GETTING IT RIGHT - ENSURING COMPLIANT WASTE GENERATION THROUGH THE USE OF ONSITE WASTE ACCEPTANCE CRITERIA

Pamela W. Edrich
Rocky Mountain Remediation Services

ABSTRACT

Rocky Mountain Remediation Services (RMRS) is the waste management subcontractor at Rocky Flats Environmental Technology Site (RFETS), accepting waste generated by all site subcontractors. RMRS is responsible for storing, treating, and disposing of all waste generated at RFETS. Over the past several decades of Site operations, a confusing assortment of waste management program plans, permits, plantwide and floor-level procedures, and operations orders have been published which control the generation and management of waste. One result of this confusion has been a high percentage of waste containers not generated in compliance with the applicable procedures, and therefore cannot be certified for offsite disposal. As more subcontractors perform work and generate waste at RFETS, the need for a formal set of Waste Acceptance Criteria (WAC) which summarize all waste generation requirements has become evident.

RMRS has developed a WAC document which concisely summarizes the documentation, content, packaging, training, and characterization requirements for the 14 primary waste types generated at RFETS. Waste generators are required to complete the new WAC Form for every containerized or uncontainerized waste that is offered to RMRS for acceptance. The WAC Form identifies general information about the waste and requests the generator to affirm that the waste complies with the requirements listed in the RMRS WAC. Once the waste is ready for transfer to RMRS, an RMRS employee reviews the WAC Form, all documentation provided, and visually evaluates the waste. RMRS then accepts the waste into RMRS custodianship.

The RMRS WAC document has only been in place for a short time, however, there have already been several positive outcomes since its implementation.

THE NEED FOR WASTE ACCEPTANCE CRITERIA

The Rocky Flats Environmental Technology Site (RFETS) recently converted from a Management and Operations (M&O) contractual arrangement to an Integrating Management Contractor (IMC)arrangement. The new IMC arrangement has resulted in a number of different subcontractor companies performing work at RFETS. Rocky Mountain Remediation Services (RMRS) is the subcontractor responsible for waste management at RFETS, accepting waste generated by all site subcontractors. RMRS is responsible for storing, treating, and disposing of all waste generated at RFETS. Under the previous M&O contract, movement of waste throughout RFETS between various groups was handled relatively casually, without the need for a formal acceptance of the waste by the onsite storage, treatment, or disposal facilities. Now that many different companies generate waste that will ultimately become the responsibility of RMRS, the need for a formal set of Waste Acceptance Criteria (WAC) has become evident.

RFETS has always had documentation that spells out the requirements for the generation, packaging, and management of waste generated at the Site. Many of the documents were originally driven by the programmatic requirements of RFETS primary offsite radioactive waste disposal facilities, the Nevada Test Site (NTS) and the Waste Isolation Pilot Plant (WIPP). Other waste generation and management requirements have resulted from RCRA regulations and safety and radiological concerns. Additional requirements have added to better control the management of waste and as corrective actions from a negative assessment of a particular waste management activity. What has resulted is a confusing assortment of program plans, permits, plantwide and floor-level procedures, and operations orders which control the management of waste. In the past there have been instances where the requirements for a container of waste may vary from storage unit to storage unit, due to the differing procedural interpretations of unit custodians.

A number of evaluations have been made of the RFETS waste generation and management system over the past few years. Each evaluation has found a high percentage of containers that were not generated in compliance with the applicable procedures. Many of these containers cannot be disposed offsite and will continue to sit in storage until the nonconformances can be corrected. Many of the evaluations recommended that the waste generation and management procedures be streamlined and that training be improved. One long-running process improvement team also recommended that the term "waste generator" be redefined so that only a small cadre of personnel having the extensive knowledge required to properly generate and package waste be designated as "waste generators".

All these issues were kept in mind during the development of the WAC. The primary focus for the WAC was to summarize all waste generation requirements and clearly define RMRS's criteria for the acceptance of waste. Other important purposes for the WAC included:

• increasing the percentage of waste generated in compliance with all procedures, permits and regulations.
• ensuring waste can ultimately be disposed at offsite facilities with little or no rework.
• allowing RMRS and the waste generating company to work together to ensure waste is compliant.
• providing RMRS the ability to "charge-back" to the waste generating company if the waste is non-compliant with the WAC.
• helping the waste generator determine what type of waste is generated and the various options for storage, treatment, and disposal.
• allowing RFETS to quickly respond to changes in offsite facilities' WAC.
• providing flexibility to the various waste generating companies concerning who within the company completes and signs the WAC paperwork.

THE STRUCTURE OF THE RMRS WAC

The WAC document consists of three major parts: a set of brief instructions, two forms (the WAC Form and the Hazardous Waste Information Form), and the Waste Type WAC for the 14 primary waste types generated at RFETS. The Waste Type WAC include all of the documentation, content, packaging, training, and characterization requirements for each waste type, in a simple to read checklist format (see Fig. 1 for an example page). Also provided in the Waste Type WAC is a reference to the detailed procedures which will explain the requirement in more detail.

Fig. 1. Example page of waste type WAC.

Choosing the correct waste type is critical to determining the appropriate requirements for the waste to be generated. A flow diagram is included in the instructions to help the generator determine the waste type. In instances where the waste may be a combination of waste types (such as asbestos-containing mixed waste), the flow diagram will direct the generator to the appropriate Waste Type WAC as a starting point. That Waste Type WAC may then refer the generator to other Waste Type WAC for a complete set of requirements.

The various waste types addressed by the RMRS WAC are outlined below.

• Radioactive or Mixed: This waste type includes low level, low level mixed, TRU, TRU mixed, residues and mixed residues.
• Non-Radioactive Hazardous: This waste type includes non-radioactive waste that is hazardous as defined by RCRA.
• Non-Radioactive Non-Hazardous: This waste type includes liquid and solid non-radioactive, non-hazardous waste that cannot be sent to the RFETS landfill or the Waste Water Treatment Plant.
• PCB-contaminated: This waste type includes all waste (solid, liquid, radioactive, non-radioactive, hazardous, non-hazardous, etc.) that is contaminated with PCBs.
• Asbestos: This waste type includes all waste (solid, liquid, radioactive, non-radioactive, hazardous, non-hazardous, etc.) that is contaminated with asbestos.
• Recyclables: This waste type includes non-radioactive recyclable material, including recycle office paper, recycle newsprint, corrugated cardboard, lead acid batteries, used oil, and wastes containing precious metals.
• Remediation Waste: This waste type includes investigatively-derived materials (IDM) and remediation waste from CERCLA investigations and remediation and RCRA Corrective Actions.
• Excess Chemicals: This waste type includes all commercial chemical products, off specification products, expired chemicals, and mixtures of chemical products which have not been used or will not be used for their intended purpose or any other purpose by their current owner.
• Unknown: This waste type includes waste for which there is no process knowledge concerning the origination, generation, or chemical composition of the waste.
• Sanitary to RFETS Landfill: This waste type includes all solid non-radioactive, non-hazardous sanitary waste that can be disposed at the RFETS sanitary landfill.
• Sanitary to WWTP: This waste type includes all liquid non-radioactive, non-hazardous waste that can be received for treatment at the RFETS Wastewater Treatment Plant (WWTP).
• Process Waste to B374: This waste type includes all liquid radioactive, mixed, and non-radioactive hazardous waste that can be received for treatment (precipitation and evaporation) at Building 374.
• Process Waste to B774 2nd Stage Precipitation: This waste type includes all liquid radioactive and mixed waste that can be received for 2nd stage precipitation at Building774.
• Process Waste to B774 Bottlebox: This waste type includes all liquid radioactive and mixed waste that can be received for treatment (solidification) at the Bottlebox in Building 774.

USE OF THE RMRS WAC

Waste generators refer to the appropriate Waste Type WAC and ensure all requirements are met during the generation of the waste. Generators are then required to complete the WAC Form for every containerized or uncontainerized waste that is offered to RMRS for acceptance. The WAC Form (provided in Figs. 2 and 3) requires general information about the waste, including the waste type, in Section A. In Sections B through E, the WAC Form requests the generator to affirm that the waste complies with the documentation, content, packaging, and training requirements listed in the Waste Type WAC. If the generator answers "no" to the questions concerning whether the waste meets the Waste Type WAC, a space is provided to explain the discrepancy.

Fig. 2. Waste acceptance criteria form.

Fig. 3. Waste acceptance criteria form.

Section F asks for certain waste characterization information. A RCRA hazardous waste determination must be made. If the waste is hazardous or mixed, an additional form, the Hazardous Waste Information Form (discussed below), must be completed. This section also provides an area to note any additional sampling and analysis that may be required before the waste can be accepted by RMRS.

If the waste has been determined to be hazardous or mixed, the waste generator must complete the Hazardous Waste Information Form. This two-page form requests RCRA information such as the EPA Hazardous Waste Numbers, treatment subcategories, and various land disposal restriction information including underlying hazardous constituents. In addition, if the waste generator can certify that the waste meets the applicable land disposal treatment standards for the EPA Hazardous Waste Numbers checked on the form, an LDR Certification statement and signature line is provided.

Finally, Section G of the WAC Form requires the waste generator's signature, verifying that all information provided is true and accurate to the best of their knowledge. Once the waste is ready for transfer to RMRS, an RMRS employee reviews the WAC form, all documentation provided, and visually evaluates the waste. RMRS will then sign in the space provided, accepting the waste into RMRS custodianship.

RMRS is the only waste management subcontractor at RFETS and is responsible for all waste storage areas, including the RCRA regulated 90-day storage areas and permitted storage areas. Because of this, RMRS must eventually accept any waste generated at the Site, whether or not it is in compliance with the WAC. Preferably, a generator will choose to fully meet all requirements specified for each waste type in the WAC. The RMRS WAC process allows a 14-day "window" of time for the generator to fully comply with the WAC. However, if the generator does not comply with the WAC, RMRS will provide the necessary expertise in characterizing, packaging, and documenting the waste to bring the waste into compliance with the Waste Type WAC. The WAC process is designed to allow RMRS to assess charges to perform this work against the generating organization. The implementation of the "charge-back" system has not yet been a priority at RFETS, but the WAC process is designed to allow for it.

SUCCESS OF THE RMRS WAC

The RMRS WAC was fully implemented in August 1996 and is required for all containers of waste now accepted by RMRS. Since the process has only been in place slightly over 2 months at the writing of this draft paper, no statistics are yet available to demonstrate there has been an improvement in the percentage of compliant waste generated. However, there have already been several positive outcomes since its implementation.

Awareness of the importance of compliant waste generation: Approximately 60 waste generators have been briefed on the new RMRS WAC and over 100 controlled copies of the WAC have been distributed. The concept of a waste acceptance criteria, new to this plantsite, has become accepted by the waste generating companies. Waste generators now realize there is a standard that must be met before they can be rid of their waste.

Allowed simplification of RCRA Permit: The Waste Analysis Plan section of the RFETS RCRA Part B Operating Permit has been greatly simplified to delete many of the specific analytical requirements for various permitted storage and treatment units. The Permit instead refers to the RMRS WAC for these requirements. When changes to analytical requirements are necessary, the WAC can be easily modified and a RCRA Permit Modification will not be required.

• Consolidation of procedures: The development of the RMRS WAC has set the stage for a procedure consolidation and streamlining effort that is currently underway.
• Formalization and standardization of RMRS waste management practices: The RMRS WAC process requires RMRS to formalize and standardize the acceptance of waste into the companys ownership. All waste accepted is reviewed against the WAC, and the requirements are the same for every receiving unit and every unit custodian.
• An easy way to disseminate new information: The WAC is relatively easy to modify, easy to read, and has a large audience. New requirements can be quickly disseminated to the waste generating organizations. As new offsite disposal options become available to RFETS, new sections of the WAC can be added if necessary.

SUMMARY AND CONCLUSIONS

The changes in RFETS management arrangement to an IMC have required that a clear set of waste acceptance requirements be prepared. The RMRS WAC document is a brief, concise statement of those requirements. The document has been implemented for only a short time and has already had a positive effect on the Sites waste generation process. It is hoped that the percentage of compliant waste that can be shipped offsite for disposal without rework will dramatically increase in the future.