1 - paducah environmental information center

Annual Site Environmental Report for 1999
EPA had authorized the Commonwealth of
Kentucky to exclusively administer the RCRA
base program for treatment, storage, and
disposal units but had not given the
authorization to administer the 1984 Hazardous
and Solid Waste Amendments (HSW A)
provisions. Therefore, a permit application was
submitted to both the· EPA and Kentucky
Division of Waste Management (KDWM) for
treatment and storage of hazardous wastes. On
July .16, 1991; a to-year RCRApermit
~No. KY8890Q()8982) was issued by KDWM
and EPA to DOE as owner and operator and
DOE's prime contractor as cooperator (currently
B~chtel Jacobs Company LLC). This RCRA
permit consists of two individual permits - a
hazardous waste management permit
administered by the Commonwealth of Kentucky
and a HSW A permit administered by the EPA.
The hazardous waste management permit issued
by the Commonwealth of Kentucky contains
regulatory provisions for treatment, storage, and
disposal activities at POOP, authorized under the
RCRA base program (pre-HSW A), as well as
HSW A provisions. The EPA HSW A permit
addresses only the provisions of the HSW A,
which include corrective actions for solid waste
management units (SWMUs), air emissions, and
the land disposal restrictions. In 1996, Kentucky
received authorization to administer the HSW A
provisions in lieu of EPA. Even though the state
is authorized, the EPA's portion of the RCRA
permit will remain . in effect until it expires
(August 19, 2001) or is rescinded. Therefore,
the Paducah Site still has dual requirements for
corrective actions under state and federal
authority.
Modifications to the RCRA Permit
Since issuance the KDWM Hazardous
Waste Management portion of the RCRA permit
in 1991, 15 permit modifications have been
approved. Modification 15 was approved in
1999. This major modification allows the
Paducah Site to perform treatment in containers
utilizing neutralization; oxidation/reduction,
and stabilization techniques.
RCRA Closure Activities
No RCRA closure activities occurred in
1999.
RCRA Notices of Violation
KDWM performed a compliance evaluation
inspection in September 1999. No notices of
violation (NOVs) were issued from that
inspection. However, the Paducah Site received
an NOV in September 1999 following selfreporting
of it noncompliance. T~e
noncompliance reported was the result of work .
being performed in a SWMU without approval
from KDWM. There were no fines or penalties
associated with this NOV. No other NOVs were
received during 1999.
Land Disposal Restrictions
As part of the corrective action
requirements, the RCRA permit's schedule of
cOf!lpHance requires DOE . to develop and
implement a . RCRA facility investigation (R6)
w.ork plan for 'SWMUs and areas of concern.
DOE 'hassubrilltted RFI work plans to the EPA
and the KDWM in accordance with the time
frames specified in the schedule of compliance.
These RFI work plans are described in further
detail in the section on CER:CLA activities.
,- ~
. Hazardous waste is subject to the land
disposal restriction storage prohibition which
permits storage only for. accumulation of
sufficient quantities of hazardous waste to
facilitate proper treatment, recycling, or
disposal. Hazardous wastes are not to be stored
for more than one year. The Paducah Site
generates mostly mixed waste, which is a
combination of hazardous waste and radioactive
waste. Nationally, there are very limited
opportunities for treatment and disposal of
mixed waste. Therefore, the Paducah Site stores
most of the mixed waste that is generated for
Environmental Compliance
2-3