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DOE/ORO/2327 Oak Ridge Reservation Annual Site Environmental ...

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4.3.10 Audits and Oversight<br />

<strong>Annual</strong> <strong>Site</strong> <strong>Environmental</strong> Report<br />

A number of federal, state, and local agencies oversee Y-12 activities. In 2000, Y-12 was inspected<br />

by federal, state, or local regulators on five occasions. The TDEC Department of Energy Oversight<br />

Division maintained a part-time regulator on site who provided periodic oversight of Y-12 activities.<br />

Except for work completed under the Federal Facilities Agreement (FFA), TDEC <strong>DOE</strong> Oversight work is<br />

non-regulatory. This clarification should be made to avoid a misunderstanding of TDEC <strong>DOE</strong><br />

Oversight’s role at Y-12. Most other matters such as CAA, CWA, and RCRA are regulated by TDEC’s<br />

Knoxville Basin Office, not TDEC <strong>DOE</strong> Oversight. The <strong>Environmental</strong> Restoration Section at TDEC<br />

<strong>DOE</strong>-O handles CERCLA matters at Y-12. In addition to external audits and oversight, Y-12 has a<br />

comprehensive self-assessment program. A summary of external regulatory audits and reviews for 2009 is<br />

provided in Table 4.6.<br />

Table 4.6. Summary of external regulatory audits and reviews, 2009<br />

Date initiated Date completed Conducted by Title of assessment<br />

1/14/2009 1/14/2009 City of <strong>Oak</strong> <strong>Ridge</strong> Semi-<strong>Annual</strong> Industrial<br />

Pretreatment Compliance<br />

Inspection<br />

1/21/2009 1/22/2009 TDEC TDEC <strong>Annual</strong> Clean Air<br />

Compliance Inspection<br />

8/4/2009 8/4/2009 TDEC Underground Storage Tank<br />

Compliance Inspection<br />

9/14/2008 9/14/2009 City of <strong>Oak</strong> <strong>Ridge</strong> Semi-<strong>Annual</strong> Industrial<br />

Pretreatment Compliance<br />

Inspection<br />

11/2/2009 11/5/2009 TDEC TDEC <strong>Annual</strong> RCRA<br />

Inspection<br />

Total<br />

findings<br />

1 a<br />

a<br />

The City of <strong>Oak</strong> <strong>Ridge</strong> requested an action plan to address inflow/infiltration into the sanitary sewer<br />

system.<br />

Abbreviations:<br />

RCRA—Resource Conservation and Recovery Act<br />

TDEC—Tennessee Department of Environment and Conservation<br />

4.3.10.1 Enforcement Actions and Memos<br />

There was no consent orders issued to Y-12 in 2009. The <strong>DOE</strong>-EM contractor for the <strong>Oak</strong> <strong>Ridge</strong><br />

<strong>Reservation</strong> construction demolition landfill at Y-12 received a NOV for MCL exceedance in<br />

groundwater monitoring well GW-305 at Industrial Landfill IV from TDEC in November 2009. There<br />

was no impact to the operation of Industrial Landfill IV. Due to the remote location of this groundwater<br />

monitoring well from public property and/or drinking water sources, there is negligible impact at this<br />

point from a health and safety viewpoint. <strong>Environmental</strong> impacts will be determined as part of the<br />

required Phase III Assessment Monitoring Program Plan as required by the TDEC Solid Waste<br />

Regulations.<br />

4.4 Air Quality Program<br />

Permits issued by the state of Tennessee are the primary vehicle used to convey the clean air<br />

requirements that are applicable to the Y-12 Complex. New projects are governed by construction<br />

permits, and eventually, the requirements are incorporated into the site-wide Title V operating permit.<br />

Sections of the Title V permit contain requirements that are generally applicable to most industrial sites.<br />

Examples include requirements associated with asbestos controls, control of stratospheric ozone-depleting<br />

chemicals, and control of fugitive emissions as well as the general administration of the permit. The<br />

Title V permit also contains a section of specific requirements directly applicable to individual sources of<br />

The Y-12 National Security Complex 4-33<br />

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