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

Annual Site Environmental Report
Because of the age of many of the ETTP facilities and the varied uses for PCBs in gaskets, grease,
building materials and equipment, DOE self-disclosed unauthorized use of PCBs to EPA in the late
1980s. As a result the DOE Oak Ridge Office and the EPA Region 4 consummated a major compliance
agreement known as the Oak Ridge Reservation Polychlorinated Biphenyl Federal Facilities Compliance
Agreement which became effective on December 16, 1996. The agreement specifically addresses the
unauthorized use of PCBs in ventilation ducts and gaskets, lubricants, hydraulic systems, heat transfer
systems, and other unauthorized uses; storage for disposal; disposal; cleanup and/or decontamination of
PCBs and PCB items including PCBs mixed with radioactive materials; and records and reporting
requirements at the ORR. A major focus of the agreement is the disposal of PCB waste. As a result of that
agreement, DOE and BJC continue to notify EPA when additional unauthorized uses of PCBs, such as
PCBs in paint, adhesives, electrical wiring, or floor tile are identified at the ETTP.
ETTP is home to the TSCA Incinerator. On December 2, 2009, the TSCA Incinerator ceased
operations as a waste incinerator and shifted into a facility closure and decommissioning mode.
3.3.12 Emergency Planning and Community Right-to-Know Act Compliance Status
The Emergency Planning and Community Right-to-Know Act (EPCRA) and Title III of SARA
require that facilities report inventories and releases of certain chemicals that exceed specific release
thresholds. The reports are submitted to the local emergency planning committee and the state emergency
response commission. ETTP complied with these requirements in 2009 through the submittal of reports
under EPCRA Sections 302, 303, 311, and 312.
ETTP had no releases of extremely hazardous substances, as defined by EPCRA, in 2009.
3.3.12.1 Material Safety Data Sheet/Chemical Inventory (Sects. 312)
Inventories, locations, and associated hazards of hazardous and extremely hazardous chemicals were
submitted in an annual report to state and local emergency responders as required by the Sect. 312
requirements. Of the chemicals identified for CY 2009 on the ORR, eleven were located at ETTP.
Private-sector lessees associated with the reindustrialization effort were not included in the 2009
submittals. Under the terms of their lease, lessees must evaluate their own inventories of hazardous and
extremely hazardous chemicals and must submit information as required by the regulations.
3.3.12.2 Toxic Chemical Release Reporting (Sect. 313)
DOE submits annual toxic release inventory reports to EPA and TDEC on or before July 1 of each
year. The reports cover the previous calendar year and address releases of certain toxic chemicals to air,
water, and land as well as waste management, recycling, and pollution prevention activities. Threshold
determinations and reports for each of the ORR facilities are made separately. Operations involving toxic
release inventory chemicals were compared with regulatory thresholds to determine which chemicals
exceeded the reporting thresholds based on amounts manufactured, processed, or otherwise used at each
facility. After threshold determinations were made, releases and off-site transfers were calculated for each
chemical that exceeded one or more of the thresholds.
3.4 Air Quality Program
The U.S. Environmental Protection Agency (EPA) Mandatory Greenhouse Gas (GHG) Reporting
Rule was enacted September 30, 2009 under 40 Code of Federal Regulations (CFR) Part 98.2. According
to the EPA rule, in general, the emissions threshold for reporting requirement is 25,000 metric tons or
more of carbon dioxide equivalent (CO2e) per year. A review was performed of ETTP processes and
equipment categorically identified under 40 CFR 98.2 whose emissions must be included as part of a
facility annual GHG report starting with the calendar year 2010 reporting period. On December 2, 2009,
the K-1435 Toxic Substances Control Act (TSCA) Incinerator (Fig. 3.4) ceased operations as a waste
incinerator and shifted into a Facility Closure and decommissioning mode. Based on projected GHG
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