Oklahoma Department of Environmental Quality RCRA PROGRAM EFFECTIVENESS: INDUSTRIAL RADIOGRAPHY OUTREACH

Transcription

1 Oklahoma Department of Environmental Quality RCRA PROGRAM EFFECTIVENESS: INDUSTRIAL RADIOGRAPHY OUTREACH

2 Christina Coffel, Environmental Program Specialist III, Hazardous Waste Compliance Section of Land Protection Division. Previously of the OK Waste Tire Program and the Radiation Management Section.

3 Industrial Radiography is a non-destructive testing method that uses ionizing radiation such as gamma rays or x-rays to make radiographic images for the purpose of detecting flaws in objects. This industry is heavily regulated by the Nuclear Regulatory Commission (NRC) concerning materials safety.

4 In September 2008, a CEI performed at a nonnotified IR company based on inspector knowledge of the facility's operations from work in the previous ODEQ section. Inspector expected facility to be recycling silver waste generated from the development of the film. IR company performed NDT on fixed wing aircraft and other structures. Facility did not have any mobile operations.

5 IR facility did generate silver bearing waste from the developer, fixer, and waste rinse waters collected into a holding tank. Holding tank was then pumped into mobile containers which he then transported to his home and dumped down the garage drain. Operator stated his wife would no longer allow him to dump it down the toilet because it stained the toilet bowl. Operator provided documentation of attending the City of Tulsa s Best Management Practices course for photographic waste and stated that he knew not to discharge the waste into his septic tank because it would kill his bugs.

6

7 Photographic waste generators generally utilize 40 CFR 266 Subpart F Recyclable Materials Utilized for Precious Metal Recovery. Requirements: Economically significant amounts recoverable Must Notify under section 3010 of RCRA Must use a manifest (generators, transporters, and people who store) Document not speculatively accumulating

8 If silver bearing waste is stored prior to recovery, hazardous waste management requirements apply and facility must count the waste for generation purposes. If silver bearing waste is not stored prior to recovery, facility does not have to manage it as hazardous or count the waste. The sludge (recovery cell) is not hazardous waste if sent for reclamation, no manifest required. Waste waters are no longer hazardous if silver content is reduced to below 5 ppm.

9 Silver potentially found in developer waste, developer rinse waters. Usually can filter waste waters through a recovery unit to capture silver enough to a level below RCRA and to an acceptable level for discharge to POTW. Recovery cell then usually shipped to reclamation facility such as a refinery for silver recovery. Developer waters may also be D002 (corrosivity).

10 September 2008 CEI identified multiple problems. Facility a Small Quantity Generator Facility improperly managed it s HW Facility improperly disposed of it s HW Facility transported HW without an authorization Penalty assessed at $50,000. Facility agreed to penalty with 2 Supplemental Environmental Projects including an industry training on the topic. Topic ended up being too complex for facility to train industry, chose to pay cash penalty instead. DEQ picked up the industry training project based on feedback from facility.

11 During research for training, multiple states answered our query. Much thanks to: District of Columbia Kansas Minnesota Montana Pennsylvania Idaho Michigan Missouri North Dakota Washington Minnesota has a great factsheet: Managing Hazardous Waste Generated by Construction and Service Contractors. EPA has an In Focus: Photo Processing document that is great as well.

12 Other state s input: Generally compared to bridge painting and blasting operations for mobile contractors. Generally assumed CESQG generation status; however, there was suggestions for SQG and LQG situations as well. Most assumed facilities would managing waste under precious metals recovery exemption.

13 April 2010 held workshop to get more information from various companies in Oklahoma to determine if the industry needed further guidance. All participants expressed desire for clarification of the applicable regulations. August 2010 held training for the IR industry at OKDEQ, OKC. Good turnout and much question and answer after presentation. Posted guidance on ODEQ webpage.

14 One IR facility invited me out to observe their activities. They had already started implementing information from the training and had a few questions that they felt could only be answered after observing their practices. Mobile operations, mainly pipeline weld IR.

15

16

17

18

19 Mobile operations imaged 200 miles of new pipeline being installed across Oklahoma. Waste fluids in mobile trucks brought back to main location and placed into waste drum labeled HW and dated upon accumulation. Waste film being collected into drum also labeled and dated. Had plans of purchasing a silver reclamation unit to be located in the mobile units to reduce volume of waste managed.

20 Future Plans: Focus on IR facility inspections this year for RCRA CEIs. Facilities are not notified generators, so HWCS is working with the Radiation Management Section to identify the facilities that are subject to RCRA inspections. Facilities have had time to implement corrections and avoid violations.

21 Goal of the inspections not only RCRA compliance but also to evaluate the Industry training/outreach and its effectiveness. Hope to learn all facilities are in compliance with RCRA but also better improve communications between compliance sections within the ODEQ.

22 Thank you RCRA PROGRAM EFFECTIVENESS: INDUSTRIAL RADIOGRAPHY OUTREACH