The Division of Waste Management and Radiation Control (DWMRC) helps businesses and residents handle waste properly and plays a critical role in safeguarding Utah residents from harmful exposure to radiation. In 2017, DWMRC accomplished these objectives through:
- Permitting and compliance for hazardous and solid waste storage, treatment, and disposal facilities
- Oversight of facilities performing corrective-action cleanup of contaminated sites
- Oversight of the recycling of used oil, waste tires, and mercury switches
- Education and outreach on proper waste disposal and the management of used oil and hazardous waste
- Inspections and compliance monitoring and licensing actions for low-level radioactive waste
- Verification of the classification of radioactive materials shipped from generator sites into the state
- Evaluation of the safety of depleted uranium disposal in the West Desert
- X-ray equipment inspections at medical, veterinary, dental, and various non-medical, industrial, and institutional facilities across the state
- Licensing of radioactive materials and uranium mills
- Continuous improvement
DWMRC works closely with facilities to clean up waste-contaminated areas and establishes permit and licensing conditions that ensure that waste treatment, storage, and disposal practices protect human health and the environment. Health physicists safeguard citizens from exposure to radiation through equipment inspections and oversight of the industrial and medical uses of radioactive materials. Education and outreach on proper waste disposal, recycling, indoor radon, and radioactive materials are critical components of DWMRC programs. The division also implements operational efficiencies to streamline its inspection and permitting processes.
Permitting and Compliance
Solid and Hazardous Waste
The division issues permits to solid and hazardous waste facilities to treat, store, and dispose waste in a manner that protects the land and ground water from contamination. Permitted solid waste facilities include municipal, commercial, and industrial landfills. The division issues permits to a number of large commercial and government hazardous-waste facilities and ensures compliance with regulatory requirements and all permit conditions through regular inspections. Failure to comply with permit conditions results in a range of enforcement actions, including increased inspections, warning letters, notices of violation (NOVs), compliance orders, and penalties.
“I had the opportunity to work with DEQ on a variety of matters regarding project planning, permitting, design, operations, and compliance issues. I had the privilege to work with Scott Anderson, and Doug Taylor on all phases of the (construction of a new landfill in Cache County) such as site selection, planning, and permitting of the new landfill. Development of a new landfill is one of the most difficult if not the difficult public project to execute in any community. Usually, the emotions of the affected community are very high and the first response is always Not in My Backyard (NIMBY). (DWMRC) was the gatekeeper entrusted to protect the environment, consider the socioeconomics of the community, project cost, and other public concerns in the development of this project. After 23 years of working with Utah DEQ particularly the (DWMRC) staff and leadership, I can say unequivocally (that) DEQ personnel are very professional, helpful, responsive, and sensitive to the public needs, while protecting our environment.”
–Issa Hamud, Director, Logan City Environment Department
Low-level Radioactive Waste (LLRW)
DWMRC is responsible for licensing, permitting, and compliance monitoring for the EnergySolutions waste management facility in Clive, Utah, one of only three shallow land disposal facilities in the country that can accept low-level radioactive waste (LLRW). The division is also responsible for the Generator Site Access program that regulates all radioactive waste generators, processers, and collectors that utilize the Clive facility for waste disposal. DWMRC licensing and oversight ensure that radioactive waste entering Utah meets Class A state requirements and that the handling and disposal of LLRW at the site is protective of public health and safety.
The division issues licenses and permits for uranium mills that extract uranium from mined ore or recover uranium from materials containing uranium, known as alternate feed material. Currently, the state only has one active, conventional uranium mill, but the owner of a second mill has requested a return to active operations pending a decision on a license renewal request to DWMRC.
White Mesa Mill – Energy Fuels
Built in 1979, the White Mesa Mill processes uranium ore and alternative feed material. Nitrate and chloroform plumes from earlier mill activities infiltrated the ground water onsite, and the mill is currently under a Corrective Action (CA) plan. Seventy-five monitoring wells are located onsite, with some of the wells testing for as many as 38 possible contaminants. The nitrate and chloroform remediation plans require Energy Fuels to pump the ground water and treat it by evaporation and/or use it as process water. Concentrations of both nitrates and chloroform have decreased since remediation began.
In 2011, Energy Fuels sought approval from DWMRC to amend its license to receive and process alternate feed material from Sequoyah Fuels Corporation. The proposed amendment would allow the mill to process up to 16,700 tons gross weight of uranium material from Sequoyah Fuels.
A safety evaluation report (SER) prepared by environmental contractor URS Professional Solutions concluded that this alternative feed material will not have a significant adverse effect on public health or the environment. The Sequoyah Fuels alternate feed amendment request is included with the renewal of the 11e.(2) byproduct radioactive material license and ground water quality discharge permit.
The 90-day public comment period ran from May 1, 2017, to July 31, 2017. The division is considering public comments through its license and permit review process and preparing a response to comments.
Shootaring Canyon – Anfield Resources
DWRMC approved the transfer of the Shootaring Canyon Uranium Mill from Uranium One to Anfield Resources on January 29, 2016. The mill hasn’t been operational since 1982, when it ran for 76 days. It ceased operations when uranium prices dropped. On June 30, 2016, Anfield Resources submitted a license renewal application to the division to transition the mill from standby to operational status. The license renewal is currently under review by the DWMRC pending, among other required documentation, a financial feasibility report.
The Rio Algom Mill began operations in 1972 and operated almost continuously until 1989. The site is currently in the process of decommissioning and closure by Rio Algom, the current owner and licensee. A uranium plume contaminated ground water onsite, and the license includes ground water monitoring requirements and concentration limits approved by the Nuclear Regulatory Commission (NRC) prior to transfer of Agreement State status to Utah, when DEQ became the licensing authority. The two tailing cells at the mill have been covered and closed.
The Radioactive Material License was renewed on March 3, 2017, for five years. This will allow Rio Algom time to complete the activities associated with the uranium plume. Once the remediation completion report on final runoff controls for the tailings cover is approved, ownership of the mill site will be transferred to the U.S. Department of Energy.
DWMRC works with companies through its Corrective Action Program to remediate environmental contamination from the improper storage, treatment, or disposal of solid or hazardous waste. Corrective Actions (CAs) ensure that facilities deal with these releases properly to minimize harm to the public and the environment. The division’s collaborative efforts with businesses and developers on these cleanups lead to timely resolution of environmental issues and a faster return of contaminated lands to beneficial use. DWMRC also prepares Site Management Plans that allow facilities to continue operations while still protecting workers and environmental receptors from residual contamination on these sites.
Tooele Army Depot-South (TEAD-S)
The Tooele Army Depot-South, formally the Deseret Chemical Depot, was once home to most of the country’s chemical weapons. The Tooele Chemical Agent Disposal Facility, built in 1994, began burning chemical weapons in 1996 and completed incineration of its chemical-weapon stockpile in 2013. Cleanup activities continue on the site.
TEAD-S Solid Waste Management Unit (SWMU) 27
Solid Waste Management Units (SWMUs) are areas where solid or hazardous wastes are placed or routinely released. SWMU 27 was the old sewer and wastewater treatment system at TEAD-S. This system operated for over 50 years before its replacement in 2012 and was used for the disposal of sewage and industrial wastewater from the auto shop, battery shop, and other industrial shops. The system consisted of oil-water separators and about a mile of drains and piping leading from the buildings to a large concrete tank. The concrete tank contained solids that overflowed into ponds and ditches.
Investigation of the entire system began in 2013 following removal of the concrete tank and tank waste in 2012. The investigation included review of design drawings, camera survey, and soil and soil gas sampling of all parts of the system. The contaminants of concern were metals, semi-volatile organic compounds (SVOCs) and volatile organic compounds (VOCs). The investigation uncovered a previously unknown older system from the 1940s-50s used prior to the concrete tank. This older system included two large buried redwood tanks and a drainfield. This older system was added to the investigation.
A report of sampling activities and results was completed in 2014. This report recommended removal of the oil-water separators, the old redwood tanks, and related soil contamination. The report indicated the other parts of the system were not significantly contaminated and the investigation for these areas was complete.
Due to Army contracting issues, the removal actions recommended in the 2014 report didn’t occur until 2016. Soil samples collected after initial removal of the oil-water separators, redwood tanks, and contaminated soil indicated the need for removal of additional soil. This additional soil was removed and a second set of samples collected. These sample results indicated the work was complete.
A final report describing the removal actions was submitted and approved in 2017. The approval designated the entire SMWU 27 system as qualified for unrestricted land use, and SWMU 27 is no longer regulated.
TEAD-S SWMUs 1 and 25 – Resource Conservation and Recovery Act (RCRA) Facility Investigation
SWMUs 1 and 25 include an area of about 2,000 acres at TEAD-S. This area was used for the demilitarization of hundreds of thousands of incendiary and military munitions devices, along with the disposal of tens of thousands of demilitarized chemical agent munitions and related waste. Much of the waste was burned or disposed in open trenches. In many cases, each trench contained multiple layers of waste, with only the top layer of waste exposed.
From 2012 to 2015, the Army removed all the exposed waste in the trenches and on the surface. Following removal of this waste, a site investigation was conducted from 2015 to 2017. This investigation included an inventory of all potentially contaminated areas, ground-based and helicopter-based geophysical surveys, soil gas sampling, soil sampling, and ground water sampling.
TEAD-S, DWMRC, Parsons, and the Army Corps of Engineers formed a project team to facilitate investigation of this large area. The team met about twice a month to plan and oversee sampling activities. At each meeting, team members discussed a sample approach for each area, then visited the site after the meeting. The team prepared a memo following each meeting documenting its decisions and the sample approach for each area. These meetings, which took place over about a year, allowed TEAD-S to complete the RCRA Facilities Investigation (RFI) for the entire 2000-acre area in an efficient and timely manner by spring 2017.
Orbital ATK Launch Systems – Bacchus Facility – Group 10 SWMUs
The ATK-Bacchus facility is located on the west side of the Salt Lake and unincorporated Salt Lake County. The facility occupies about 10,000 acres and includes over 400 buildings that were/are used to produce and prepare explosives for the mining industry, manufacture solid propellants, and produce solid-propellant rocket motors.
As part of past manufacturing processes, ATK has generated a variety of industrial wastes. The main wastes include ash from the burning of explosives, laboratory waste, spent solvents, and contaminated wastewater. Much of the historical solid waste and drummed solvent was disposed in landfills. Historically, wastewater contaminated with explosives, metals, organics, and perchlorate was discharged into sumps.
DWMRC issued ATK a Resource Conservation and Recovery Act (RCRA) permit that required investigation and cleanup of waste disposed in landfills and discharged to sumps. It was determined that significant soil and ground water pollution resulted from the historical waste and wastewater disposal activities.
Group 10 included 18 areas with small, well-documented chemical spills (for example, 30 gallons of acid or one drum of solvent). In 2015 and 2016, all 18 areas were sampled. Only a few samples were needed at each site due to the small areas impacted. The sample results confirmed that only one site needed soil removal, and significant soil and soil gas contamination was not present at the other Group 10 SWMUs.
Soil removal at N-10, the one site that required cleanup, occurred in 2016. Soil samples collected after the removal showed N-10 was complete. A sampling report submitted in fiscal year (FY) 17 recommended that all Group 10 SWMUs qualified for unrestricted land use. This recommendation was approved, and the Group 10 SWMUs are no longer regulated.
Success Story: Cottonwood Geneva Land Development
In 2005, Anderson Geneva purchased the 1700-acre, former Geneva Steel Facility in Vineyard, Utah, following the steel plant’s bankruptcy in 2002. The property has two co-permittees — United States Steel Corp. and Anderson Geneva—who are responsible for the permit for post-closure requirements, corrective-action investigation, and cleanup of the former steel mill.
Cottonwood Partners, a real estate investment and development company from Salt Lake City, purchased approximately 45 acres from Anderson Geneva for redevelopment as a mixed-commercial land-use site known as The Forge at Geneva.
A Phase I Environmental Site Assessment (ESA) was conducted on the 45-acre parcel. Based on the results from the Phase I assessments, two separate Phase II ESAs were conducted on a specific portion of the five-acre parcel to better evaluate the potential for contamination. In addition, a Limited Subsurface Investigation was performed to define the contamination. These investigations were performed to determine the nature, degree, and location of contamination within the surface and subsurface soil as well as any potential ground water impacts.
The investigations concluded that polycyclic aromatic hydrocarbons (PAHs) existed in the surface soil and within the subsurface at depths of around three feet below ground surface. PAHs are a concern, as they have been linked to different types of cancers and are classified as a probable human carcinogen. Investigations showed no known ground water impacts.
Cottonwood Geneva had specific land use requirements for the 45 acres, as well as timelines for the different investigation phases and completion of cleanup. Forty of the acres were designated for general mixed commercial use, but a portion of the remaining five acres was specifically earmarked for a proposed medical center.
The prospective purchaser for the medical center required that the site meet residential cleanup levels—unrestricted land use or residential standards that meet the most conservative levels. Under this standard, the division issues a determination that the corrective action is complete without controls. To achieve this corrective action determination and meet land use requirements, the property owner had to remove approximately 7,300 tons of contaminated soil for shipment offsite for disposal at an approved landfill.
Because Cottonwood Geneva was on a fast-track to get the site cleaned up and ready for re-development, the project required a lot of energy and time from DWMRC staff. Besides the usual reviews and approvals, additional challenges arose that made it difficult to meet the owner’s timelines. For example, after the initial approval was granted for the removal of contaminated soil, three separate and additional addendums had to be reviewed and approved before implementation of the work plan. This required a lot of back and forth contact between Cottonwood Geneva, its consultant, and DWMRC. Division staff worked hard to meet these timelines while still ensuring the cleanup met the environmental standards and requirements to protect human health and safety.
“Rocky Stonestreet has been helping us for the past 3+ years with the remediation of our 45-acre development located within the original Geneva Steel site. He has been responsive, supportive, resourceful, knowledgeable, and professional in helping us address the environmental challenges of our project. He was always quick to respond to questions and thoughtful in developing timely solutions to our remediation issues. We appreciated his support in allowing us to beneficially reuse materials within our site that saved us time and money. He helped us craft a Site Management Plan and Environmental Covenant that allows us to protect the interests of the public while at the same time reclaiming a contaminated brownfield site and creating a world-class mixed use development. Scott Anderson and Eric Baiden were also very supportive and helpful. With our combined efforts, a dying piece of property has been reclaimed and will provide a place for residents of Utah County to work, live and gather long into the future!”
–Jeff Gochnour, Director of Development, Cottonwood Geneva, LLC
Success Story: Western Zirconium Financial Assurance
One of DEQ’s four values is exceptional service: “We are public servants committed to the people of Utah and our customers. We solve problems, actively engage stakeholders, and are professional, responsive and fair.”
DWMRC exemplifies this value by working with its licensees to establish financial assurance for the eventual decommissioning and remediation of the licensees’ operations. Having financial assurance in place relieves the taxpayer of the liability for cleanup of a site should a licensee prove unwilling or unable to do so. Financial assurance can take many forms, with the most common including a letter of credit or surety bond (a form of insurance) in combination with a standby trust to receive the funds if conditions require a claim.
This year, DWMRC personnel worked with the technical staff at Westinghouse Electric’s Western Zirconium operation near Ogden to identify environmental hazards associated with the business operation, quantify those hazards, and estimate the funding necessary to perform the cleanup work if the business were to fail. The licensee obtained a letter of credit from a bank for the amount estimated, plus a contingency fund of an additional 25 percent for unforeseen needs. The letter of credit named DEQ as the beneficiary. If DEQ were called to exercise the letter of credit, the funds would be placed in a trust account, where it would remain until cleanup work at the site was performed and bills came due.
This funding assurance provides exceptional service to the people of Utah by protecting taxpayers from paying for cleanup costs and ensuring a site cleanup that is protective of people and the environment when a business is unable to cover cleanup costs.
Education and Outreach
Education and outreach are key components of DWMRC programs. The division educates businesses and residents on the proper disposal/recycling of solid and hazardous wastes to prevent soil and ground water contamination from the improper storage or disposal of wastes. The used oil and waste tire programs, for example, have dramatically reduced the health hazards from these two waste streams and helped encourage proper disposal and recycling of these materials.
DWMRC provides comprehensive information on the management of household hazardous waste, recycling, pollution prevention, and best management practices (BMPs) for specific businesses. The used oil and small hazardous waste generator programs offer presentations and training to the public and businesses as part of their public outreach efforts. The Indoor Radon Program is dedicated to providing the public with the tools to recognize and remediate elevated levels of radon in homes and schools.
The Used Oil Program makes it easier for do-it-yourselfers (DIYers) to properly dispose of used oil, thanks to its extensive public education and outreach program and collaboration with Utah’s 13 local health departments. Over 400 locations throughout the state accept used oil, many of them private companies that have registered with DWMRC as collection centers. A reimbursement program provides financial incentives for businesses collecting and recycling used oil.
The Used Oil program provides basic used-oil and pollution-prevention training for businesses, community groups, professional organizations, and schools, along with short videos that explain how and where to recycle used oil.
The Waste Tire Program oversees the storage, disposal, and recycling of waste tires to reduce health and safety hazards, decrease the number of tires in landfills, and encourage the tire recycling industry. The Waste Tire Recycling Fund provides partial reimbursement of the cost of transporting, processing, recycling, and disposing of waste tires. Since program inception in 1991, tire recycling has increased dramatically. Utah recycled approximately 5 million waste tires in 2017. Most of these tires are recycled or processed within the state at six registered tire recyclers.
Success Story: Snyder Property Waste Tire Removal
A waste-tire cleanup was conducted at the Jon Snyder property in Jensen, Utah. The property is located on the Green River and near the entrance to Dinosaur National Monument. During the early 1980’s, several business in the area dumped waste tires on the property; these tires were subsequently buried. Run-off from storms eventually uncovered the waste tires, which began to migrate to the surface, requiring cleanup.
DWMRC worked closely with Mr. Snyder, Darrin Brown of the TriCounty Health Department, and Scott Hacking, DEQ District Engineer at the time. The waste tires were uncovered and removed for recycling by Liberty Tire with 100 percent funding from the State Waste Tire Fund.
Small-quantity Generators of Hazardous Waste
DWMRC provides compliance assistance for small businesses that generate less than 2,200 pounds of hazardous waste per month. This program has been successful in helping small businesses understand the requirements necessary for compliance with the hazardous-waste-management rules specific to small business. Although DWMRC visits approximately 150 companies a year through this program, there remain many small generators that are not aware of the compliance assistance program. The division collects information about these other small quantity generators through trade associations, word-of-mouth, and complaints received from neighbors. The aim is educate these small waste generators on the proper disposal of hazardous wastes to protect their workers and the environment.
Success Story: Training and Outreach across Utah
Hazardous waste rules can be complex and confusing. But sometimes all that a small hazardous-waste generator needs is a chance to hear from DEQ staff and ask questions. That’s why Alex Pashley and Tom Ball offer training to companies to help them understand the rules, see how the rules apply to their facility, and find out what they need to do to meet their regulatory requirements. Alex and Tom take their trainings “on-the-road,” making presentations in college classrooms, company lunch rooms, and conference rooms.
After a recent training presentation, Dr. Leon Pahler from the Rocky Mountain Center for Occupational and Environmental Health said,
The training is available to anyone who requests it and takes anywhere from one to two hours to complete.
Tom Ball conducts outreach with local health departments, local emergency-planning commissions, and at the Governor’s Public Safety Summit to help these organizations understand what DWMRC does. Tom makes presentations at Salt Lake Community College to introductory engineering students to provide them with an overview of DEQ, along specifics about DWMRC and the types of engineers DEQ employs and their job responsibilities.
The division also gives presentations on a regular basis to high school science and driver-education classes around the state, including Richfield High School, Cyprus High School, and Ogden High School.
“Tom has visited my classroom over the last couple of years. The information provided covers important information for my class. Our students need to understand the importance of taking care of our environment. Tom’s presentation helps students understand that important topic.”
–Corey Morrison, Richfield High School
“I’m so appreciative of the opportunity to use Tom as a resource in my Environmental Science classroom. Not only was he flexible in his scheduling, but he was engaging and informative. He provided a powerful first-hand account of what scientists can do in our community while presenting real-world, tangible examples of human impacts on our environment. Thank you so much for making this resource available to my students!”
–Sara Byrd, Ogden High School
Electronic Waste (E-Waste)
Electro”stream in the country, with predictions that approximately 50 million tons of electronics will be discarded in 2017 alone. DWMRC is particularly concerned about the mismanagement of recycled and discarded Cathode Ray Tube (CRT) television and computer monitors. E-waste contains a wide range of hazardous materials, including heavy metals such as lead, mercury, and cadmium. CRT screens in particular contain high levels of lead. Improperly disposed e-waste can end up in landfills where these toxic substances can contaminate soils and ground water.
To combat this problem and inform the public of environmentally safer options, DWMRC publicizes electronic recycling events, maintains a list of recycling centers that accept electronics, and identifies manufacturers that participate in electronics take-back programs. The division also inspects electronics recyclers to ensure they are managing recycled electronics appropriately. More about e-waste …
According to the U.S. Environmental Protection Agency (EPA), indoor radon is the second-leading cause of lung cancer in the United States and a serious problem in Utah. One in three homes in the state test above the EPA action level of 4 picocuries per liter (pCi/L) of air, with homes testing at an average of 5.3 pCi/L. The radon program provides the following services:
- Radon awareness through public outreach and education
- Low-cost test kits to Utah residents
- Indoor radon surveys in target areas
- Individualized assistance to homeowners and public agencies
- Public-school testing
- Real estate training on testing, disclosure, and mitigation
DEQ offers an online link through its website to access and order $9.00 test kits, provides information on test results by zip code, sponsors a radon poster contest in the schools, works with home builders and organizations such as Habitat for Humanity to use radon resistant construction in their projects, and provides free continuing education (CEU) courses on radon for real estate professionals throughout Utah. Partnerships between the radon program and local health districts, hospitals, Utah Department of Health, Utah Builder’s Association, and community outreach programs have increased public and professional awareness of the risk of indoor radon exposure in the state.
Success Story: Radon Training for Real Estate Professionals
DEQ’s Radon Program Coordinator is licensed through the Utah Department of Commerce, Division of Real Estate, to teach a continuing education (CE) course for realtors called “Radon for the Real Estate Professional.” The biggest initial motivation for realtors to learn about radon is the inclusion of radon on the Buyer Due Diligence checklist. But DEQ’s radon coordinator found that after realtors attended the class, they began to see how their knowledge about radon could help protect their clients and their families from its adverse health effects. Realtors have been enthusiastic about the class and offered positive feedback about the information presented.
In 2017, over 400 realtors took the radon course. Estimates show that every realtor talks to at least fifty potential clients every year; this means that at least 20,000 people in Utah learn about radon through real-estate transactions every year. These client conversations increase public awareness of the dangers of indoor radon, encourage homeowners to test their residences, and arm them with information to mitigate the problem.
“I have taken other radon courses before, but never a radon class that discusses radiation and the science behind radon. In addition, I also enjoyed learning about radon and lung cancer — hearing from a lung cancer survivor made the topic even more important to me, my family, and clients. I do not understand why radon is not a required test when selling and buying a home. Thanks for an excellent class — I am so glad I came.”
–Response to post-class survey, realtor with KeyRealty
DWMRC’s X-ray inspection program safeguards patient health by making sure that diagnostic and therapeutic radiological equipment uses the lowest amount of radiation necessary for a given procedure. Highly trained radiological inspectors evaluate the performance of X-ray units and radiation safety practices at these facilities on a regular basis.
The division provides support and guidance to facilities with X-ray equipment, including procedures for measuring and reducing patient and non-patient exposure. Regularly scheduled visits from inspectors provide medical and dental professionals with the opportunity to ask questions, receive additional safety guidance, and review exposure levels and instrument calibration. Inspections and radiation safety advice during inspections have increased compliance rates from 70 percent to 90 percent over the past eight years. As the use of radiological diagnostics increases in medical, dental, veterinary, and industrial practices, the proper operation of X-ray units is crucial for protecting individuals from unnecessary or even harmful exposure to radiation.
“I was very impressed with the speed and accuracy of the inspection. Most people might worry about having an inspection, but I loved the peace of mind that it gave me that everything was set up correctly.”
–Dr. James D. Beadle, Sound Corrections Chiropractic, PLLC
In 2009, EnergySolutions requested a license amendment for the disposal of large quantities of depleted uranium (DU) at its facility. DU is a unique form of low-level radioactive waste that becomes more radioactive with time. State rules promulgated in 2010 require the company to complete a performance assessment (PA) to determine whether it can meet federal and state performance standards to protect public health and safety before accepting DU at the facility. EnergySolutions submitted a site-specific performance assessment in 2011, and DWMRC, in recognition of the inherent scientific and technical complexities, hired outside contractor S. Cohen & Associates (SC&A) in August 2013 at the request of the licensee to provide technical support in evaluating the PA for adequacy.
DWMRC and SC&A conducted meticulous reviews of the PA and submitted detailed questions, observations, and concerns regarding technical and regulatory issues surrounding the disposal of DU. EnergySolutions requested, and was granted, several extensions to perform and submit additional analyses and respond to the various items raised in the technical evaluations conducted by DWMRC and SC&A.
DEQ’s consultant finalized its Safety Evaluation Report (SER) (Volume 1 and Volume 2) in April 2015. The SER identified eight issues in the PA that remained unresolved, and stipulated seven conditions to be met to move the project forward. A public comment period was initiated, and EnergySolutions requested additional time to address these issues. DWMRC subsequently held two public information meetings on the SER to provide the public with the opportunity discuss report findings with DEQ and its consultants. In late November 2015, EnergySolutions submitted a revised model (version 1.4) in response to issues raised in the April 2015 Draft Safety Evaluation Report (SER), general comments on the content and scope of the SER, and specific technical comments and edits to the SER.
The review of model 1.4 was, for various reasons, placed on low priority beginning February 2016. The project was elevated to high priority beginning January 2017. DWMRC completed an interrogatory of the version 1.4 model in May 2017. At this time, DWMRC is waiting on the final response to comments from EnergySolutions, after which an SER (version 2) will be written and public comment solicited. The Director of DWMRC will then issue a decision (approval, approval with conditions, or denial), with a subsequent second public comment period regarding the agency action.
Continuous Improvement/SUCCESS Framework
DWMRC is committed to continuous improvement to improve performance and implement innovations that advance quality, efficiency, and effectiveness. Listed below are a few of the proposed and ongoing continuous improvement/SUCCESS Framework process improvements within DWMRC.
Upcoming Continuous Improvement Projects
Conversion of Used Oil Financial Assurance (FA) forms to writable PDF format
These writeable/fill-in forms will expedite the process for receiving information from permittees/FA institutions and issuing permits.
Revision of used-oil permit application forms on the web to enhance the permitting process
This is the first step for taking the basic information on the application form and directly inputting it to permit templates. The change will improve processing time of permit applications and decrease review costs.
Conversion of Revision of Used Oil Annual Report Forms to a writable PDF
The conversion will allow permittees to input the information directly into the report, streamlining the process for both staff and permittees. Currently, permittees must download the form and enter the information manually.
Update of new rule citations on the small-quantity generators (SQG)/ large-quantity generators (LQG) checklists
This update will give allow the public to access the newest rule citations in a writable pdf checklist on the DEQ website. Generators will be able to download the checklists so they can use DWMRC forms for their own inspections. Having the checklists available should improve compliance rates. This conversion will also help inspectors and generators use electronic devices in the field.
Ongoing Continuous Improvement Projects
Waste Management Permitting
The division continues to work on process improvements to ensure enforceable permits are completed in an efficient and timely manner. The division is monitoring trends and resolving technical issues that have required additional time to address.
Waste Management Compliance
The division continues to work on process improvements to ensure permit compliance in the regulated community. Enhanced compliance tracking has increased attention to timeframes and further improved compliance rates.
Improvements to the program have led to significant efficiencies in X-ray inspections, including the following:
- Newer equipment that cuts data collection time approximately in half
- Streamlined reporting process
- Data collection and data transfer using an iPad rather than pen and paper
- Administrative staff taking on most of the filing duties, freeing inspectors to visit more facilities