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R. Michael Turnipseed, Director Allen Biaggi, Administrator (775) 687-4670 TDD 687-4678
Administration |
STATE OF NEVADA KENNY C. GUINN Governor 
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Waste Management Corrective Actions Federal Facilities Facsimile 687-6396
Air Quality |
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Division of Environmental Protection 333 W. Nye Lane, Room 138 Carson City, Nevada 89706-0851 |
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Jhon Carilli, RCRA Program Manager Waste Management Division U.S. Department of Energy Nevada Operations Office P.O. Box 98518 Las Vegas, NV 89193-8518 Subject: Part B Permit Application for a Mixed Waste Disposal Unit Dear Mr. Carilli: The Nevada Division of Environmental Protection (NDEP), Bureau of Federal Facilities, has reviewed the subject Application. The following comments have been generated after an initial review of the Application. The Department of Energy, Nevada Operations Office (DOE/NV) needs to address these comments in order for the NDEP to finish it's review of the Application. 1. Section P.2.a, Second Paragraph: How is the unit, Pit 3 Mixed Waste Disposal Unit (MWDU), subject to Department of Transportation (DOT) standards? 2. Section P.2.b.1.a, Land Use: The DOE/NV did not mention the historic disposal of other mixed wastes within the Area 5 Radioactive Waste Management Site (RWMS). 3. Section P.2.c.3, Waste Verification There is no mention of the process from which wastes will be generated. Specifically, a permitted RCRA process, or a CERCLA process. This is important for determining the level of verification and sampling which will be required for any waste received at the MWDU. This is especially important for wastes which have been asserted to meet the Land Disposal Restriction (LDR) requirements at the point of generation. Reliance on process knowledge from DOE generators has not been overly reliable over the past few years, and will not be deemed acceptable on its own in order to support a waste determination. 4. Section P.2.d.3.e, Lab Packs: The acceptance of Lab Packs would appear to be precluded under the requirements of Section P.2.c.2 5. Section P.2.d.7, Leachate Management System: The DOE/NV continues to make reference to the fact that neutron logging data demonstrating that "the operation cover dries out without changing water contents in or below the waste zone." However, the NDEP has never received the data which supports this assertion. The DOE/NV must either supply this data, or remove this assertion from the application. The DOE/NV makes reference to the fact that the only leachate which would be generated is the rainwater which falls directly on the exposed waste packages, and subsequently runs off into the pit. The application is silent on how this leachate will be managed. 6. Section P.2.e, Groundwater Monitoring Plan: The purpose of the reports listed in the first paragraph are to document the condition of the upper aquifer and demonstrate the RWMS activities have not impacted ground water quality, not to provide a detailed groundwater monitoring program for the area 5 RWMS. In fact, these wells were not originally installed as monitoring wells, but as pilot wells. 7. Section P.2.e, Groundwater Monitoring Plan: The NDEP does not have enough information to consider the three wells as sufficient to meet the groundwater monitoring program for an active, permitted unit. The DOE/NV needs to present more information to support an overall groundwater monitoring/release detection program for the MWDU. The plan should address the issues in accordance with those found in 40 CFR 264.90(b)(2). The DOE/NV will not be granted a waiver from groundwater monitoring, however, since the three wells do not meet the strict definition of a monitoring system under 40 CFR 264.92, an integrated approach to ensuring that the groundwater will not be impacted by the MWDU must be presented. 8. Exhibit P.2.g-1, Section 6.2: The contact information is covered with multiple hand-written corrections and cross-outs, without any signature or initials. The NDEP is requiring the official copy of this section, with the signature of the person authorized to issue the emergency contact information. 9. Section P.2.i, Closure Plan: The DOE/NV needs to specify the usage of the remaining unused portion of the pit, beyond the 20,000 m3 volume specified in the permit application. The closure plan needs to cover closure of the entire unit, regardless of the disposal of wastes which are not RCRA hazardous. Since the unit cannot be closed until completely filled, the closure plan needs to specify all waste forms to be disposed and an estimation of the time final closure will be achieved. Any questions may be directed to Matthew A. DeBurle, of my staff, at (775) 687-4670, extension 3031.
PJL/KKB/MAD/ cc: M. McKinnon, NDEP/LV T. Zaferatos, NDEP/LV E. Di Sanza, DOE/WMD P. Tilman, DOE/WMD P. Matthews, BN B. Loux, NWPO  Federal Facilities Home PageSite Map NDEP Home Page |
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