RCRA FACILITY CLOSURE

N Area RCRA Facility Closure Cost Estimate Summary. T8-1... 

Estimated Cost for Closure—This section estimates the cost for N Reactor deactivation, RCRA facility closures, RCRA past-practice (RPP) site remediation, and D D. The level of confidence behind these cost estimates is commensurate with engineering and planning currently available. Cost estimates for near-term activities are based on more detailed planning than outyear activities, such as site remediation after 2005 and D D by 2016. 

RL-4120 RL-3600 RL-3600 RL-5282, 5284 Not Available N Reactor Deactivation (FY92) N Reactor Deactivation (FY93-FY99) RCRA Facility Closures RCRA Past Practice Site Remediation Decontamination and Decommissioning... 

Actions at a RCRA facility may culminate in its return to normal operating status while at most Superfund sites (and at some RCRA facilities undergoing Corrective Action), these activities typically culminate in final cleanup or closure of the site. These and other factors might lead to selection and implementation of different corrective measures at otherwise similar RCRA and Superfund sites. 

In conducting sampling for preclosure activities (such as the RCRA facility investigation (RFI)) and for closure activities, the Army must either follow accepted published... 

On or within any other area or structure deemed to be included in the JACADS Closure Campaign (JCC) through the RCRA Facility Assessment (RFA) or other means. 

U.S. Army. 2000e. Conceptual Site Model and Assessment Methodology for the Human Health Risk-Based RCRA Permit Closure of the JACADS Facility, Johnston Island, Johnston Atoll, North Pacific (Ocean). Prepared by United States Army Center for Health Promotion and Preventive Medicine for the Project Manager for Chemical Stockpile Disposal, June 27. Report No. 39-EJ-8929-99. Aberdeen Proving Ground, Md. U.S. Army Program Managerfor Chemical Demilitarization. 

Draft closure plans for the four RCRA facilities were submitted to Ecology in 1987 and are scheduled to be revised and resubmitted in 1994 in accordance with the Tri-Party Agreement (DOE-RL 1991). 

The facility would use a dry scrubber system for emission control, which would eliminate the need for wastewater treatment. Any water from emission control and from decontamination procedures would be treated in the on-site groundwater treatment system. The residual soil and collected ash is assumed to be nonhazardous and can be disposed of in a solid waste disposal facility in compliance with subtitle D of RCRA. In the event that they cannot be delisted due to the presence of metals, the residuals will be managed as part of the closure of Area 2 shown in Figure 16.21 (lead-contaminated soil). 

Recommendation 2. The end state, end use, and stewardship issues pertaining to closure of any chemical agent disposal facility should be resolved early so that planning can proceed on an assured rather than an assumed basis. If possible, facility end uses should be included in the RCRA operating permit. If end use and end state cannot be defined early in the planning process, risk assessments and cost and schedule estimates for alternative end states and uses should be prepared. 

The Army s closure objective is to render the JACADS facility clean according to Resource Conservation and Recovery Act (RCRA) criteria and avoid a permit requirement for postclosure care under RCRA (U.S. Army, 2000a). 

The JACADS closure activities will involve the dismantling and destruction of that portion of the facility that cannot be decontaminated to meet the 5R cleanliness standard. An area decommissioning matrix delineates the areas that will be decontaminated and dismantled, decontaminated and abandoned in place, or solely abandoned in place (U.S. Army, 2000c). The remaining systems, structures, and components (SSCs) that are left in place must meet the Resource Conservation and Recovery Act (RCRA) criteria for decontamination as well as the Army standard of 5R. Areas that were kept free of any agent or hazardous materials will be sampled to demonstrate their cleanliness in accordance with the final closure sampling and analysis plan. 

The postclosure survey report should fully and completely document all activities and all results (data), and it should certify that the closure has been done in compliance with the work plan and all applicable laws and regulations. A professional engineer licensed in the state where the closure was done must attest to the report. (In the case of JACADS, the state is California, where the EPA Region IX office is located.) Appendix E provides two sample tables of contents from industrial RCRA closure survey reports accepted by EPA they can be used as a guide to the contents of the final and interim reports required. Box E-1 shows the table of contents for a final facility RFI postclosure report. Box E-2 shows the table of contents for an interim remedial measures report, used to obtain EPA conditional approval for the cleanup of specific areas prior to final facility closeout. 

All wastes classified as hazardous under RCRA, including properly treated toxic waste that is still considered hazardous, are intended for disposal in near-surface facilities regulated under Subtitle C of RCRA. EPA has developed detailed technical requirements on waste treatment and the siting, design, operation, and closure of disposal facilities. Thus, when viewed in relation to intended disposal technologies, there is basically only one class of hazardous chemical waste, regardless of the amounts of hazardous substances present i.e., a waste either is hazardous or it is not. 

Requirements on treatment and disposal of hazardous chemical waste under RCRA, especially the intention to limit contamination of groundwater, are based to some extent on considerations of risks to public health and the environment posed by waste. However, requirements on waste treatment and the siting, design, operation, and closure of disposal facilities are not based on long-term projections of the ability of disposal systems to limit releases of hazardous substances to the environment, nor is any consideration given to... 

Finally, if high-level waste is considered to be hazardous waste under RCRA, requirements on construction, operation, and closure of a disposal facility, including the provision of a liner system, leachate collection and removal system, and leak detection system (see Section 4.2.2), would need to be addressed. Such requirements are impractical at a geologic repository for disposal of high-level waste... 

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