Fiscal Year 2009 End-of-Year Report - ?· Fiscal Year 2009 End of Year Report ... Completed = 46 Comment:…

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  • Fiscal Year 2009 End-of-Year Report

    RCRA Performance Partnership Agreement (PPA) for the Hazardous Waste and Toxics Reduction Program, Nuclear Waste Program, and Industrial Section

    September 2009 Publication no. 09-04-033

  • Publication and Contact Information This report is available on the Department of Ecologys website at www.ecy.wa.gov/biblio/0904033.html For more information contact: Hazardous Waste and Toxics Reduction Program P.O. Box 47600 Olympia, WA 98504-7600 Phone: 360-407-6700

    Washington State Department of Ecology - www.ecy.wa.gov

    o Headquarters, Olympia 360-407-6000 o Northwest Regional Office, Bellevue 425-649-7000 o Southwest Regional Office, Olympia 360-407-6300 o Central Regional Office, Yakima 509-575-2490 o Eastern Regional Office, Spokane 509-329-3400 To ask about the availability of this document in a format for the visually impaired, call the Hazardous Waste and Toxics Reduction Program at 360-407-6700. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

  • Fiscal Year 2009 End of Year Report

    RCRA Performance Partnership Agreement

    for the Hazardous Waste and Toxics Reduction Program, Nuclear Waste Program, and Industrial Section

    Washington State Department of Ecology Olympia, Washington

  • This page is purposely left blank

  • Table of Contents Hazardous Waste and Toxics Reduction Program ........................................... 1 Pollution Prevention and Regulatory Assistance Section Permits Group ....................... 1 Central Regional Office ............................................................................................................ 2 Inspections ...................................................................................................................................................2 Permitting .....................................................................................................................................................3 Corrective Action .........................................................................................................................................4 Eastern Regional Office ........................................................................................................... 5 Inspections ...................................................................................................................................................5 Southwest Regional Office ...................................................................................................... 6 Inspections ...................................................................................................................................................6 Permit Modifications and Renewals ............................................................................................................7 Closure Plan Reviews ..................................................................................................................................7 Post-Closure Plan Reviews ..........................................................................................................................7 Permitting, Closure, Post-closure and Corrective Action Work ..................................................................7 Northwest Regional Office ..................................................................................................... 12 Inspections .................................................................................................................................................12 Permitting, Closure, Post-closure and Corrective Action Work ................................................................13 Nuclear Waste Program .................................................................................... 18 Inspections .................................................................................................................................................18 Inspection Detail ........................................................................................................................................18 Permitting, Closure, Post-Closure ..............................................................................................................19 Industrial Section ............................................................................................... 20 Inspections .................................................................................................................................................20 Permits .......................................................................................................................................................21 Closure/Post Closure ..................................................................................................................................21 Corrective Action .......................................................................................................................................21 Appendix ........................................................................................................... 23 RCRA Enforcement Data for Fiscal Year 2009 ........................................................................................23

  • 1

    HWTR Pollution Prevention and Regulatory Assistance (P2RA) Section Permits Group

    Philip Services (now Burlington Environmental LLC) Tacoma Assisted Southwest Regional Office (SWRO) on one permit modification request. Granted a six-month extension for the permit renewal application. Received the permit renewal application in May 2009. Began work on the completeness review. Met with Ecologys Solid Waste Program and Tacoma Pierce County Health Department and discussed the solid waste permitting options. Philip Services (now Burlington Environmental LLC) Kent Assisted Northwest Regional Office (NWRO) on one compliance report. Completed two permit modifications. Received the permit renewal application in August 2008. Conducted the completeness review and began detailed review of the application. We are working with the facility to modify and complete the application. Conducted one site inspection to review the stormwater collection system. Emerald Services, Inc. Assisted SWRO on one compliance inspection, one compliance report and one permit modification. Performing a detailed review of the permit application and working with the facility to modify and complete it with public notice expected in December 2009. US Navy, Keyport Assisted NWRO on a compliance inspection and provided input on the resulting compliance report. Completed a permit modification request. Bonneville Power Administration (BPA) Ross Complex Assisted SWRO on one compliance inspection and provided input on the resulting compliance report. Bay Zinc Worked with Central Regional Office (CRO) and drafted an options paper outlining the operating permit renewal and the corrective action permit pathways. Performed one site visit to discuss the options with Bay Zinc. Standard Permit Conditions Worked with the Environmental Protection Agency (EPA) and ORC to develop and complete standard conditions for HWTR dangerous waste management permits. Univar Kent Provided public notice on the draft CAP and Agreed Order. Reichhold/SSA Container Facility Provided public notice on the proposed cleanup action plan, consent decree, and modified DW permit to fulfill corrective action. PSC/Georgetown Provided public notice on an update to the community and public officials regarding the status of monitoring, sampling, and beginning preparation of draft cleanup action plan.

  • 2

    GE/Dawson Street Provided public notice on the Agreed Order re-draft cleanup action plan and SEPA documents. Fort Lewis Provided public notice on the cleanup action plan and SEPA checklist. HWTR Central Regional Office Inspections

    Mandated Treatment, Storage and Disposal (TSD) inspections

    Commitment = 1 Completed = 1

    Comment: A Compliance Enforcement Inspection (CEI) was completed at Bay Zinc in September

    2008. Bay Zinc is not operating as a TSD and generates waste as a Conditionally-exempt Small Quantity Generator (CESQG). The Washington State Department of Ecology (Ecology) has been at Bay Zinc observing corrective action activities.

    LQG CEIs

    Commitment = 5 Completed = 5

    Comment:

    State Priority visits

    Commitment = 30 Completed = 26

    Comment: 26 evaluations at non Large Quantity Generator (LQG), notified sites

    0 LQG Follow-up Compliance Inspections (FCI) 11 MQG CEIs 5 CESQG CEIs 2 XQG (generators with an active ID number that report they are not generating waste) CEIs 0 MQG FCIs 2 CESQG Compliance Assistance visits (CAVs) 3 XQG CAV 1 CESGQ FCI 1 CESQG Compliance Schedule evaluation (CSE) 1 CESQG SNN (facilities that no longer show significant non-compliance)

  • 3

    New Notifier (NN) visits

    Commitment = 0 Completed = 0

    Comment:

    Increased Generator Contact (IGC) visits in CRO:

    Commitment = 0 Completed = 30 auto recyclers/mercury switch campaign

    Comment: Commitment met

    Delinquent Annual Report (DAR) visits

    Commitment = 0 Completed = 0

    Comment: Although no site visits were conducted, delinquent reporters were contacted by telephone.

    Other state site visits

    Commitment = 0 Completed = 0

    Comment:

    Inspection Summary - CRO site visits:

    Commitment = 36 Completed = 31 Resource Conservation and Recovery Act (RCRA) notified (TSD, LQG and state priority) 30 Auto recycler visits in CRO 85 Auto recycler visits in other regions 40 Complaint response actions _____________________________________________________ Total = 222 site visits

    Permitting

    Yakima Training Center (YTC):

    Closure has been completed for the Open Burn/Open Detonation (OB/OD) unit (the only permitted unit at YTC). However, the permit cannot be terminated until corrective action is complete for the entire facility. It is anticipated the facility will implement a RCRA corrective action-only permit in 2009.

  • 4

    Kronos Micronutrients (formerly Bay Zinc): Kronos current dangerous waste permit has expired.

    Although Kronos is not conducting RCRA regulated activities at this time, the permit cannot be terminated because groundwater contamination is present.

    Ecology and Kronos have been discussing the option of renewing the permit (for potentially anticipated waste feedstock) or closing the unit and implementing a corrective action only permit.

    This facility has approved controls in place for the Government Performance and Results Act (GPRA) operating permit baseline.

    Cameron Yakima, Inc: No change in site status from last year.

    Memo sent to CRO Central Files stating that site is closed, permit denied, etc. Data entry has not yet been done to reflect this.

    This facility has approved controls in place for the GPRA post-closure baseline.

    Corrective Action

    Yakima Training Center: The Army has completed investigation and voluntary cleanup at all but one site at this 324,000 acre

    facility. A RCRA Corrective Action Completion Report has been submitted. This report is a summary of historical record review, investigation, and cleanup actions at every potentially contaminated site (115) identified in the 1993 RCRA Facility Assessment report.

    The Land Use Control Plan describing future management protocols for eight sites needing institutional controls has been finalized and accepted by Ecology.

    Groundwater sampling continues for two contamination plumes.

    A multi-phased investigation of the May 2008 fuel spill at the POL facility revealed soil contamination beneath the concrete fueling pad. The monitoring well installed nearby has not contained water, but continues to be checked periodically. The Army will likely propose institutional controls to manage the contaminated soil in place.

    During 2007-2008 five sites underwent historical record review, site investigation work plan development, sampling and reporting. No further action has been requested for these sites and cleanup is considered complete.

    The Human Exposure environmental indicator (EI) determination was completed in 2009.

    The Groundwater Migration Under Control environmental indicator determination was completed in 2009.

  • 5

    Bay Zinc: Institutional controls have been implemented. The site continues to conduct long term groundwater

    monitoring.

    The Human Exposure environmental indicator determination is complete.

    The Groundwater Migration Under Control environmental indicator determination is complete.

    Cameron Yakima, Inc. No change from last year.

    The Human Exposure EI determination remains current.

    The Groundwater Migration is Controlled EI determination remains current. HWTR Eastern Regional Office

    Inspections

    LQG CEIs: Commitment = 5 Completed = 12

    State Discretionary/State Priority visits: Commitment = 12 Completed = 52

    Comment: Completed visits includes - 9 Medium Quantity Generators (MQG) CEIs, 12 CESQG CEIs, 4 CAVs, 3 Case Development Inspections (CDI)s, 6 Follow-up Inspections (FUI)s, 1 FCI); and 17 complaint site visits

    Increased Generator Contact visits: Commitment = 60 Completed = 46 Comment: The IGC visits completed this fiscal year included visits to several veterinary clinics.

    Delinquent Annual Report visits: Commitment = 0 Completed = 0

  • 6

    HWTR Southwest Regional Office The following is a brief summary of the exceptions to the negotiated PPA workload, and the enforcement actions that occurred in FY 2009. Work that was completed as targeted was not discussed. Enforcement and other additional items not referenced in the PPA are added as appropriate. Inspections

    TSD Inspections 10/28/08 BPA Ross

    Commitment = 3 3/16/09 BPA Ross Completed = 3 4/16/09 Emerald Services

    We committed to inspect Burlington Environmental/PSC-Tacoma, however the lead inspector for that facility has been serving as Acting Unit Supervisor since February 2, 2009. In addition to those extra duties, the lead inspector was involved in a settlement negotiation that included the PSC-Tacoma facility during the February to June 2009 time period. Resource limitations didnt allow for an inspection. LQG CEIs Commitment = 25 Completed = 31

    Increased Generator Contacts Commitment = 30 Completed = 189

    State Priority Inspections (SPIs) Commitment = 40 Completed = 32

    Delinquent Annual Reporter Visits Commitment = 10 Completed = 0

    New Notifier Visits Commitment = 20 Completed = 7

    Other State Site Visits Commitment = 0 Completed = 39

    Delinquent Annual Reporter Visits Commitment = 10 Completed = 0

    Total State Discretionary Facility Site Visits Commitment = 100 Completed...

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