RCRA permitting strategies for the development of innovative technologies: Lessons from Hanford

The Hanford Site restoration is the largest waste cleanup operation in history. The Hanford plutonium production mission generated two-thirds of all the nuclear waste, by volume, in the Department of Energy (DOE) Complex. Cleanup challenges include not only large stored volumes of radioactive, hazardous, and mixed waste, but contaminated soil and groundwater and scores of major structures slated for decontamination, decommissioning, and demolition. DOE and its contractors will need to invent the technology required to do the job on a timetable driven by negotiated milestones, public concerns, and budgetary constraints. This paper will discuss the effort at Hanford to develop an integrated, streamlined strategy for compliance with the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) in the conduct of research, development, and demonstration (RD&D) of innovative cleanup technologies. The aspects that will be discussed include the following: the genesis of the RD&D permitting challenge at Hanford; permitting options in the existing regulatory framework; regulatory options that offered the best fit for Hanford RD&D activities, and the problems associated with them; and conclusions and recommendations made to regulatory bodies.