Regulated Disposal of NORM/TENORM Waste in Colorado: The Deer Trail Landfill
- Dade Moeller and Associates, 1835 Terminal Drive, Suite 200, Richland, WA 99354 (United States)
- Clean Harbors Environmental Services, 108555 East Highway 36, Deer Trail, CO 80105 (United States)
- Faegre and Benson, LLP, 3200 Wells Fargo Center, 1700 Lincoln Street, Denver, CO 80203 (United States)
On January 31, 2005, Clean Harbors Environmental Services submitted a license application to the Colorado Department of Public Health and Environment (CDPHE) for the disposal of naturally occurring radioactive material (NORM) and technologically enhanced radioactive material (TENORM) at Clean Harbor's Deer Trail RCRA Subtitle C landfill. Deer Trail is located 70 miles east of Denver, Colorado. The license application for Deer Trail was submitted under CCR 1007-1, Part 14 [1] the Colorado State equivalent of 10 CFR Part 61 [2] for radioactive waste disposal. A disposal license is required since some of the NORM/TENORM waste in Colorado is licensed by CDPHE. The license application does not extend to byproduct or source material, and thus does not include the broader categories found in Class A radioactive waste. The license application requires the establishment of a radiation protection program, assuring that all NORM/TENORM waste, even non-licensed waste disposed under RCRA, will have appropriate radiological controls for workers, the public, and the environment. Because Deer Trail is a RCRA Subtitle C facility with an active RCRA Permit and because of the overlapping and similar requirements in the process to obtain either a RCRA permit or a radioactive waste disposal license, the license process for Deer Trail was appropriately focused. This focusing was accomplished by working with the Colorado Department of Public Health and Environment (CDPHE) and excluding or waiving selected radioactive materials license requirements from further consideration because they were found to be adequately addressed under the RCRA Permit. Of most significance, these requirements included: - Institutional Information - Federal or State ownership will not be required, since the State's Radiation Control regulations allow for private site ownership, consistent with the same financial assurance and institutional control requirements of RCRA. - Development of Additional Technical Information, Including an Environmental Impact Assessment - since the site has been through the RCRA site selection and permit process. - Intruder Analyses - because of the low NORM/TENORM waste concentrations to be encountered and because of RCRA site closure requirements. The results of the waste acceptance criteria analysis included in the license application recommended that the total activity of NORM/TENORM waste, including the alpha and bet a emitting radionuclides, be enforced to the limit of 74 Bq/g (2,000 pCi/g), which is also used to define radioactive waste in Colorado, as long as a radium concentration limit of 15 Bq/g (400 pCi/g) is also maintained. A Radiation Protection Plan set of Standard Operating Procedures was developed and submitted as part of the license application. These procedures cover the mandatory worker training program, the various types of radiation surveys that will be conducted during operations, the required records and reporting, and waste tracking and disposal operations. All NORM/TENORM waste must also meet the RCRA waste acceptance criteria for the landfill, thus assuring that there will be no incompatibilities with waste forms, waste chemistry, or other waste co-mingling issues. On June 8, 2005, the Rocky Mountain Low Level Waste Compact approved the disposal of radium contaminated waste from a Denver Superfund site at Deer Trail. The specific waste in question was identified as radioactive waste designated by Colorado as requiring disposal under the rules of the regional compact. On August 26, 2005, the CDPHE issued the final draft radioactive materials license for disposal of NORM/TENORM waste at Deer Trail for a 60-day public comment period. The final license was issued on December 21, 2005. Once Clean Harbors has successfully demonstrated that all of the license conditions are met, the site will be authorized to receive waste. This paper provides a discussion of the status of the license, its conditions, and the regulatory process followed to obtain the license. (authors)
- Research Organization:
- WM Symposia, Inc., PO Box 13023, Tucson, AZ, 85732-3023 (United States)
- OSTI ID:
- 21210725
- Report Number(s):
- INIS-US-09-WM-06464; TRN: US09V1153081187
- Resource Relation:
- Conference: Waste Management 2006 Symposium - WM'06 - Global Accomplishments in Environmental and Radioactive Waste Management: Education and Opportunity for the Next Generation of Waste Management Professionals, Tucson, AZ (United States), 26 Feb - 2 Mar 2006; Other Information: Country of input: France; 15 refs
- Country of Publication:
- United States
- Language:
- English
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