Facilities
The Resource Conservation and Recovery Act
RCRA, enacted as federal law in 1976, is the principal law that governs disposal of hazardous waste in the United States. In 1992, the U.S. Environmental Protection Agency authorized the California DTSC to implement and oversee RCRA in California. Structures at the Santa Susana Field Laboratory under RCRA permits therefore must undergo this additional specialized process prior to removal. This process is focused on:
- Protecting human health and the natural environment from waste,
- conservation of energy and natural resources,
- reducing the amount of waste generated, and
- disposing of waste in an environmentally sound manner.
In California, RCRA stipulations are managed by DTSC. There are three main phases of RCRA.
- Permitting: During this phase an entity documents how it intends to manage toxic substances.
- Operations: While operating the entity demonstrates to DTSC how it is complying with the RCRA permit requirements.
- Closure: During the closure phase, the entity removes all toxic materials and demonstrates there is no remaining contamination above standards.
For its former operations at the site ETEC, DOE prepared two RCRA permits: one for the RMHF and the second for the HWMF. The RMHF was used for the storage and processing for subsequent shipment of chemical wastes and mixed wastes (containing chemicals and radionuclides). The RMHF received authorization to operate under an interim status permit from DTSC in 1997. Although the RMHF permit is still active, it has not been operated since 2007. The HWMF was used for the removal of sodium and potassium from metallic objects. It was permitted in 1983. Operations at the HWMF ended in 1997.
This process in done in tandem with the Department of Energy’s National Environmental Policy Act as well as the State’s Environmental Impact Report. All reports must be completed in order conduct a remediation of the site.
Public Comment Period Begins for Draft Closure Plans for RCRA Buildings
Standard Operating Procedures and Building Survey Plan
The Building Survey Plan describes radiological characterization necessary to determine residual building contamination for planning of demolition and protection of workers and the public. The Standard Operating Procedures describes the master plan process for building demolition. Next, it provides references for regulations and standard procedures for Area IV D&D. Lastly, it provides general approach for waste disposition, demolition and documentation.
EPA 2000-2003 Building Surveys
Between January 2000 and September 2001, EPA and its contractor, Tetra-Tech, reviewed Boeing's and DOE's final status and verification surveys of 11 prior radiological facilities that had undergone D&D survey and release. EPA and Tetra-Tech also conducted radiological surveys of 8 of these facilities.
On January 9, 2003, EPA issued the final reports of its three year assessment of Boeing's remediation and survey process for releasing radiological buildings for unrestricted use.
- EPA Survey Cover Letter
- EPA Survey Q&A
- Survey Table
- Building 4011, 4019, 4055, and 4100 confirmation surveys
- Building 4012, 4029, and 4363 confirmation surveys
- Building 4059 confirmation survey
- Building 4009, 4011, 4019, 4055, and 4100 document review
- Building 4012, 4023, 4028, 4029, and 4363 document review
- Building 4059 document review
EPA reached the following conclusions:
- "Previous DOE/Boeing surveys sampled in appropriate and representative locations"
- "Measurements made in previous surveys were accurate"
- "EPA concurs with the conclusions made by the Department of Energy (DOE) and Boeing Rocketdyne about the locations and levels of residual radioactivity"
- "Residual radioactivity does not exceed DOE and Nuclear Regulatory (NRC) established limits for unrestricted use."
EPA therefore confirmed that prior surveys had been conducted in a correct, appropriate and compliant manner.