RCRA PART B PERMIT MODIFICATIONS FOR COST SAVINGS AND INCREASED FLEXIBILITY AT ROCKY FLATS ENVIRONMENTAL TECHNOLOGY SITE

Candice C. Jierree
Rocky Mountain Remediation Services

Kirk Ticknor
ICF Kaiser, Inc.

ABSTRACT

With shrinking budgets and downsizing, a need for streamlined compliance initiatives became evident at the Rocky Flats Environmental Technology Site (RFETS). Therefore, Rocky Mountain Remediation Services (RMRS), part of the Kaiser-Hill team at RFETS, successfully modified the Rocky Flats RCRA Part B Permit to obtain significant cost savings and increased flexibility.

This was done by requesting operations personnel to suggest changes to the Part B Permit which would be cost beneficial. The team subsequently obtained approval for those changes from the Colorado Department of Public Health and the Environment (CDPHE).

BACKGROUND

In the fall of 1995, the RFETS received significant reductions in the amount of funding available for hazardous waste management and RCRA compliance. Hundreds of personnel left the RFETS; however, the compliance workload did not decrease. In fact, more waste was expected to be generated because of plans to accelerate decontamination and decommissioning. As a result of the funding and personnel reductions, RMRS began to seek ways to obtain streamlined compliance and relief from unnecessary requirements.

OBTAINING THE CHANGES

The RMRS permitting organization requested operations personnel to identify requirements in the RCRA Part B Permit which seemed unnecessarily burdensome. A request for written input was sent to affected personnel. Recognizing that some operations personnel were overloaded with day-to-day compliance responsibilities, RMRS permitting personnel also visited personnel at their work stations and took verbal suggestions for change along with the proposed alternative compliance action.

A variety of changes were identified through the survey process. The following are specific examples of those changes and estimates of resultant cost savings for the RFETS:

1. In areas where all the containers held the same type of waste, it was suggested that a single label be posted at the entrance to the area to identify hazardous waste containers. In addition, operations personnel proposed to maintain specific information such as EPA waste codes in the RFETS' waste database system rather than on labels as they deteriorated or as waste characterizations were refined. It was estimated that $2,000,000 per year in costs could be avoided with this change.
2. Operations personnel requested an option for adding absorbent or compacting waste within a storage unit to avoid shipment to other areas at the site for this type of treatment. This resulted in a reduced volume of waste to be managed within a treatment unit. It was estimated that $50,000 per year in costs could be avoided from this change.
3. Operations personnel requested use of fingerprint testing for waste characterization in the field rather than requiring the tests to be performed in a laboratory. It was estimated that approximately $1,000,000 per year in costs could be avoided from transportation and laboratory analysis.
4. Several changes were proposed to allow more flexibility to store different waste types within the existing storage units at the RFETS. For example, liquid storage was requested in areas which were previously allowed solid storage only. RMRS also requested approval to store low-level and transuranic (TRU) mixed waste in areas which were previously allowed to store only one of these waste types. This increased flexibility would result in a reduced need to construct new facilities to store waste generated from decontamination and decommissioning. Each new facility could cost approximately $1,000,000.

Twenty-five cost savings permit modifications were proposed in a single request for modification. The full list of modification requested is attached to this paper along with the justification for the request, and the response from the CDPHE.

The proposed changes were transmitted in draft form to CDPHE for initial feedback and negotiations. Not all of the changes were initially accepted. A series of meetings were conducted and operations personnel were invited to help defend some of the proposals. This greatly facilitated negotiations since both parties were able to hear concerns "straight from the horse's mouth." As a result of the negotiations, and the concerns of CDPHE, some proposals were modified.

Using this cooperative process, temporary approval was obtained within weeks of the official request, and final approval was obtained for all negotiated permit modifications.

FUTURE ACTIONS

RFETS has recently completed a re-application for its RCRA Permit. The same technique discussed above was used to help obtain a greatly streamlined permit application. This should result in even greater flexibility in the permit to support the RFETS' clean-up mission in light of shrinking budgets.

RECOMMENDATIONS

Based on our experience at the RFETS, RMRS recommends that RCRA permit holders should not be hesitant to propose reasonable alternatives to high cost compliance activities. Although there is no guarantee of success, any permit modification which is sensible, in compliance with established law, and which saves company funds (and, in the case of government facilities, tax dollars) is a worthwhile endeavor.

A'TTACHMENT TO
RCRA PART B PERMIT MODIFICATIONS
FOR COST SAVINGS AND INCREASED FLEXIBILITY
AT ROCKY FLATS ENVIRONMENTAL TECHNOLOGY SITE

Class 2 Permit Modification Request
List of Requested Changes 1)

1. Proposed Change: Remove the requirement for the identification of EPA hazardous waste codes on hazardous waste labels in the first paragraph of Part III,B.8 of the Permit.
   
   Justification: Pursuant to the CHWR, Part 262, EPA waste codes are not required on hazardous waste labels. The removal of this requirement will alleviate the need to re-label waste containers when characterizations affecting waste codes change or deterioration of the labels occurs and will reduce exposure to employees having to re- label radioactive mixed waste containers. Container characterizations and compatibilities continue to be easily verified using the operating records and container locator systems required by the Permit. In addition, compatibility codes and accumulation start dates will continue to be kept on the hazardous waste labels.

2. Proposed Change: Remove the requirement from Part III.B.15.b for individual inspection logs for each cargo container within a unit.
   
   Justification:The CHWR contain no requirement that separate inspection logs be maintained for individual units. Approval of this modification will eliminate individual inspection logs for each cargo container so that only one log will be needed for a unit, allowing for more efficient operation of the unit by eliminating unnecessary paperwork. For example, 280 signatures per month are obtained on inspection logs for Unit 15A alone. The removal of this requirement from the Permit will not diminish the safe status of the wastes stored at the permitted units consisting of multiple cargo containers. Each unit will continue to be inspected appropriately and problems or deficiencies will be noted on a single inspection log.

3. Proposed Change: Add the following to the Unit Specific Conditions to Units I and 15A to allow addition of absorbent and manual compaction of certain wastes:
   
   "Addition of liquid absorbent such as "Oil Dry" to solid wastes containing liquids is allowed in this unit. Waste allowed for this treatment would be those allowed in this unit. Addition of absorbent will be done manually. Precautions will be taken to ensure no releases occur during this activity.
   
   Crushing of fluorescent bulbs and manual compaction of soft waste is also allowed in this unit.
   
   A "Dextrite tube crusher or similar equipment will be used for crushing bulbs. Compaction of soft waste will only be done manually (e.g., by rearranging waste or by applying hand force). Waste allowed for this treatment will be those wastes allowed in the unit. Precautions will be taken to ensure no releases occur during this activity.
   
   For flourescent bulbs, reverification of waste characterization will be performed annually. This will be done by process knowledge unless there is reason to believe that the manufacturing process has changed. If manufacturing process has changed, the reverification will include sampling and analysis of a minimum of five samples, taken from diverse sources. The waste will be sampled in accordance with the Colorado Hazardous Waste Regulations and SW-846 methods for TCLP extraction and cold vapor atomic absorption for mercury."
   
   Justification: This change allows for-compaction and addition of absorbent to waste currently in storage at the Site. These practices will result in safer and more efficient storage and disposal of those wastes.

4. Proposed Change: Add waste code D030 (2,4-dinitrotoluene) to the approved waste codes in the Unit Specific Conditions for Unit 1 in Part III.
   
   Justification: Recently identified generation of D030 waste by the on-site laboratories has created the need to store D030 waste. The D030 waste is generated when laboratory standards which contain 2,4-dinitrotoluene are no longer needed. Once deemed waste, the 2,4-dinitrotoluene must be stored as a RCRA-regulated material in permitted storage facilities at the Site while awaiting disposal. Permitted storage is necessary because disposal capabilities for this waste are being developed but are not yet available.

5. Proposed Change: Add "Hazardous waste in gas cylinders and lecture bottles" to the waste description in the Unit Specific Conditions for Unit 1 in Part III. In addition, add "and 50 m³ of gas @ STP" to the maximum capacity for this unit.
   
   Justification: With the pending closure of Unit 23, which was identified for the storage of waste gas bottles, the Site will have no capacity to store this waste form at any of the permitted units. Specifically, gas storage capability is needed to store organo-metallic gases prior to their off-site disposal. Permitted storage is necessary because it may require more than 90 days to procure disposal options for certain gases.

6. Proposed Chanqe: Add "solid" to the waste description for Unit 10 in the Unit Specific Conditions for Unit 10 in Part III.
   
   Justification: This addition will allow storage of solid low-level mixed waste in Unit 10. Specifically, some solid low-level mixed waste currently stored in buildings to be decommissioned will be moved to Unit 10, alleviating the need for new storage units.
7. Proposed Change: Add transuranic mixed (TRM) waste to the waste description in the Unit Specific Conditions for Unit 14 in Part III.
   
   Justification: This addition will allow some of the TRM currently stored in buildings scheduled to be decommissioned to be moved to .Unit 14, eliminating the need for short-term TRM storage elsewhere on site until a new storage facility is built. Storage of TRM waste will be limited to a maximum quantity of radioactive material allowed in Unit 14 based on the design of the building and credible accident scenarios.8)

8. Proposed Change: Alter current waste container stacking description to allow four-high stacking of drums and three-high stacking of full-size crates in the Unit Specific Conditions for Unit 14 in Part III. In addition, delete the overall stacking height limitation of 11' 6" for this unit.
   
   Justification: The CHWR do not define container stacking requirements. The additional stacking request allows for more complete and efficient use of the. permitted capacity of Unit 14, eliminating the need for short-term TRM storage elsewhere on site until a new storage facility is built.

9. Proposed Change: Add a liquid storage capacity of 5,500 gallons in the Unit Specific Conditions for Unit 14 in Part III. To reflect this change, add catch basins as an allowable type of secondary containment.
   
   Justification: This change allows storage of liquid wastes in Unit 14. Specifically, this change will allow those wastes to be staged for off-site treatment and disposal because the buildings that currently store those wastes do not have adequate docks for off-site shipment.
   
   Secondary containment for liquids will be provided by catch basins with sufficient capacity to contain the volume of identified liquids placed within them. The requirements of §264.175(b)(3) of the CHWR are satisfied because the secondary containment will hold 100% of the liquids. Incompatible liquids will be located in separate catch basins as required by the Permit. --'

10. Proposed Change: Increase the maximum capacity for liquid storage from 15,765 gallons to 71,565 gallons in the Unit Specific Conditions for Unit 15A in Part III.
    
    Justification: Unit 15A includes cargo containers that have a maximum capacity of 71,565 gallons. These cargo containers have sufficient secondary containment for that maximum capacity. The requested change allows Unit 15A to store any combination of liquids and solids in the cargo containers and is needed to allow consolidated storage of drums that contain incidental amounts of liquid.

11. Proposed Change: Add the following unit specific condition to Units 15B, 24 and 25 in Part III. "The Permittee may post a single hazardous waste label for each type of hazardous waste at each entrance to the areas that store hazardous waste in this unit. In addition, a list of containers which correspond to each label will be placed in a nearby location to assist personnel in identifying hazards associated with each container in the unit. Whenever a container is removed from the unit for off-site shipment, a hazardous waste label containing the required information pursuant to Part 262 of the CHWR will be affixed to the container. Before transporting, each container will be labeled in accordance with U. S. Department of Transportation regulations."
    
    Justification: This posting of labels at entrances to storage areas will minimize management and maintenance costs associated with the current labeling practices in the saltcrete, pondcrete, and sludge storage units (i.e., Units 15B, 24, and 25). This change will reduce the radiation exposure to employees who change the deteriorated labels on containers. Effective management of wastes stored in these units will not be impacted by this change since 1) the containers of hazardous waste will be clearly identified to personnel at each entrance to areas storing hazardous waste, 2) all waste containers (whether hazardous or nonhazardous) within the unit must be managed in accordance with the requirements of the permit, 3) most of the containers within these units have the same characteristics, and 4) container characterizations and compatibilities can be easily verified using the operating records and container Locator systems required by the Permit.

12. Proposed Change: Add low-level mixed (LLM) waste to the waste description in the Unit Specific Conditions for Unit 63 in Part III. To reflect this request, change the current waste description for Unit 63 to read "Mixed Waste and Residue."
    
    Justification: Allowing LLM waste to be stored in Unit 63 increases flexibility to store LLM and thus reduces employee radiation exposure caused by movement of waste containers to other storage units. Unit 63 is needed to store LLM waste generated from maintenance and solution processing in. Building 371 and is the most efficient area to store this waste because it is the only area in Building 371 where these containers can be stacked.

13. Proposed Chanqe: Add the following unit specific condition for Unit 90.58 in Part II1: "The boundary of Unit 90.58 includes two areas in Module A of Building 707 for container staging. The staging areas in Module A will be located in the C-Cell or indicated by a roped area or painted boundary on the floor. In the staging area, containers must comply with the permit conditions for Unit 90.58 except that secondary containment is not necessary for solid wastes. Containers may be staged in Module A for a period not to exceed 30 calendar days after suspension of sampling activities."
    
    Justification: This change allows staging of mixed residue drums near their planned sampling location in Module A. Staging near the sampling location reduces the amount of drum handling and concomitant radiation exposure during sampling activities. A drawing showing the proposed staging locations is included as an attachment to this Permit Modification.

14. Proposed Chanqe: Remove Condition #1 from the Unit Specific Conditions for Unit 90.23 in Part Ill, which requires waste to be compatible with the liquids stored in the tanks in this unit.
    
    Justification: The need to store caustic liquid wastes in Unit 90.23 prior to final treatment is created by the draining of tanks in Building 771. Although the caustic wastes from tank draining are not compatible with liquids in the tanks in Unit 90.23, §264.177 of the CHWR allows storage of incompatible wastes as long as they are physically separated by a wall, berm, catch basin, etc. To minimize potential problems in the event of a leak, catch basins or berms will be used to separate incompatible wastes. In addition, caustic wastes will not be stored adjacent to the tanks nor under any acid-containing piping associated with the tanks.

15. Proposed Change: Add LLM waste to the waste description in the Unit Specific Conditions for Unit 90.23 in Part III of the Permit. To reflect this request, change the current waste description for Unit 90.23 to read "Mixed Waste and Residue".
    
    Justification: This addition increases flexibility to store LLM and thus reduces employee radiation exposure caused by movement of waste containers to other storage units. With this change, LLM liquid wastes generated from the processing of liquid mixed residues in Building 771 will be stored in Unit 90.23 prior to being transferred for further processing in other buildings.

16. Proposed Change: Replace the requirement to remove each container from its storage bin during weekly inspections in the Unit Specific Conditions for Unit 90.117 in Part III with the following: "The containers stored in Glovebox A31 will not be physically removed from their storage bins during routine inspections of this glovebox. Instead, containers will be inspected during nuclear material accountability inspections in accordance with the Nuclear Materials Safeguards Procedure Manual. The Director will be notified of any changes to the inspection frequencies specified in that procedure for this unit."
    
    Justification: Unit 90.117 is a glovebox which is designed and operated to prevent release of materials and to reduce radiation exposure to personnel. Any release within the glovebox would present no danger to human health or the environment because it would be contained and isolated until discovered. This change does not alter the Permit requirement to inspect the glovebox each week, thereby maintaining compliance with §264.174 of the CHWR for inspections.
    
    Containers within the storage bins will be inspected during regularly scheduled nuclear material accountability inspections to detect trends in container deterioration. Changes to NMA inspection criteria are carefully controlled (i.e., changes must comply with DOE orders for ensuring a high confidence of material accountability and are approved by Site Accountability Managers and DOE prior to implementation). In addition, this change will decrease radiation exposure to the inspectors and reduces the possibility of spilling container contents during inspections.

17. Proposed Change: Remove the requirement to open each bin door during weekly inspections in the Unit Specific Conditions for Unit 90.43 in Part Ill. Instead, replace this requirement with the following: "The door to each storage bin will not be opened during routine inspections of this glovebox. Instead, containers will be inspected during nuclear material accountability inspections in accordance with the Nuclear Materials Safeguards Procedure Manual. The Director will be notified of any changes to the inspection frequencies specified in that procedure for this unit."
    
    Justification: Similar to the justification for requested change #16 above. In addition, only solid material is stored in this unit; therefore, the possibility of releases from the containers in this unit is very unlikely.

18. Proposed Chanqe: On the drawing for Unit 90.43 in Part III, remove the last sentence from Note #2 and delete "a closed door with" from Note #3.
    
    Justification: The notes are in error .since there is a single door on the bins, and the door separating this portion of the glovebox from the .rest of the glovebox is typically kept open to maintain proper airflow within the glovebox system. The requested changes to the notes on the drawing will have no adverse impacts on the storage of the waste in this unit.

19. Proposed Change: Add the following unit specific condition to Unit 11 in Part II1: "Some solid containers in this unit may also contain liquid material. For those containers, catch basins will be used for secondary containment. In lieu of calculations based on 100% of the total volume of the containers, the minimum berm height for those catch basins will be based on the volume of the identified liquid stored within the containers to be placed inside the catch basins."
    
    Justification: Containers storing liquid are currently assumed to contain 100% liquid for purposes of secondary containment calculations. Criticality safety requirements limit the berm height on catch pans to 2 inches in Unit 11. If each container is assumed to contain 100% liquid and the catch basin berm height is limited to 2 inches, the catch basins in Unit 11 must be designed with a larger surface area in order to provide containment. These larger catch basins take up more floor space, reduce the storage capacity in Unit 11 unnecessarily, and will result in greater surface area being contaminated in the event of a spill. Therefore, when the volume of liquid in a container is known, the Site may elect to use only the identified volume of liquid in determining the amount of required containment capacity. The proposed change will provide containment for 100% of the identified liquids in containers.

20. Proposed Change: In the Unit Specific Conditions in Part III of the permit for Units 90.2, 90.65, 90.70, 90.72, 90.83, 90.86, and 90.96, change the container inspection in certain mixed residue vaults to be consistent with the nuclear material accountability (NMA) inspections. In addition, replace the first three sentences in Part V.B.2.e, paragraph 5 to reflect this change as follows: "In addition, personnel shall perform container. inspections in vault storage areas during nuclear material accountability inspections in accordance with the Nuclear Materials Safeguards Procedure Manual. The Director will be notified of any changes to the inspection frequencies specified in that procedure for the vaults in this Permit. Container condition will be assessed and documented in the operating record at that time. A typical logsheet for listing of container IDs during the NMA inspection is presented in Table 5," Also, replace the requirement for annual container inspection with a requirement for NMA inspection on the inspection logsheet for vaults in Part V (Table 3).
    
    Justification: This modification allows reduction in personnel radiation exposure by requiring employees to conduct inspections of containers only during NMA inspections. The NMA inspection criteria are based on nuclear worker safety and the amount of movements of nuclear materials from their current storage locations, and are subject to change to protect workers. The requested change will make the RCRA inspection criteria consistent with the NMA inspection criteria, thereby ensuring worker safety. Changes to NMA inspection criteria are carefully controlled (i.e., changes must comply with DOE orders for ensuring a high confidence of material accountability and are approved by Site Accountability Managers and DOE prior to implementation). In addition, this request will help reduce the possibility of spills due to material handling.
    
    Inspections conducted in conjunction with NMA inspections will identify any potential container, deterioration as well as any trends in container deterioration. In addition, Selective Alpha Air Monitors (SAAMs) located in the vaults are capable of detecting releases that might occur between the NMA mandated inspections. The SAAMs are checked on a weekly basis. Thus, the proposed inspections described above complies with §264.174 requirements for inspections.

21. Proposed Change: Delete the reference to Site Laboratory Procedure 6220 from Table 6 (Fingerprint Analysis Methods) in Part IV.
    
    Justification: This change allows fingerprint analyses to be conducted in the field. Personnel conducting field verifications will be adequately trained to perform the field verifications, which are very similar to the verifications performed in the laboratory. The generic methods specified for Part IV of the permit are currently sufficient to ensure adequate fingerprint analyses.

22. Proposed Change: In the third paragraph of Part V.B.5, change the first three sentences to -read: "Emergency power generators, if used as emergency back-up power supplies, are tested per industry standards such as IEEE or NFPA to ensure proper operation. Documentation of the setests is kept on file at the Site."
    
    Justification: The proposed change allows emergency generator testing' to be conducted in accordance with industry standards instead of monthly. Changes to the emergency generator test frequencies are carefully controlled. For example, changes in the test frequencies require an engineering evaluation (e.g., nuclear safety analysis and comparison to industry standards) and DOE approval prior to implementation.

23. Proposed Change: Add the following to the seventh paragraph of Part V.D.I: "Temporary staging of containers within the units may occur for such activities as shipment (incoming or outgoing), rearrangement to allow for non-routine maintenance, venting, and sampling. During this time, containers may not conform to the standard arrangement specified in Part III of the Permit. (Instead, containers may be grouped together in arrays of up to four containers wide and twenty containers long.) Staging shall not exceed 15 calendar days, and at least 26 inches aisle space will be maintained around container groups. Each container group will be marked with sign indicating the date the staging began and that the area is for staging."
    
    Justification: This change is consistent with the existing Permit requirements (e.g., Part III.B.15) and allows for more efficient staging of containers for movement, venting, and sampling which will result in decreased radiation exposure to personnel. While the ease of container movement within units will be temporarily interrupted during staging, the aisle space requirements of §264.35 of the CHWR will continue to be met. The proposed 15 calendar days to be allowed for staging is consistent with the amount of time allowed for staging areas in Part 111.B.15.c of the Permit.

24. Proposed Change: Replace Paragraphs 6 through 9 in Part X.A with the following:
    

    "6. Waste Minimization Program Plan
    	a.	The written Waste Minimization Program Plan is incorporated into this permit by reference.
    	b.	Revisions to the Waste Minimization Program Plan will be submitted annually to the Director by October 30. The revision will include a report of annual progress as follows:
    		i.	Include detail regarding achievements in waste minimization by the facility, including: percentage reduction, and actual volumetric or mass reduction, for each major RCRA regulated waste stream using the previous year as a baseline, and through what means these were achieved (i.e., treatment, source reduction, product substitution, other).
    		ii.	Where specific reduction goals have not been met, provide the Director with an explanation of the circumstances preventing achievement, and a strategy to achieve these goals in the next year."

    
    Justification: This change allows for the annual Waste Minimization Progress Report to be combined with the Annual Update to the Waste Minimization Program-Plan, which is submitted each year in October. This eliminates unnecessary paperwork and duplication of efforts in submittal of those reports. --

25. Proposed Change: Add the following general condition to Part II1: "Compaction and addition of absorbent is allowed within the units in this Permit. If not specifically approved in the Unit Specific Conditions of this Permit, these activities will be conducted in accordance with Standard Operating Procedures that will be approved by the Director. The Director will be notified of any changes to the Standard Operating Procedures,'
    
    Justification: This change allows for compaction and addition of absorbent to waste currently in storage at the Site. These practices will result in safer and more efficient storage and disposal of those wastes.