1 - paducah environmental information center

Paducah Site
longer than one year. Storage of waste for this
purpose Oack of treatment and disposal options)
does not comply with land disposal restriction
regulations. If not for the radioactive
constituents, this waste would not pose a
compliance problem for the site, as there would
be treatment and disposal options readily
available: Consequently, on June 30, 1992,
DOE entered into an FFCA with EPA Region IV
to regulate the treatment and storage of land
disposal restriction mixed waste at the Paducah
Site. 0n April 13, 1998, EPA Region IV released
DOE from the FFCA, and allowed KDWM to
regulate mixed waste under the FFC Act.
Land Disposal Restrictions NOVs
No NOYs were received in 1999.
Site to provide a schedule for TCLP
characterization of the identified waste.
In response to the FFCA, the Paducah Site
submitted an implementation plan that
establishes a general framework for compliance
with the requirements of the FFCA. The
implementation plan establishes priorities for the
characterization program and the nature of the
data to be collected, and includes a schedule for
TCLP characterization of the identified waste.
The primary characterization objective is the
acquisition of sufficient data to safely handle the
waste and provide for determination of its status
under RCRA. Characterization of the waste with
respect to PCB and radionuclide concentrations
is the second objective. The final characterization
objective is the collection of data related to
treatment and/or disposal of the waste.
Toxicity Characteristic Leaching
Procedure FFCA
The Paducah Site has generated a
significant volume of waste materials that are
stored on-site. A large quantity of this waste was
generated; characterized, and placed in storage
before September 25, 1990. At .tha~ time,
characterization required utilizing the Extraction
Procedure for toxicity. On September 25, 1990,
a new regulation became effective replacing the
Extraction Procedure for toxicity with the
Toxicity Characteristic Leaching Procedure
(TCLP).Since the accumulated wastes had not
.been characterized under the new toxicity
characteristic regulations, DOE needed revised
, characterization .data for these wastes by the new
• protocol.
On March 26, 1992, EPA Region IV and
DOE entered into a TCLP FFCA concerning the
regulatory status of these wastes. The TCLP
FFCA requires the Paducah Site to identify those
solid wastes that are not being managed in
RCRA-regulated units and that have not been
characterized under the TCLP test method.
Additionally, the FFCA requires the Paducah
A three-phase program for accomplishing
the goals of the plan is underway. Phase I
activities consist of data compilation and waste
prioritization. Phase II involves identification of
discrete waste streams and development of
characterization plans. The final phase of the
program incl~des the development of sampling
and analysis plans, field sampling, and data
reporting.
Phases I and II of the program have been
completed. Phase III is now being carried out on
a waste stream basis. The characterization plans
developed during Phase II are used to guide the
development of the sampling and analysis plans
for the discrete waste streams. Field activities are
underway to characterize the discrete waste
streams. Characterization completion is set for
December 2000. .
TCLP FFCA NOVs
No NOYs were received during 1999.
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Environmental Compliance