RCRA permitting strategies for innovative technologies demonstrations
J.F. Donaghue, S.W. Gajewski
Abstract
J.F. Donaghue, S.W. Gajewski
Abstract
The Department of Energy (DOE) Hanford Site`s huge waste inventory and environmental contamination are the result of almost 50 years of weapons plutonium production. The research, development, and demonstration (RD&D) of innovative cleanup technologies are crucial to Hanford cleanup. RD&D activities involving hazardous and mixed waste are subject to Resource Conservation and Recovery Act (RCRA) regulations. RD&D activities are dynamic and unpredictable, and do not fit well with the RCRA permitting process, which was developed for stable commercial activities. The lengthy, highly detailed process for acquiring and modifying RCRA permits is a major barrier to the development and implementation of innovative waste treatment technologies. The challenge at Hanford is to find more flexible regulatory mechanisms to support critical RD&D activities and to work effectively with regulators to provide the regulatory logic, technical familiarity, trust, and confidence necessary to support technology development requirements. The team analyzed RCRA permitting alternatives, and surveyed more than 50 RD&D activities, assigning each a tentative compliance pathway based on an optimum interpretation of the alternatives. The results were delivered to the regulators, along with specific recommendations regarding regulatory interpretations and strategies that would support an aggressive RD&D program without compromising public health and safety.
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The Department of Energy (DOE) Hanford Site`s huge waste inventory and environmental contamination are the result of almost 50 years of weapons plutonium production. The research, development, and demonstration (RD&D) of innovative cleanup technologies are crucial to Hanford cleanup. RD&D activities involving hazardous and mixed waste are subject to Resource Conservation and Recovery Act (RCRA) regulations. RD&D activities are dynamic and unpredictable, and do not fit well with the RCRA permitting process, which was developed for stable commercial activities. The lengthy, highly detailed process for acquiring and modifying RCRA permits is a major barrier to the development and implementation of innovative waste treatment technologies. The challenge at Hanford is to find more flexible regulatory mechanisms to support critical RD&D activities and to work effectively with regulators to provide the regulatory logic, technical familiarity, trust, and confidence necessary to support technology development requirements. The team analyzed RCRA permitting alternatives, and surveyed more than 50 RD&D activities, assigning each a tentative compliance pathway based on an optimum interpretation of the alternatives. The results were delivered to the regulators, along with specific recommendations regarding regulatory interpretations and strategies that would support an aggressive RD&D program without compromising public health and safety.
Key concepts: Resource Conservation and Recovery Act, Hazardous waste, Hanford Site, Work (physics), Business, Resource (disambiguation), Process (computing), Waste management