility operators will be charged for groundwater and surface water that is collected in active waste systems. The Remedial Action Program or the Surplus Facilities Program will be charged for treatment of contaminated groundwater and water that is collected due to the poor integrity of existing systems that have been abandoned. The cost of waste treatment will be included as a parameter in determining priorities for remedial actions. Priority for closure of waste 316 management units will be established through the I-iCRA Facilities Assessment and the RCRA Facility Investigation and Corrective Measures Study. Summary Implementation of a plan to charge waste management costs tc the facility that generates such waste requires a long-term commitment and consistent administration. The benefit is that generators are provided the incentive to optimize waste management practices if the charges are appropriately applied. REFERENCE 1. Reducing Hazardous Waste Generation: An Evaluation And A Call For Action. Committee on Institutional Considerations in Reducing the Generation of Hazardous Industrial Wastes, Environmental Studies Board, Commission on Physical Sciences, Mathematics, and Resources, National Research Council, National Academy Press, Washington, D.C., 1985. 2. Kendrick, C. M., Hazardous Waste Minimization Report for Calendar Year 1986. ORNL/TM-10516. in press. ^ Waste Management Facility Acceptance - Some Findings Presented by: Dr. Brent Sigmon, Science Applications International Corporation 319 ?^ WASTE MANAGEMENT FACILITY ACCEPTANCE - SOME FINDINGS Acceptance of waste management facilities remains a significant problem, despite years of efforts to reassure potential host communities. The tangible economic benefits from jobs, taxes, and expenditures are generally small, while the intangible risks of environmental or other impacts are difficult to evaluate and understand. No magic formula for winning local acceptance has yet been found. Limited case study and survey work does suggest some pitfalls to be avoided and some directions to be pursued. Among the most significant is the importance that communities place on controlling their own destiny. Finding a meaningful role for communities in the planning and operation of waste management facilities is a challenge that would-be developers should approach with the same creativity that characterizes their technical efforts. [ 321 PROCEEDINGS PAPER NOT AVAILABLE AT TIME OF PRINTING 323'Oc^ n> Permitting and the Public Presented by: JoAnn Garrett, International Technology Corporation 325 PERMITTING AND THE PUBLIC Community Relations and Permitting have both been around a long time. They have existed primarily as separate programs coming together only at the time of official public hearings or when public opposition surfaced in relation to a particular permitting effort. IT has linked Community Relations and Permitting in a program designed to overcome or minimize public opposition to the siting of hazardous waste treatment facilities. IT's Technology Projects group has been created to commercialize new and innovative hazardous waste treatment technologies both for fixed facilities and for Superfund remediation projects. The Permitting and Community Relations efforts are begun at the time of site selection and proceed as an integrated program through construction and operation. The Community Relations Manager and the Permitting Manager work as a team with regulatory authorities and the community, reshaping and recasting the communicy awareness program to communicate the project goals and corporate commitment to the community. The permitting program is altered in response to comments received from the community and regulatory officials. The end product is a permitted operating facility with public acceptance and the operating flexibility. 327 PERMITTING AND THE PUBLIC - JoAnn Garrett, IT Corporation, Knoxviile, TN; Robert D. Stephens, IT Corporation, Knoxville, TN. If you were asked, which environmental permit is most difficult to ob- tain, which one would you name? The one I would select is probably the one most neglected and certainly the most sensitive of all the permit- ting processes. This permit is not issued by any regulatory agency. So elusive is this permit, you are never sure you have one until your facility is built and operative ~ even then it can be revoked. This most difficult of all permits to obtain is the public permit ~ the one issued by John Q and Mary Jane Public — the same people who are your neighbors, the people who will live next door to your facility or down- wind in the next county. The average citizen does not understand haz- ardous wastes, but does react emotionally to the images evoked by the words "hazardous" and "toxic". The fact that you have spent millions of dollars designing and permitting your facility and that it is the best technology available on the market today c-es not impress him. What the average citizen is concerned about is his health, his general welfare, his family and the environment in his back yard. The fears and uncertainty that moved Rachel Carson 25 years ago are ex- pressed today by the schizophrenic attitude that acknowledges in one breath that hazardous wastes are a societal time-bomb only to utter in the next breath, "not in my back yard". During those same 25 years, scientists and engineers have conjured up technological miracles to burn garbage and recycle wastes. Regulations to guarantee that these technological miracles work safely have been written. But unless we seek better more effective and imaginative methods to educate, inform and involve the public in siting desperately needed hazardous waste facilities, the scientific and regulatory triumphs of the past 25 years will be for naught and we will still be generating wastes. Towards this end, IT has linked in-house community relations and per- mitting activities in an integrated program which is initiated at site selection and proceeds through permitting to construction and oper- at i on. Our overall goal is to strengthen and broaden the general community good will toward a project so that the technical review can proceed in a positive atmosphere. The community relations manager and the permit- ting manager work as a team with regulatory authorities and the commu- nity, re-shaping and re-casting the community awareness program to com- municate the project goals and corporate commitment to the community. The permitting program is altered in response to comments received from 328 the community and regulating officials. The end product is a permitted operating facility with public acceptance and operating flexibility. To reach our overall goal we established a series of sub goals or ob- jectives. • Expand base of support through outreach to organized business, civic and community groups. • Provide opportunities for information dissemination. • Maintain position as authoritative source on the project. • Identify and respond to specific concerns about the project before they coalesce into opposition. • Link community relations with permitting schedule. Keeping in mind our goal and objectives, the next link in our program is a set of assumptions about the host community based on an in-depth profile. Every community has a unique character, and a little time spent early analyzing that character — discovering what makes it tick what turns it off — will pay big dividends during permitting and oper- ating phases of any hazardous waste facility. In Oak Ridge, TN, IT Corporation has linked an in-house community rela- tions program with permitting efforts for its Environmental Technology Development Center (ETDC). The ETDC is IT's national center for demon- strating transportable technologies for treating hazardous wastes. A permitting manager's delight (or nightmare) the Center will require six local, state, and federal permits and when operational will house ther- mal and non-thermal treatment technologies. IT took the time to develop a profile uniquely describing Oak Ridge. Based on assumptions flowing out of that profile we developed a commu- nity relations strategy tailored to fit Oak Ridge. The profile showed a community of well educated and technically trained people with a history of active interest and involvement in environ- mental issues. A sensitivity that had been recently heightened by the Department of Energy disclosure that thousands of tons of mercury had been spilled into streams flowing through the city. Recent efforts by DOE to site a temporary storage facility for high level nuclear wastes inside the city limits exacerbated the feeling of being "dumped on". With this understanding of the community, IT opted for openness — to tell the facts, answer questions, explain the permitting process, any- where, anytime with any group -- our goal being a public so well in- 329 formed and supportive that when official hearings were held no one would show up to protest. With that goal in mind and working backwards from key milestones, community relations activities were strategically arrayed or clustered along the permitting schedule time line. Given the penchant of Oak Ridgers for community involvement, it would have been logical for IT to form a citizen's advisory group to review its overall permitting process. Fortunately such a group was already in place. The Environmental Quality Advisory Board was established several years ago by the City Council in recognition of the relative complexity of environmental issues and the importance assigned to them by the citizenry. Although tedious and time consuming, answering EQAB's questions as they reviewed our permit applications was a valu- able exercise in that it prepared us for our larger public. In addition to our interaction with EQAB, IT designed a package of com- munity relations activities which included discussing the project one- on-one with key community leaders; speaking to civic organizations; hosting forums and small coffees; buying ads in local newspapers; pub- lishing fact sheets and newsletters. All tactics were selected with the overall strategy in mind. In short we defined our overall goal and associated objectives; devel- oped assumptions based on an in depth profile of the community, then devised and executed a strategy that flowed from those assumptions. I have just mentioned some of the activities that were part of the com- munity relations/permitting strategy at our project here in Oak Ridge. Although selected and tailored to fit our overall strategy for the community the following activities may be adapted or altered to fit any host community. • Develop a clear and consistent message as to what the facility or project is — write it down in clear understandable language free of technical acronyms and jargon. If your secretary can not understand what you are doing, chances are, the general public will not either. Be consistent — siting of hazard- ous waste treatment operations are subjected to in- tense scrutiny — people are listening, especially potential opposition. In your narrative you should: - Describe the facility, how will it look? - What will it cost and where will the money be spent? - What activities will be conducted there? 330 - What are the estimated economic benefits? - What environment impacts are expected? • Prepare a road show with ample audio-visual support. Incorporating your clear and consistent message, further develop and hone a road show for use in un- official community meetings and new releases. Train and rehearse a team to make presentations to groups of all sizes in varying settings. Site tours and briefings for the general public and the media should also be included as part of an active commu- nity speaking program. Press kits should be prepar- ed for official hearings. • Emphasize the local nature of the project through the creation of a unique letterhead and logo. • Identify supporters who can feed back community con- cerns to the project manager. • Maintain a "courtesy call" schedule whereby the project manager checks in periodically with key officials and community leaders one-on-one. • Prepare and issue fact sheets describing the project and its notable features using graphics and a con- cise format. • Establish a newsletter for key local and state lead- ers. Issued periodically, a newsletter will ensure that your story is communicated directly to critical audiences. • Develop a mailing list of elected officials, commu- nity leaders and affected citizens so that fact sheets, news releases, and newsletters can be issued quickly and effectively. • Subscribe to local newspapers and read them. • Place a corporate ad once each month in the local paper. • Join the local Chamber of Commerce. Supportive and invariably eager to supply economic data, mailing lists, and access to the state and local industrial development entities, membership in the local Cham- ber of Commerce is a worthwhile investment. 331 • Establish an information repository in a convenient location. Usually placed in the care of the local library, the repository can include permit applica- tions, fact sheets, newsletters, newspaper clip- pings, as well as other documents pertinent to the project. « Promote the formation of a citizen interface group. A citizen's interface group may not be needed if a group such as Oak Ridge's Environment Quality Ad- visory Board is in place or if opposition is mini- mal. An interface group should be selected by the elected governing body of the city, town or county where the facility is to be located. Answers to questions raised by concerned and affected citizens will be more credible if they are researched and presented by such a group. All of the above activities are not implemented at every IT site nor do I suggest that the list is all inclusive. But combinations appropriate to the specific host community are in place at IT incineration sites around the country. In some areas, IT provides emergency response training for local public safety personnel, coordinates household hazardous waste clean-up and education events, and conduct public education meetings and workshops as well as public opinion research. IT has a corporate commitment to providing relevant information about its facilities to the public and welcomes citizen advice in developing plans to improve operation. Obtaining the usual required environmental permits to operate a hazard- ous waste facility often seems interminable and confusing, and at times, difficult, but at least in the regulatory process, one has written rules and guidelines. And one can ask for interpretations. The rules and guidelines for the public permit on the other hand are unwritten, ill-defined and subject to change. Furthermore, the pursuit continues throughout the development phase as well as the operational phase of your project. Even though we feel, as I am sure you do, that the hazardous waste industry serves a vital public purpose and need, it is in our best interest to educate, inform and persuade the public if we are to ob- tain, and retain, that most elusive of permits - the public permit. D90X JG 333^34 Integrating Waste Management into the Curriculum Presented by: Dr. Cuyler A. Dunbar, Roane State Community College ABSTRACT INC0RPCRATI1G WASTE MANAGEMENT H*CGRAMS INTO THE CURRICULUM AT RQSNE STATE GOMMJNITY COLLEGE In response to requests of area firms involved in Waste Management/Waste Cleanup processes, Roane State Community College has developed and submitted for State Board of Regents approval pertinent associate degree program options. Assuming approval by this body, the proposals will then be submitted to the Tennessee Higher Education Commission for consideration at their October meeting. The proposals include an associate degree program in Environmental Health Technology and a program option in Land Reclamation under the current Mining Technology program. The Environmental Health Technology program contains three options: the existing Health Physics option and new options - Industrial Hygiene and Waste Management. Eall 1988 is the targeted start-up date. Problems inherent in the start-up efforts include lag time in state funding procedures, lack of appropriate library resources and laboratory equipment, and the need for qualified faculty. Roane State is also developing non-credit training programs which meet the OSHA training requirements for workers engaged in hazardous waste activities. 337 INTEGRATING WASTE MANAGEMENT INTO THE CURRICULUM - Dr. Louise R. Greene, Roane State Community College, Harriman, IN; Dr. Cuyler A. Dunbar, Roane State Community College, Harriman, TO Throughout the sixteen year history of Roane State Community College, its programmatic developnent has been in direct response to expressed community needs. Scores of persons from our fifteen county servio, area have assisted us in identifying needed programs, in moving these programs through the approval process, in developing curricula, and in placing graduates of our programs. There are those on our staff whose specific responsibility it is to constantly monitor our communities to identify changes and developing trends. It was the arrival of firms such as International Technology and Scientific Ecology Group and the expansion of Bechtel's presence in the area which captured our attention and made us aware of the nature of some of the problems these and many other firms are working to resolve. With this awareness came an acute sense of responsibility for using college resources to contribute to resolution of some of these problems. Our next step then was to contact the Department of Energy to express a willingness to commit to any needed programs. Finding enthusiasm and encouragement there, we began to talk with representatives of Martin Marietta Energy fastens, International 338 Technology, Bechtel, Scientific Ecology Group, AIDEL Consulting Services and others regarding specific needs. It is gratifying to us that some of these people contacted us first to discuss the possibility of developing programs. We believed that the initiative of these people affirmed the worth of our past performance. Many one-on-one conversations occurred; small group discussions were held; and Roane State personnel progressed in their understanding of the need and its scope. Following the February Oak Ridge Model Conference, a survey instrument was prepared and sent to 150 participants in the conference. The participants selected were those whose company is located in Tennessee or in adjacent states. A return of about 30 percent of the surveys mailed was realized and through these responses need for programs in industrial hygiene, waste management and contaminated land reclamation was established. We then hosted a meeting at the Pellissippi Campus for representatives of the Department of Energy; Martin Marietta Energy Systems; Bechtel National, Incorporated; International Technology, and Scientific Ecology Group. At this meeting we presented our plans for developing these programs and requested input from those present for curriculum content, for expressions of interest in employing graduates and for potential internship opportunities. These letters of interest, support and intent were received within a couple of weeks or so. It is these letters which you provided that were possibly the most influential factor in moving the program proposals through the 339 approval process, and in developing the curriculum content. Before we began the actual writing of the proposals - a fairly lengthy process, we went to Findlay College in Findlay, Ohio to meet with Dr. Luke Bartolomeo who developed a baccalaureate degree program for Findlay. This program is now in its second year. Dr. Bartolaneo has requested that Roane State and Findlay develop an articulation agreement so that our graduates could transfer easily to Findlay to complete the baccalaureate degree. While our programs are not designed as transfer programs, we have included all of the math ana tics chemistry and physics required in the higher degree so that the transfer into a four year program could be easily effected should our students choose to do so. We also contacted Muskingum Technical College in Zanesville, Ohio. This two year college offers the associate degree in Hazardous Materials Management. The curriculum of each Findlay and Muskingum was considered carefully as the Roane State curricula were developed. Particularly helpful in curriculum building was the information and support provided by Doctors Ton Row, Frank Homan (who I understand has since left) and Lance Mezga of Martin Marietta Energy Systems. With the input of many of you we decided that given the parameters of program development guidelines within which we must operate, that an umbrella of program options would be appropriate. 340 We chose as the name for the new associate degree program - Environmental Health Technology. Options within this degree program will be our currently operating Health Physics Technology program and the two new options Industrial Hygiene and Waste Management. In addition, we developed an option Cbntaminated Land Reclamation which w.J.1 be offered under our Mining Technology program. There are three sections in the curriculum of each option. All options must have a common general education core which includes english composition, college algebra, trigonometry, speech, computer literacy, and social science and humanities electives. There is also a core of major courses common to all options. These include: Statistics, Chemistry, Biology, Physics, Safety and Emergency Response, and Federal and State Laws and Regulations. Then each option contains 21 semester hours of courses unique to that option. In Health Physics these include such topics as basic concepts of atonic and nuclear structure, radio-active decoy and ionizing radiation; internal and external dosimetry, shielding, radiation detection, instrumentation and measurement, radiation analysis, and radioactive waste management. The industrial hygiene option includes occupational safety and protection, environmental analysis, and topics such as threshold 341 limits, cbse-response, sampling methods and statistics, calibrations and equipment use, and methods of control of occupational health hazards. The Waste Management option includes a study of the definition and characterization of various categories of waste, a study of instruments used in qualitative and quantitive analyses of hazardous wastes, monitoring system, engineering controls, sampling techniques, data gathering and interpretation, and waste reduction and packaging techniques. Throughout this entire process of development, Mr. Dewey Large of AIDEL Consulting Services has been retained to serve as advisor for all phases of the process and to serve as liaison between Roane State and the various industries and agencies who have an interest. Throughout this investigative and fact gathering period, we have kept our governing board, the State Board of Regents, aware of our intent to respond to your needs and of the status of our progress. In late July, the proposals for the Associate Degree program, Environmental Health Technology and for the option Contaminated Land Reclamation were sent to the State Board of Regents Staff for the review process which is preliminary to the request for approval by the Board members. This Board met in September and these programs were approved. They have been forwarded to the Tennessee Higher Education Cdimission for approval. This body will consider them at their 342 January meeting and assuming approval at that time, we can then begin to accept students for the Fall 1988 class. Though this has been a time consiming and painstaking process of investigation and consultation. If these proposals now awaiting approval by the Tennessee Higher Education Commission emerge f ran that body on a green light, then our work really begins. We must analyze budgets to determine how we can reallocate resources to fund the start-up costs. For several years now, the Higher Education Commission has not approved any funds for new program start-up. Funding for programs is generated by student credit hours, meaning, of course, that there is considerable lag time before any funds are received to operate the program. In addition to resolution of the funding problems, we must identify and obtain appropriate library materials to support the programs; locate qualified faculty to teach courses which perhaps no one has ever taught before in this geographical area; analyze classroan and laboratory space needs and determine where these are available; and recruit students who have special aptitudes for mathanatics and science as well as an altruistic desire to protect and perpetuate a safe and healthful envirorment. At the outset we knew this was an untried trail. We have had in the preparation much cooperation and assistance f ran among your group, and 343 we believe that with this continued support we will implement programs consistent with standards of excellence we set for ourselves and with standards you demand in your employees. There is another component of our involvement in the Waste Management Area. The non-credit or continuing education component addresses the 40/48 hour training program for those who work with hazardous wastes as required by OSHA/SARA. We have completed the 2nd approximation of the training modules, and we expect to have this program in place in a few weeks. Our first workshop will be a 40 hour training program which will utilize the special corporate and human resources found in the Oak Ridge area. If you would like program specific information as it is scheduled, please leave your business card with either Dr. Louise Greene or me. We do appreciate your input and your support in our efforts to meet your training needs. With your help, we will provide you with employees who have received quality training. 345 r.D F:~OM BEST" AVAILAEiLb COPY A University Program in Hazardous Chemical and Radioactive Waste Management Presented by: Frank L. Parker, Vanderbilt University 347 A UNIVERSITY PROGRAM IN HAZARDOUS CHEMICAL AND RADIOACTIVE WASTE MANAGEMENT Frank L. Parker Vanderbilt University The three main functions of a university program are education, training, and research. At Vanderbilt University, there is a Solid and Hazardous Waste option in the Master of Science in Engineering Program. The two main foci are treatment of wastes and environmental transport and transformation of the wastes. Courses in Hazardous Waste Engineering and Radioactive Waste Disposal present a synoptic view of the field, including legal, economic, and institutional aspects as well as the requisite technical content. The training is accomplished for some of the students through the aegis of an intern- ship program sponsored by the U.S. Department of Energy. In the summer between the two academic years of the program, the student works at a facility where decontamination and/or decommissioning and/or remedial actions are taking place. Progress in understanding the movement, transformation, and fate of hazardous materials in the environment is so rapid that it will not be possible to be current in the field without participating in that discovery. Therefore, our students are studying these processes and contributing to new knowledge. Some recent examples are the study of safety factors implicit in assuming a saturated zone below a hazardous waste landfill when an unsaturated zone exists, application of probalistic risk assessment to three National Priority List sites in Tennessee, and the explanation of why certain organics precede pH, conductivity and nitrates through a clay liner at a hazardous waste disposal site. 349 A UNIVERSITY PROGRAM IN HAZARDOUS CHEMICAL AND RADIOACTIVE WASTE MANAGEMENT, Frank L. Parker, Vanderbilt University, Nashville, TN Education and Training In August 198A, Vanderbilt University's Department of Civil and Environ- mental Engineering was awarded a grant by the U.S. Department of Energy to fund a Pilot Internship Program on the Decontamination and Decommis- sioning of Radioactive Waste Sites, because of the need to bring young, properly-trained people into the field. The initial grant was for three years with the intent for an initial enrollment of six students (four graduates and two undergraduates) and an equilibrium level of twelve students for the two-year program. The grant has since been renewed for another three years. Key to the success of the program are the quality of the students (minimum grade average "B") and the practi- cum in the summer between the two academic years. In the practicum, the student gets hands-on experience in the waste field. The summer work must result in a senior paper or part of a master's thesis. The undergraduate students, from all branches of engineering, pursue their own individual curriculum, adding courses in Elements of Modern Physics, Atomic and Nuclear Physics Laboratory, and Radiological Aspects of Environmental Engineering. The graduate students are enrolled in the Solid and Hazardous Waste concentration within the Environmental Engineering graduate program. A suggested curriculum is shown in Table 1. As can be see, such a study program would be equally applicable to a degree in hazardous waste engineering. We did, in fact, offer one of the earliest courses in hazardous waste engineering in the country. Since that time, most engineering schools that offer environmental engineering options offer a course in hazardous waste engineering. A typical hazardous waste engineering curriculum is shown in Table 2 (adapted from MacKenzie L. Davis's article, "A Survey of Graduate Education in Hazardous Waste Management," Journal of the Air Pollution Control Association, September, 1986). Our course is similar except that we put greater emphasis on the environmental transport of hazardous materials. It can be seen that laboratory work is lacking in this course. This is true for most university courses in hazardous waste. This lack is due to liability problems, the availablility of other courses where some of these techniques are taught and the lack of proper instrumentation to carry out the necessary teaching. Key to the success of the summer practicum is the formal structure, outlined below, but informally applied. In the fall, a colloquium is held in which the returning interns present the results of their summer's work to the Technical Advisory Committee and to the new interns. Toward the end of the year, the companies where the students may intern send one-paragraph to one-page descriptions of internship duties that they will sponsor the next summer. Early in the year, most companies send representatives to Vanderbilt to meet with the interns and tell 350 them about the internship opportunities at their various sites. Early in the spring, the students make their choice, with some guidance from me, to assure a reasonable distribution of students among companies and research topics. They then determine with the sponsor which twelve week period would be most suitable for them to spend on site. At the end of the first week or two at the site, the student, with his super- visor, prepares a detailed proposal for the summer's work. this is then sent to me for concurrence. Shortly after that I visit the site for discussions with the supervisor and the students to be sure that both are satisfied with the progress made to date and to iron out any difficulties that may exist. Then the cycle is repeated. In addition, a Technical Advisory Committee composed of high-ranking officials in the major companies with whom we have students doing their practicum meet in conjunction with the fall colloquium at which the interns present the results of their summer's work. They also meet the new interns at that time. Prior to the meeting, the annual report of the internship program and vitae of the new interns are distributed to members of the committee. A list of the present members of the Tech- nical Advisory Committee is given in Table 3. Research The changes in waste disposal understanding and treatment are so rapid that participation in research projects helps the students learn how to keep abreast of such changes. The work of some of the interns, as well as the work of some of the other students in the hazardous chemical waste program, is summarized now: Robert Broshears - The recent Ph.D. dissertation by Robert Broshears at Vanderbilt University examined the risks pre- sented by three hazardous chemical waste sites in Tennessee that are on the National Priority List. Broshears develop- ed a risk algorithm, shown in Figure 1, to determine what degree of treatment or more accurate quantification of the parameters, if any, was needed to meet ingestion standards. In some cases, when none of the above would be sufficient, institutional controls would be necessary. To illustrate the methodology, only the results of the groundwater pathway at the Velsicol Disposal site in Hardeman County, Tennessee will be presented. The topography and a cross section of the site are shown in Figures 2 and 3. From the mid-60s to the early 1970s, the corporation buried 300,000 drums of wastes from the manufacture of organochlorine pesticide waste in near-surface trenches. The wastes included hepta- chlor, dieldrin, heptachlor epoxide, endrin, as well as other organic constituents, including carbon tetrachloride. Only the heptachlor analysis will be dealt with in this paper. For those interested, the,hydraulic conductivity at the site was taken to be 1.2 x 10 m/s, hydraulic gradient, 0.0034, dispersivity, 100 m, and porosity, 0.08. Using standard, simplified first-order deterministic models of degradation, solubilization, and leaching of the waste and 351 dilution of the waste stream with ground water and by ad- vection, dispersion, retardation and degradation and inges- tion of drinking water, maximum individual risks for worst case analysis at 1000 m for times of 100, 1000, and 10,000 years were greater than 10 per year, except for therisks at 100 years for hydraulic conductivities of 1.2 x 10 and for 100 (.and 1000 years at hydraulic conductivities of 1.2 x 10 m/s, where the plume had not yet reached the sam- pling point. Therefore, a probabilistic risk analysis was carried out. The results are shown in Figures 4 and 5 for individual and collective risk, respectively. If one adopts the criterion that 95% of the maximum individual risk less than 10 is an acceptable risk and that a collective risk less than one is also acceptable, one can see that for indi- vidual risks, the 100-year calculation is acceptable, but the 1000 and 10,000 year risks are not. Then one goes back to the algorithm and sees that improved estimates of the solubility and partitioning coefficient by further experi- mentation would lead to the improved estimates shown in Figures 4 d and e. One can see that the 1000-year estimate is satisfactory but that the 10,000 year estimate is not. Similarly, for the collective dose, one can see in Figure 5 that the 100 and 1000 year risks meet the criterion but the 10,000 risk was exceeded until further refinement of the solubility and partitioning were made. It can be seen from this study that, depending upon the time interval utilized and the accuracy of the input data and the criterion of acceptable risk utilized, releases of hepta- chlor may or may not be acceptable. If institutional con- trol of drinking water supplies can be maintained over a period of centuries, then the risks would meet the criteria. Lance Cooper - in most hazardous and low-level radioactive waste burial grounds, the waste trenches are above the water table. When a risk assessment is made of the travel of the wastes to the point of use, the conservative assumption is made that there is no vadose zone, i.e., that the zone beneath the trenches is always saturated. However, the degree of this conservatism is unknown. To determine the relative conservatism, Lance Cooper utilized the SUTRA model of the USGS (developed by Clifford I. Voss) in both the saturated and unsaturated mode. SUTRA (for Saturated-Unsaturated TRAnsport) is a groundwater transport model that allows simulation of either totally saturated systems or combined saturated-unsaturated systems. The model uses a "hybrid finite-element and integrated finite difference" solution scheme. SUTRA allows the simula- tion of variable density fluids (i.e., density changes with concentration), solute production or decay, and solute sorp- tion onto the soil matrix. It may be used for either areal or cross-sectional saturated simulation or cross-sectional 352 unsaturated simulation. It was applied to two of the Nation- al Priority List sites in Tennessee - Hardeman County, already discussed, and North Hollywood. Though there were many chemicals placed in the North Holly- wood site, shown in Figures 6 and 7, the calculations were carried out for chlordane alone, with an unsaturated depth of 3.5 m. (Chlordane is moderately soluble and has a half- life of approximately ten years.) The results are shown in Figure 8, where it can be seen that the saturated solution is conservative. Seven years after emplacement the leachate profiles had reached stady state. As is to be expected, due to lack of dilution, the concentrations directly beneath the site are greater for the unsaturated condition than for the saturated condition by about 35%. The resultant concentra- tions are shown at 400 m from the waste site. It can be seen that the concentrations for saturated conditions are higher than for conditions with an unsaturated zone and a saturated zone. At steady state, the safety factor is about 10%. For Hardeman County, similar calculations were carried out. There the unsaturated zone is about 15 m, as shown previous- ly, and the pollutant of concern is carbon tetrachloride, which is highly soluble but is deemed to be non-biodegrad- able. The results are shown in Figure 9, where it can be seen that steady state is approached in five years for the saturated case and ten years for the unsaturated case. Here it can be seen that the saturated case is conservative by about 50%. The factor of safety was less than two for both waste sites considered in this study. That is, at the same offsite location and at steady state, the saturated concentration was less than twice the unsaturated concentration. The un- certainties that are involved in parameter estimation for the system may cause variances this great, or greater. Though there is no generic solution to this problem, based on these two cases, the inclusion of the unsaturated zone is not warranted in cases where the disposal facility is located in humid regions. This may not be true in arid regions where the depth to the v?ater table is considerably greater than either of the two cases that were considered in this report. David Pods and Dean Gore - We had been asked by one of the owners of a certified hazardous waste burial site to deter- mine why some of the organics placed in the trenches were leaching out of the trenches ahead of the water implaced in the trenches at the same time. We were furnished some of the leachate and some of the liner material from the site. We spiked the samples with additional quantities of meth- ylene chloride, carbon tetrachloride, 1,1,1-trichloroethane, and lithium chloride and potassium iodide in 0.01 N CaSO. 353 solution to approximate groundwater, as shown in Table 4. The organics were chosen because they were present in the leachate. The iodide in the potassium iodide was chosen to approximate water movement because of the presence of chlo- rides in the wastes. It is expected that the anionic iodide would move unimpeded through the compacted clay liner. The cationic lithium was chosen to determine the rate of move- ment of typical cations and as an imprecise surrogate for the hydrogen cation or pH. The organics being non-polar would be less subject to exchange reaction and would move relatively unhindered through the soil. In addition to the clay liner used, which, as shown in Table 5, had large frac- tions of montmorillonite and illite with reasonably high cation and anion exchange capacities, a standard kaolinite with lower exchange capacities was tested. The results are shown in Figure 10, revealing that the organics mostly pre- cede the iodide in systems where mercury was added. It has been observed that there was significant biological degrada- tion of the methylene chloride in the kaolinite tests. Therefore, for the livingstone clay tests, mercury was added to poison any biological growth. This phenomenon of organ- ics preceding the usual pH, conductance, chloride or nitrate indicators of municipal landfill leachates has been identi- fied as hydrodynamic chromatography. The results verify what had been observed in practice and provide the theoretical justification for such early breakthrough of the organics. Zahava Slonim - Rather extensive data are available about the transport of toxic chemicals in air and water, from soil to water, and from soil to air by soil surface volatiliza- tion. However, the information available about the vertical transport of pesticides through dry soil, in the interparti- cle spaces, and the dynamics of this transport is limited. The vertical transport of pesticides in the soil of hpzard- ous waste disposal sites is of concern due to the quantities of toxic chemicals being released over extended periods of time. The important soil characteristics controlling the transport of pesticides through soil are: soil mineral type, soil par- ticle size, soil moisture and temperature. They influence the adsorption and desorption rates of the pesticides to and from the soil particles. The objective of this study was to determine the role of the physical and chemical properties of the pesticides in controlling their vertical movement in the vapor phase though the soil. In our study, the organochlorides lindane, heptachlor, diel- drin, DDT, endrin, and methoxychlor were selected on the basis of their vapor pressures, molecular weights, and relative retention times in gas chromatography, as shown in Table 6. They were studied under controlled temperature and humidity conditions, using clean, dry clay with particle 354 size in a known range. Three different migration patterns were expected, correlated with physicochemical properties. Organochlorides are held on the surface of the soil pcrti- cles by the van der Waals forces between the solid surface and the adsorbed molecules. A pesticide with high vapor pressure has a larger fraction of its total concentration in the soil present in the vapor phase. The migration rate of the pesticide in dry soil will be a function of the fraction of the pesticide which is present in the vapor phase: V = V Fr pap where V = velocity of pesticide (cm/day) V = velocity of air (cm/day) 3 Fr = fraction of pesticide in the vapor phase The adsorption coefficient (fraction of concentration ad- sorbed/total concentration) value for a given pesticide can be derived from the complementary value of the fraction of pesticide in the vapor phase (Fr ). Physical adsorption decreases rapidly as the temperature in- creases and is generally very small above the critical tem- peratures of the adsorbed components. The larger the equi- librium constant (the ratio between the adsorption and de- sorption rate constants), the larger the fraction of time a molecule spends immobilized on the solid surface. This results in the molecule migrating more slowly by diffusion in the vapor phase. The fraction of the pesticide that moved vertically through the soil ^.n the vapor phase could be cal- culated by comparing the observed data with the theoretical. Adsorption coefficients for the different organochlorines can be calculated. The results for the materials that did not degrade are shown in Figure 11. Our results strongly suggest a direct relationship between the mobility of organochlorines in dry soils and their vapor pressure and the differences in relative retention time in gas chromatographic columns, and that organochlorines will migrate in dry soil through the interparticle spaces, pro- vided their concentration is high, and that those with high vapor pressures will move more rapidly than do those with lower vapor pressures. The total dieldrin degradation in the Red Calfkiller River clay suggests that iron oxides present in the soil enhance the breakdown of some organochlorine residues in the soil. If valid, this could be utilized practically by adding iron salts to soils that need to be detoxified. 355 Mike Vick - Mixed hazardous chemical and radioactive wastes are presently orphan wastes. No commercial landfill will accept them. In the cleanup of the Fusrap Colonie Interim Storage Site, the waste was depleted uranium contaminated with an oil and water emulsion, i.e., a mixed waste. The objective was to separate the oil and the uranium from each other and from the water so that the water could be disposed of in the town's sewer system and the oil and uranium to their respective sites. The schematic of how to accomplish this is shown in Figure 12. First, the tramp oils on the surface of the tank were sorbed. The oil-water emulsion was broken by the acid-alum split (pH < 2.0), then alum [A1-(SO,)_] was added to act as a coagulant and adsorbent and finally to raise the pH to 6.7 causing the precipitation of the aluminum hydroxide. The supernatant was then raised to a pH > 10 to cause the precipitation of uranic oxide (UO,). The process worked successfully, and, of the initial 1000 gallons of waste, 860 gallons of decontaminated water were deemed safe for discharge to the sewer, and the 30 gal- lons of tramp oil, 40 gallons of uranic oxide slurry and the 70 gallons of aluminum hydroxide slurry were solidified with a gypsum cement. Bill Crawford - Plutonium 238 is used for specialized energy sources. In the course of the manufacture of the energy sources, waste is generated. Waste disposal is expensive, but the loss of the plutonium is even more expensive. The production and the wastes must be handled within glove boxes hermetically sealed to prevent loss of the extremely toxic alpha-producing wastes. Bill designed a pyrohydrolysis in- cinerator (to maintain temperatures low enough to extract the Pu after incineration), shown in Figure 13, that would fit into a glove box. The cost of the system was $300,000 and the avoided costs of waste disposal of plutonium- contaminated waste was $400,000 the first year alone. This ignores the value of the estimated 10 kg of Pu-238 per year that will also be recovered. Conclusions University programs in hazardous waste engineering differ. Even within one university, there are numerous other activities that have not been discussed here. At Vanderbilt, there are professors within the same department as mine who are working on other topics. There are some chemistry professors who are working on the removal of toxic metals from human systems, and others who are removing volatile materials from burial grounds. There are investigations in the Medical School con- cerning the effects of organics on human systems. So what do the universities have to offer? They train workers and future leaders in the waste disposal field. They can and do do the research and the integration of the results which cannot be done on a commercial basis where there are always fires to be extinguished. 356 Universities need help in locating high-quality students for training and providing these students with hands-on experience in the field and lectures based on field experience in the classroom. 357 ACCEPTABLE START WORST CASE RISK DONE UNACCEPTABLE PROBABIUSTIC RISK ACCOTARX UNACCEPTABLE MEAN RISK ACCEPTABJ. EXTREME RISK DONE UNACCEPTABLE REMEDIAL ACTION STUDCS NOTFIASBLf NSTTUTIONAL CONTROL NOT FtAS8lI ASSESSMENT Figure 1. Risk Assessment Algorithm for Hazardous Waste Sites (after Broshears, 1986) 358 Scale J:2W)00 Figure 2. Plan View of Hardeman County Disposal Site (after Broshears, 1986) E LfT-UVIAL DEPOSITS ZOCr 1000 500 0 500 1000 FEET VERTICAL EXAGGERATION > S Figure 3. Profile Beneath Hardeman County Disposal Site (after Broshears, 1986) -S -t -1 -i -S LOG OT INOlVIOUftL RISK LOG Of INDIVIDUAL RISK fur III.IIVIIIUJI ruk 1,1,1.jl .1 II.L V.la.c.l |l,»|,,=al S,lc ifciin fi.r i k Hn" li. hr-pl;l, |,|.,t f,ir l ,.n|..,,.r,l ( . I....I »l V.l»i:,,l l),»|,,,,u| Silo LOG OF 1ND1VIUUHL ram for n..l.vi.l.,,1 ,,,k ,hir la In |,l»rlilot /or iim- 111liK.1l ,it V.I,.M.I llupiul Sill for indiviilntl rnV .lur lo tir|il:irtit,,r I.,. H Kl.auiV .,|.|.,vo,l |.«r.ipnl,r .Irlinil it Vrhii'ul Hu|n.i4l Sl -• -7 -» -5 LOG OF JNOlVltXKIL RISK fHiii fill iniliviilual lisk <<•!<• l Figure 4. Individual Risk, Heptachlor, Velsicol Site (after Broshears, 1986) •///<>///• 1.1 •Mfc- r •:<;;::% '/'y/yy//\yy//'/'\ //'•/ '/ *'.••/•'•////^/s.'/s.- vj • , • •/' •'////,/./ -l.S -1.0 -O.b 0.U 0.S 1.0 -2.0 -l.i -1.0 -fl.S u.o LOC OF COUKCTIVE KISK LOG Of' COLLECTIVE KJSK llisUigr.ini for cullcrlivc risk ilur Ln lirpt.-irlitor for a 10,000-yr tiigram (cir collective: r»k iluc Lu lupUi hlor fur a lUO-yr time iiilcrvul \k\ Wm Vcbaul |j»|iuoal Siic Ullic iiiLfrvul al Vclsicol iJiHposal Silc o -2.5 -2.0 -I.S -1.0 U.S 0.0 o.s I.S -2.0 -l.S -10 "OS o.o LOG OF COLLLCTIVE KISK LOG OF COLLECTIVE RISK lli.sli.Rr.im f,,r cnllii live risk ilm- t.> hriiUrlili.r fur a lUOOyr lliiLup.rini for collcrlivr risk due to luptaclilor fur a 10,000- Him- llit.rv.il al the Vi-bi.,,1 D.sp.nal Nile ir Linn inti'rv,ii and improved paraiiu'lt-r defutilioii ul Vclsicol l>ispus^l Site Figure 5. Collective Risk, Heptachlor, Velsicol Site (after Broshears, 1986) 361 Figure 6. Plan View of North Hollywood Dump (after Broshears, 1986) a. HOLLYWOOD Ml DUMP LOESS 250 FliUVJAL 200 "ALLUVIlfl^T LEV E DEPOSITS < i to 150 > o ^» •O-D 100 CLAY- CONFINING BED UJ^> LU 50 O N I F l U! .'..' MEMPHIS. SAND "'' -bO Figure 7. Profile Beneath North Hollywood Dump (after Broshears, 1986) RELATIVE CONCENTRATION, C/C. RELATIVE CONCENTRATION, C/C. c 1-1 o • I-" I- W "5 <° O P> 0 rt- CL H- O (D •1o on o to (D rt 3 (1- X 1 II D9 1 *• rt- o p. o o V) H cro C n CO v//////////////////, n 3- (D 3 n V/////////////////A n (ti 3 O 3 n tn Y/////77//7X DEFINITION OK HA2AKDOUS WASTE TOXICOLOGY ENVIRONMENTAL AND WATER RESOURCES ENGINEERING LEGISLATION/REGULATIONS RCRA Solid and Hazaiduut. Waste Option CERCLA KirsI Year MANAGEMENT ALTERNATIVES KWKE 260 Solid Waste Management SOURCE REDUCTION EWKE 2t>9 Radiological Aspects of Environmental Engineering GOOD HOUSEKEEPING EWKE 271 Environmental Chesistry 3 PROCESS MODIFICAlION hw'KE 276 Cr'jupH Water Hydrology SOURCE SEGREGATION EWKE 277 Open Channel Hydraulics 3 EWKE 278 Hydrology 3 REUSE EWKE 300 Water Quality Management - RECYCLING EWKE 318 Systems Analysis for 3 WASTE EXCHANGE Environmental Engineers 12 12 TREATMENT/PRETREATMENT ADSORPTION EXTRACTION Second Year DISTILLATION EWKE 272 Microbiology of Water, Waste- NEUTRALIZATION water, and Air OXIDATION EWRE 273 Environmental Chemistry Lab 3 EWRE 279 Economics and Law of Air and 3 Water Resources THERMAL TREATMENT EWKE 280 Atmospheric Pollution COMBUSTION PROCESSES EWKE 155 Hazardous Wastes Engineering 3 PYROLYSIS Math 233 Introduction to Statistics 3 Electives CATALYTIC OXIDATION AIR POLLUTION CONTROL 12 13 LAND DISPOSAL HYDROGEOLOGY SECURE LANDFILL DESIGN LAND TREATMENT Table 1. Suggested Curriculum REMEDIATION SITING Table 2. Hazardous Waste Course Outline 365 E. L. Albenesius E.I. DuPont De Nemours Savannah River Laboratory Aiken, SC 29801 L. C. Brazley U.S. Department of Energy Washington, D. C. 20545 Frank Coffman IT Corporation 312 Director's Drive Knoxville, TN 37933 Frank Crimi Nuclear Energy Business Operations General Electric Company P. 0. Bex 325 Shippingport, PA 15077 Morton Goldman NUS Corporation 910 Clopper Road Gaithersburg, MD 20878 George Hardigg School of Engineering Advisory Committee 2064 Outlook Drive Pittsburgh, PA 15241 Robert Mason Bechtel National, Inc. P. 0. Box 350 Oak Ridge, TN 37830 Henry McGuire Westinghouse Hanford Operations P. O. Box 1970 Richland, WA 99352 9-10-87 Table 3. Advisory Committee Members 366 MILTIHC BOIUHC srEctnc TAPOR SOl-UBlLirt S0LUB1L1TT OCTANOt/ POIWT fOIHT cuAvin russuxE IN HjO IH OBCANIC (°C) (°C) SOLVENTS WATtK « 20°C) ("• Hg) (pp«) »A«T. COErr. HETHTLERZ CHLORIDE dt.Cl 4lehlorc«ch«n« -»S.l 40 1.J27 13,100* - •w - 8«.M CARSO* TETUCTILORIDt ccl* -21. M 1.39* too 2.7) tttrichlorcatthtn* w • 15J.82 1,1, i-TMcnunonnMiE OljCCI, -31.0 1. J« 410 2.«f •» • 113.41 t - T«k*» froa CltC «n* 9tttl( ('. 10) • - 20» C • - »• e •• - io» c Table 4. Physical Constants of Contaminants ROfCTTltS XAOLINITE LIVINGSTON SANS Not tastad 0.0 X SILT lab grad* •:.: CLAT elay 37.» ORGAHIC COKTENT S.t 7.4 Z CATION EXCHANGE CAPACITT 23.0 54.0 Mq/100| ANION EXCBANCE CATACITT 4.8 ]4.5 »*q/100| KAJOt HoBtaor- CUil Kaolloltc lllODlCC, SPECIES Ulltc Table 5. Clay Properties 367 MOLECULAR VAPOR PRESSURE PESTICIDE • * KA0LIN1TE COLUMNS RED CALFKILLER*** COLU"NS WEIGHT • 20° C RT RECOVERY DEGRADATION RECOVERY (ran Hg) DEGRADATION (t) (*) ITNDANE 290.6 9.4 x 10"6 short 93.0 No HEPTACHLOR 373.3 3 x 10""* short 0.003 Yes 0.0 Yes DIELDRIN 361 1.78x 10"7 intermediate 87.5 No 0.0 Yes ENORIN 373.9 2 x 10"7* intermediate 0.003 Yes METHOXYCHLOR 345.7 7 long 96.0 NO DDT 354.5 1.9 X 10"7 long 0.4 Yes t 25° C R. • Relative Retention Time Coraon alluvial clay rich in quartz with high concentration of iron oxides Table 6. Movement of Organochlorines Through Soils 100 60 o "3 50 DDT DIELDR1N z LINDANE 0 40 AT ! Z Ul u 30 o u LJ a 20 0 1/P1 UJ 0. 10- 3*5 FRACTION NUMBER Figure 11. Migration Profiles of Lindane, Dieldrin, and DDT in Kaolinite Column Steam Combustion Air REMOVAL Of TRAMP OILS ACIDIFY TO ADDITION pH<2 Of ALUM Primary s Chamber 1 REMOVE SURFACE SOLIDS A«b I ADDITION Of NAOH(pH . 6.S-7) nrr.AUT , _,_ ,_l ' I WATER ADDITION Of HEPA f • NAOM(PH > 10) ALUMINUM HYDROXIDE SLURRY T .. MUMCR CX> To URANIUM . Suck rntc»riAit SOLIDIFICATION I Blower INTERIM STORAGE SUV - Siatcrad N«t«l Flltar HSPA - High efficiency Partlou!*!* Wlt«r Figure 13. Schematic of Plutonium Recovery Incinerator Figure 12. Flow Diagram of Treatment Process 369 Interpreting the SARA and RCRA Training Requirements Presented by: W. Michael Moreland, ORNL 371(372 INTERPRETING THE SARA AND RCRA TRAINING REQUIREMENTS W. Michael Moreland Susan M. Wells Technical Resources and Training Group Environmental Compliance and Health Protection Division Oak Ridge National Laboratory Oak Ridge, Tennessee 37831 The Resource Conservation and Recovery Act (RCRA) and the Superfund Amendments and Reauthorization Act (SARA) promulgated by the EPA (RCRA) and the OSHA (SARA) require hazardous materials training for all individuals working with hazardous materials. Facilities that are involved in the generation, storage, treatment, transportation, or disposal/removal of hazardous materials/waste must comply with all relevant training regulations. Using the guidelines contained in the RCRA and SARA regulations, decisions must be made to determine: - The type of regulatory requirement based on facility function (i.e., whether the facility is a RCRA or CERCLA facility). - The type of training required for specific categories of workers (e.g. managers, supervisors, or general site workers). - The level of training needed for each category of worker. This presentation will outline how the Environmental Compliance and Health Protection Technical Resources and Training Group, working with waste operations personnel, establishes specific training requirements. 373 INTERPRETING THE SARA AND RCRA TRAINING REQUIREMENTS, W. Michael Moreland and Susan M. Wells Technical Resources and Training Group, Environmental Compliance and ^Health Protection Division, Oak Ridge National Laboratory , Oak Ridge, Tennessee 37831 ABSTRACT The Resource Conservation and Recovery Act (RCRA) and the Superfund Amendments and Reauthorization Act (SARA) promulgated by the EPA (RCRA) and the OSHA (SARA) require hazardous materials training for all individuals working with hazardous materials. Facilities that are involved in the generation, storage, treatment, transportation, or disposal/removal of hazardous materials/waste must comply with all relevant training regulations. Using the guidelines contained in the RCRA and SARA regulations, decisions must be made to determine: - The type of regulatory requirement based on facility function (i.e., whether the facility is a RCRA or CERCLA facility). - The type of training required for specific categories of workers (e.g. managers, supervisors, or general site workers). - The level of training needed for each category of worker. This presentation will outline how the Environmental Compliance and Health Protection Technical Resources and Training Group, working with waste operations personnel, establishes specific training requirements. BACKGROUND There are currently several federal regulations requiring facilities that are involved in hazardous material activities to train employees concerning the hazards that surround them. All facilities, including the Oak Ridge National Laboratory (ORNL), that are permitted under the Resource Conservation and Recovery Act (RCRA)* are Operated by Martin Marietta Energy Systems, Inc., for the U. S. Department of Energy under Contract No. DE-ACO5- 840R21400 "the submitted manuscript hai bMn author«d by a contractor of tha US. Government under contract No. DE- AC0S-84OR21400. Accordingly, the U.S. Government retains a nonexclusive, royalty-free license to publish or reproduce the published form of this contribution, or allow others to do so. for U.S. Government purposes." 374 currently required to comply with 40 CFR Part 265 by putting into place a RCRA training course that trains employees on proper hazardous waste management procedures, emergency response and worker protection. Recently OSHA, under the Department of Labor in response to Title I, Section 126, of the Superfund Amendment Reauthorization Act (SARA)2 issued a final interim standard (29 CFR 1910.120), which requires the training of hazardous waste workers in worker protection techniques and the health effects of hazardous materials. Review of both regulations reveals there are various exceptions as well as non-specific requirements that must be interpreted in order to develop specific facility training curriculums that will meet the intent of the above regulations. The following paragraphs will review the specific training requirements contained under 40 CFR Part 265 and 29 CFR 1910.120 and discuss the approach used by the Environmental Compliance and Health Protection Division's Technical Resources and Training Group in developing hazardous material worker training curriculums that comply with the EPA (RCRA) and OSHA (SARA) training regulations . REGULATION OVERVIEW 40 CFR 265.16 (RCRA) The training requirements for employees working at facilities .permitted under RCRA are contained in 40 CFR Part 265.163. Specifically, this training regulation requires that facility personnel complete classroom instruction or on-the job training. The training must include instruction which teaches facility personnel hazardous waste management procedures ( including contingency plan implementation) relevant to the positions in which they are employed. 1. Minimum Requirements 40 CFR Part 265.16 requires that the RCRA training program at a minimum must ensure that facility personnel are able to respond to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: (1) Procedures for using, inspecting, repairing, and replacing emergency and monitoring equipment; (2) Key parameters for automatic waste feed cut-off systems; (3) Communication or alarm systems; (4) Response to fires or explosions; 375 (5) Response to hazardous material spills; (6) Shutdown of operations. The minimum requirements seem to indicate that emergency response personnel must receive this training or show documentation of equivalent past training meeting these requirements. The workers that this regulation addresses are approximately the same as those requiring the OSHA (SARA) training under 29 CFR 1910.120 . Time Constraints 40 CFR Part 265.16(b) states that employees working in RCRA permitted facilities are required to receive training within 6 months following employment in order to work in a RCRA facility area unsupervised. Retraining On an annual basis, all workers previously receiving RCRA training must take part in review of the initial training gi ven. Documentati on 40 CFR Part 265(d) requires RCRA-permitted facilities to maintain the following documentation: (1) JOB TITLE for each worker position at the facility related to hazardous waste management, (2) NAME of employees filling each job title (3) JOB DESCRIPTION for each position listed under (1). This description must include requisite skill, education, other qualifications, and duties of facility personnel assigned to each position. (4) TRAINING DESCRIPTION - Written description of the type and amount of both introductory and continuing education training that will be given to each person filling a position listed in (1). (5) RECORDS that show proof that employees have received the required training for their job position identified in (1) and (4). This should consist of tests or sign-in sheets (6) RECORD MAINTENANCE must be provided so that training records are maintained of all current personnel until closure of the facility or at least three (3) years 376 following the last day the employee worked at the faci1i ty. 29 CFR 1910.120 (SARA) Unlike 40 CFR Part 265.16 (RCRA) which was written by the EPA to train employees in hazardous waste management procedures and emergency response, the interim final rule 29 CFR 1910.1204 promulgated by the OSHA focuses on the training of hazardous waste workers in hazardous materials protection methods, health risks, and emergency response. Training requirements are outlined in Table 1. Time Constraints The proposed rule specifies that employees must have the training specified before they are allowed to work in hazardous waste operations where they might be exposed to health and safety hazards. Specifically, the OSHA requires 40 hours of classroom instruction for workers involved in RCRA and CERCLA (Comprehensive Environmental Response, Compensation and Liability Act of 1980^) remedial action operations. Those workers involved solely in treatment, storage, and disposal operations permitted under Section 3004 of RCRA require only 24 hours of classroom instruction. Workers must be provided with this training at the time a job is assigned. Once an employee has received the required training, he/she need not be retrained to work at subsequent sites, even if a different employer is involved. General Worker Training Requirements Since waste sites contain many potential hazards, workers should be trained to: Recognize hazards, Apply appropriate work practices to minimize the hazards, and Properly use respirators and other personnel protective equipment. To assure that this is accomplished, an extensive training program is necessary. This is reviewed in depth elsewhere in this paper. 377 Supervisor/Manager Training Requirements Since supervisors and managers directly responsible for waste site operations must be prepared to make informed decisions and provide guidance, they are required to receive a minimum of eight additional hours of specialized training on managing hazardous waste sites. Training, whether for general workers or managers and supervisors, should be geared to the worker's job function and responsi bi1ity. Emergency Response Training According to 29 CFR 1910.120, training must also be conducted for emergency response employees at hazardous substance clean-up operations that: - Are covered by the CERCLA. This includes initial investigationsperformed at CERCLA sites to ascertain whether hazardous substances are present. - Involve major corrective actions at clean-up operations covered under RCRA. This includes remedial investigation and feasibility studies at sites. - Involve hazardous waste sites designated by state and local authorities. When there is a reasonable possibility that these workers may be asked to respond to emergencies at hazardous waste treatment, storage, and disposal facilities permitted under RCRA, 24 ho^rs of initial training and 8 hours of annual refresher training must be provided for them. To meet the 24-hour requirement, initial training sessions must be held at least monthly. Workers in this category would include fire departments, plant emergency organizations, hazardous materials teams, spill response teams, and other groups with responsibility for emergency response. Employees, who will be consulted for technical advice or assistance concerning specific hazardous materials in the event of a spill or hazardous substance release incident, must have 24 hours of training annually or demonstrate competency in their area of specialization. However, training sessions for these workers need not be held on a monthly basis. If a facility has a fully-trained emergency response team that is prepared to respond in a reasonable amount of time, workers must have sufficient training to recognize that an emergency response situation exists, but are required to have 24 hours of training. 378 If skilled support personnel from outside of the organization such as off-site contractors are utilized, 29 CFR 1910.120 does not require 24 hours of training or demonstration of competency. It is the responsibility of the employer to provide an initial briefing for outside support personnel before they become involved in an emergency situation. The briefing should include information regarding duties to be performed, chemical hazards involved, and instruction in wearing the proper personal protective equipment. Retrai ninq Hazardous waste workers must be reminded that being engaged in hazardous waste operations can pose serious health and safety risks. For this reason, the OSHA/SARA regulation requires that eight hours of annual retraining be provided to employees. ORNL FACILITY COMPLIANCE The first step undertaken by our group in deciding what training curriculum was needed involved an intense review of both the SARA and RCRA regulations to determine if and how ORNL must comply with the regulations. The Laboratory has hazardous waste treatment, storage, and disposal (TSD) facilities that are currently under interim status or permitted under RCRA. Although ORNL has sites that fall under the jurisdiction of CERCLA/SARA, these sites are currently being addressed under RCRA 3004(u). Both RCRA and SARA training regulations explicitly mention that corrective actions undertaken under the authority of RCRA Section 3004(u) as well as interim status or permitted TSD facilities must comply with both regulations. Therefore, ORNL has developed and implemented a RCRA training program to comply with 40 CFR Part 265.16 and is currently in the process of completing a training curriculum to comply with 29 CFR 1910.120. Below is a discussion of the training curricula that have been developed to comply with these regulat ions. BASIC ORNL WORKER TRAINING CURRICULUM Oak Ridge National Laboratory has a variety of divisions which are responsible for performing hazardous material/waste operations. Within each of these divisions are various categories of workers which come in contact with a wide variety of hazardous/radioactive materials at various treatment, storage, and disposal facilities. Because of the complexity in developing a training curriculum that will meet the specific needs of workers supporting a multi-functional laboratory, the Technical 379 Resources and Training Group, in conjunction with these divisions, has developed the ^allowing training curricula to meet the requirements se. ^th under 40 CFR Part 265 and 29 CFR 1910.120. ORNL RCRA TRAINING PROGRAM An outline of the ORNL RCRA training curriculum is given in Table 2. Under each of the RCRA subjects in Table 2, classroom instruction is given to inform employees about the proper methods used by the ORNL to manage hazardous materials/waste. Although workers may be involved in different activities such as transportation, treatment, or disposal of hazardous materials, the training curriculum has been subdivided into modules that all workers receive regardless of their responsibilities. Thus, they can better understand their own role in the ORNL operations that are involved with hazardous materials from "cradle to grave." The RCRA training program being implemented at ORNl. requires that employees demonstrate proper knowledge of waste management procedures through on-the-job exercises and written tests. Because of the wide variety of operations that involve hazardous materials, the RCRA training program at ORNL has evolved into a 40-hour classroom/on-the-job training curriculurn. ORNL SARA TRAINING PROGRAM The SARA training curriculum currently under development to comply with 29 CFR 1910.120 is also outlined in Table 2. Upon reviewing the SARA outline, it can be seen that the proposed ORNL SARA/OSHA training curriculum emphasizes worker protection methods and health effects of hazardous materials. Because ORNL is only involved currently in operating treatment, storage, and disposal facilities permitted under RCRA, most ORNL hazardous waste workers will require the SARA training curriculum consisting of 24 hours of classroom and field exercises. For those employees who may engage in remedial waste clean-up operations, the SARA training curriculum will be expanded to 40 hours of instruction in order to remain in compliance with 29 CFR 1910.120. In order to meet the specific training requirements established by OSHA for different categories of workers, the training outline presented above will be revised to include information needed by workers exposed to unique hazards and supervisors/managers. Using guidelines developed jointly by the NIOSH/OSHA/USCG/EPA6 the ORNL 380 SARA training curri culurn will address three categories of workers: - General Site Workers - Unique Hazard Workers - Supervisors/Managers The level of training to be presented to each category of worker listed above will be consistent with the following type of materi al : 1. General Site Workers - Site Safety Plan - Safe Work Practices - Nature of Anticipated Hazards - Handling Emergencies and Self-Rescue - Safe Use of Field Equipment - Handling, Storage, and Transportation of Hazardous Materi als - Employee Rights and Responsibilities - Use, Care, and Limitations of Personal Protecti ve Clothing and Equipment - Safe Sampling Techniques 2. Workers Exposed to Unique Hazards - Training Requirements for General Site Workers - Site Surveillance - Site Safety Plan Development - Use and Decontamination of Fully Encapsulating Personal Protective Clothing and Equipment - Use of Instruments to Measure Explosivity, Radioactivity, etc. - Use of Specialized Equipment - Topics Specific to Identified Site Activities 3. Supervisors/Managers - Training for General Site Workers - Training for Workers Exposed to Unique Hazards - Management of Hazardous Waste Site Clean-up Operati ons - Management of Site Work Zones - How to Communicate with Press and Local Community Table 1 illustrates the amount of trai ni ng that is required for each category of worker depending on the type of facility that they work i n. CONCLUSIONS When a comparison is made of the curricula developed by ORNL to comply with 40 CFR Part 265 and 29 CFR 1910.120, much of the training presented may overlap. The most 381 significant difference between RCRA and SARA training is the emphasis on worker protection and health hazards under SARA versus hazardous waste management procedures and emergency response under RCRA. ORNL is reviewing the RCRA, SARA and other related training programs so that excessive duplication does not occur. Though the SARA training curriculum presented in this paper has not been finalized, it represents our best interpretation of the EPA and OSHA regulations. The pilot presentation of the in-house SARA training will be offered in November, 1987; after evaluation of the pilot session, it will be finalized and offered on a regular basis. REFERENCES 1. Resource Conservation and Recovery Act of 1976 (RCRA), Public Law 94-580, October 21, 1976, 90 Stat. 2795. 2. Superfund Amendments and Reauthorization Act of 1986 (SARA), Public Law 99-499, October 17, 1986, 100 Stat. 1613. 3. Personnel Training, 40 CFR Part 265.16, Federal Register- 50 FR 4514 January 31, 1985. 4. Hazardous Waste Operations and Emergency Response, 29 CFR 1910.120, Federal Register- 52 FR 29620, August 10, 1987. 5. Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or "Superfund"), Public Law 96-510, December 11, 1980, 94 Stat. 2795. 6. Occupational Safety and Health Guidance Manual l-'or Hazardous Waste Site Activities, National Institute for Occupational Safety and Health (NIOSH), Occupationa Safety and Health Administration (OSHA), United States Coast Guard (USCG), and Environmental Protection Agency (EPA), DHHS (NIOSH) Publication B5- 115, October 1985. Table 1. SARA Training Requirements Basic Basic Mgt. On-Site Annual (24 hrs) (40 hrs) (8 hrs) Field Refresher Exper. (8 hrs) (24 hrs) Remedial Action General Site Workers Remedial Action Supervisors/ Managers CERCLA Facility Workers CO CERCLA Facility C» Supervisors/ ro Managers RCRA Facililty Workers RCRA Facility Supervisor/ Managers Emergency Response Personnel 383 Table 2. RCRA and SARA Training Programs RCRA SARA RCRA Regulation Overview SARA Regulation Overvi ew Worker Protection ORNL Hazardous Waste Site Overview Storage Types of Hazards Transportation Toxicology Treatment Protective Equipment Di sposai Medical Surveillance Moni tori ng Site Evaluation and Control Emergency Response Emergency Response U.S. GOVERNMENT PRINTING OFFICE 1988-548-118/60136