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HomeMy WebLinkAboutDSHW-2024-009522HAZ-RAD REPORTER ANNUAL NEWSLETTER • DECEMBER 2024 Division of Waste Management and Radiation Control PAGE 1 A Message from the Director DOUG HANSEN For example, the day I started work at the State, my desktop computer monitor was a monochrome amber cathode ray tube (CRT). I had access to an email account, but the internet was strictly off limits as it would only serve as a distraction to the work at hand and could never prove useful or productive. Correspondence was still treated as if clerical staff worked on typewriters. Paper copies of draft letters were supplied and re-typed into a Word Perfect file before editing, printing, and mailing. As I enter my thirtieth year of state government service, I can’t help but reflect on the differences from my first years until now. So much of the work we do is more efficient, largely as a result of the incorporation of technology into the daily work we do. In This Issue: 3 5 6 8 9 10 12 13 15 17 18 19 20 Hazardous Waste Section Used Oil & Outreach Section Interactive Maps Uranium Recovery Section X-Ray Section Low Level Radioactive Waste Corrective Action Section New DWMRC Employees In Memory of Otis Willoughby DWMRC Email List Solid Waste Section Small Business Envir. Assistance Division Reorganization PAGE 2 A Message from the Director (cont.) At the time, these processes felt like a major improvement compared to processes of just a handful of years earlier when routine letters used literal boilerplate forms where blank fields were filled in through use of an IBM Selectric typewriter. Now so many of our processes are automated internally and our customers can transact most business with us online. The pace of work has changed as well. Some of us remember a time when the work year was divided into distinct seasons consisting of field work preparation (spring), field work and inspection season (summer and fall), and paperwork and catch up season (winter). Those days are long past. Now the volume of permitting and licensing actions, the number of facilities with permits and licenses, and the general support we as a division continuously provide to stakeholders in industry, the public, and government organizations ensures a constant, dynamic workload throughout the year. The increased access to government and the efficiencies realized through technological resources have assisted us in keeping pace with growing needs within the state. With that constant demand and the variety of programs housed within the Division of Waste Management and Radiation Control, I am continually surprised at the range of challenges and opportunities that arise. I honestly don’t know what interesting work awaits me when I walk through the doors of my office each day. The best part of all of it though is the people I get to work with, whether it’s our amazing division staff, elected officials, industry representatives, or the interested public. My thanks to all who care deeply about safely managing the materials that are critical for a prosperous, modern society. DOUG HANSEN Hazardous Waste Section PAGE 3 Hazardous Waste Permit applications and Drum Top Lamp Crusher registrations can now be submitted online through the Community Portal. Instructions can be found at: https://deq.utah.gov/waste-management-and-radiation-control/hazardous-waste-management- program BY THOMAS WELBY X-ray registrants can submit new applications, view the status of an application, submit changes to issued registrations, and renew registrations. Instructions can be found at: https://deq.utah.gov/waste-management-and-radiation-control/x-ray-program Solid waste facility reporting, including permitted recycling facilities and waste tire facilities, is now conducted through the Community Portal. Instructions for Solid Waste program registrations can be found at: https://deq.utah.gov/waste-management-and-radiation- control/forms-division-of-waste-management-and- radiation-control Community Portal Are you a small quantity generator (SQG) of hazardous waste (i.e., a producer of between 220 and 2,200 lbs of non-acute hazardous waste per month)? SQGs in Utah are now required to re-notify every four years. To remain in compliance with this requirement, you need to submit your updated Notification of RCRA Subtitle C Activities (Site Identification Form), also known as EPA Form 8700-12. The re-notification is due by September 1, 2025. Renotification for Small Quantity Generators due September 1, 2025 Instructions can be found at: https://rcrapublic.epa.gov/rcrainfoweb/document s/rcra_subtitleC_forms_and_instructions.pdf The Hazardous Waste Section will be hosting a two-day virtual training session for hazardous waste generators May 14-15, 2025. For recordings of previous trainings, visit: https://deq.utah.gov/waste- management-and-radiation- control/hazardous-waste-management- program Hazardous Waste and Used Oil Training Used Oil Section hosted a day-long virtual training on October 2024. For recordings of previous trainings, visit: https://deq.utah.gov/waste-management- and-radiation-control/outreach-and- training-used-oil-program In October, the Utah Test and Training Range (UTTR) was issued a 10-year renewal of their RCRA Part B operating permit. The Division worked closely with UTTR, the Department of Defense, and EPA Region 8 to revise language regarding Open Burn and Open Detonation (OB/OD) Alternative Technology reporting requirements. Additionally, language was revised to reflect the closure of Landfill 5 in 2023. On March 20, 2024, the EPA published a proposed rulemaking regarding the OB/OD standards, which the Division provided comments on. As EPA works on finalization of this rulemaking, the Division will continue to work closely with our OB/OD facilities and the EPA to support the facilities' operations and ensure protection of human health and the environment. Hazardous Waste Section PAGE 4 BY GABRIELLE MARINICK, JUDITH MORAN, AND THOMAS WELBY Utah Test and Training Range Permit Renewal Adam Wingate and Gabby Marinick at UTTR Open Detonation Site E-Manifest Registration for Small and Large Quantity Generators Beginning January 22, 2025, Large and Small Quantity Generators (LQGs and SQGs) are required to register and maintain an account on e-Manifest to access final signed manifests from receiving facilities, submit post-receipt data corrections requested by regulators, and (beginning December 1, 2025), submit exception reports electronically via e-Manifest. For information, visit: EPA.GOV/E-MANIFEST 1. Lack of Department of Transportation Awareness Training Employees signing hazardous waste manifests must receive Department of Transportation (DOT) awareness training every three years. 2. Failing to Make a Waste Determination Generators must make a hazardous waste determination for each solid waste at the point of generation. 3.Partially Used Aerosol Cans in the Garbage Aerosol cans must be punctured or completely empty before disposal in trash. Partially full aerosol containers can be sent for disposal as universal waste. 3 Common Issues for Hazardous Waste Generators PAGE 5 Interactive Maps Environmental Interactive Map With the Interactive Map, users can locate Hazardous Waste and Used Oil Facilities Low Level Waste Disposal and Uranium Mills Solid Waste Facilities Users can also find information on Air Quality Drinking Water Enhanced Health Indicators Environmental Response & Remediation Water Quality Access the map at: https://enviro.deq.utah.gov/ Recycling & Waste Facility Map DWMRC’s new interactive recycling map can help you find recycling, solid waste facilities and used oil collection centers near you. Filter by facility type and county to find local sites’ contact information, collection statistics and more! Contact the Division at (801) 536-0200 to put your business on the recycling map and increase foot traffic to your business. Access the map at: https://recycle.utah.gov/ BY THOMAS WELBY In July 2024, the Waste Management and Radiation Control Board approved amendments to both Utah Admin. Code sections R313-17 and R313-24. Under R313, part of the review of a major licensing action is an environmental review. The licensee is required to complete an Environmental Report (ER), which gathers data on the potential environmental impacts of the licensing action, and the Division completes an Environmental Analysis (EA) on these data. The rules were updated to provide additional clarity on what licensing actions would count as major licensing actions (and therefore require an ER / EA), and to clarify the required contents of the ER and EA. Utah Admin. Code Section R313-17 was modified to clarify when “a change in engineering design, construction, or process controls” would count as a major license action. Language was also added to require Alternate Feed requests be major licensing actions. Section R313-24 was significantly overhauled. R313-24-3 now provides additional information on construction at Uranium Mills, R313-24-4 lists minimum requirements for the ER, and R313- 24-5 now lists the minimum requirements for the EA. Current copies of all Utah Administrative Codes are available at https://adminrules.utah.gov/public/search//Current%20Rules. Uranium Recovery Section PAGE 6 Rule Update: Uranium Recovery Reporting and Assessment Process BY ADAM WINGATE Uranium Ore The Shootaring Canyon Uranium Mill is located in Garfield County, 50 miles south of Hanksville, 14 miles north of Bullfrog Basin Marina, and 2 miles west of Utah State Highway 276. Originally constructed by Plateau Resources between 1978 and 1981, it began operations in 1982 and operated for 76 days. In 1983 it officially entered stand-by mode and has been in stand-by mode ever since. The Mill has had several different owners throughout its life, including Plateau Resources, US Energy, and Uranium One. Anfield Resources purchased the Mill from Uranium One in 2015. Despite entering stand-by over 40 years ago and multiple changes in ownership, the Mill has maintained a Radioactive Materials License. This year, two major licensing actions have occurred, which could potentially put the Mill on track to restart operations. First, in April, Anfield Resources submitted an application to the Division to renew the Radioactive Material License, exit stand-by, and resume operations. Facilities at the Mill have largely not been updated since 1983, so a considerable amount of work will be required to bring the Mill up to modern standards, but the application to renew is the first step in completing the required renovations. Uranium Recovery Section PAGE 7 New Life and New Ownership at Shootaring Canyon Uranium Mill BY ADAM WINGATE Then, in October 2024, the Division received notice that the Canadian company IsoEnergy intends to acquire Anfield Resources and all of its assets, including the Shootaring Canyon Mill. The Division has paused its review of the renewal application until the transfer of control has been reviewed and finalized, but IsoEnergy has indicated that it intends to continue with the renewal and hopefully resume operations as soon as possible. Aerial photo of Shootaring Canyon Uranium Mill PAGE 8 Let me know if you have questions about air, water, or hazardous waste permits To contact me please call 801-536-0091 or email: edivver@utah.gov Small Business Environmental Assistance BY ELEANOR DIVVER Hello. My name is Eleanor and I am Utah’s DEQ Small Business Environmental Assistance Program Coordinator/Ombudsman. SBEAP is a free, confidential and non-regulatory program designed to assist businesses with Environmental permitting. SMALL BUSINESS ENVIRONMENTAL ASSISTANCE PROGRAM (SBEAP) SBEAP also: Advocates on behalf of small businesses Assists with communication between your small business and DEQ Offers permitting assistance Provides workshops, webinars, and trainings Mails out informational and informative printings upon request For more information, visit the SBEAP website at: https://deq.utah.gov/sbeap/small-business- environmental-assistance-program What are engineering controls and how do I practice it at my facility?QUESTION: Engineering controls are methods designed to remove hazards at the source, before it comes in contact with the worker. The initial cost of engineering controls can be high, but the long-term operating costs are frequently lower and can sometimes provide cost savings. Common engineering controls include: Installing guardrails and proper lighting to prevent falls Limiting workers to exposure of hazardous chemicals via proper ventilation Separation of hazardous chemicals into different storage areas Using air conditioners and heaters to combat extreme temperatures Installing noise absorption panels to dampen high noise levels Improved fire detection and suppression systems ANSWER: ASK ELEANOR Administered properly, radiation from x-ray equipment is an invaluable tool in the diagnosis, treatment and management of disease. X-rays have also become an invaluable tool in industrial settings for non-invasive package inspections, mineral and food quality inspections, and manufacturing. However, radiation from x-ray equipment can be harmful or even deadly if administered or used incorrectly. The use of radiation in medicine may be one of the most difficult areas for ensuring a balance between risk and benefit. The State of Utah x-ray program strives to ensure each patient exposed to x-ray radiation receives high quality medical care with the lowest dose of radiation possible. Operators of x-ray equipment designed for human use must meet the State’s Division of Occupational and Professional Licensing requirements. Utah x-ray program inspectors test x-ray equipment to ensure that they operate within allowed limits and verify operators are trained and licensed to use x-ray equipment safely. Appropriate training and equipment operation results in better quality images with fewer repeated x-ray procedures and lower overall doses of radiation. There are 2,924 facilities in Utah with over 11,000 registered x-ray machines. These facilities include medical and industrial facilities such as: Chiropractors Dentists Veterinarians Hospitals Mining Manufacturing Food processing Defense contractors X-ray program staff are knowledgeable in the use of x-rays and the requirements found in R313. The division also uses Qualified Experts to measure regulatory parameters on radiation machines, evaluate radiation safety programs, evaluate radiation levels, and give advice on radiation protection needs. They are not employees or representatives of the Division or the State but they have been authorized to conduct inspections, review floor plans, shielding specifications and equipment arrangement of installations utilizing ionizing radiation. X-ray Section PAGE 9 Why Does Utah Require X-ray Equipment to be Registered? BY TOM BALL The Division began a waste characterization study this year that will continue through 2025. The waste characterization study is being conducted by a contractor and will include onsite activities at landfills and a survey of individuals and companies, along with scholarly research to determine opportunities for reduction, reuse, and recycling in Utah. Solid Waste Section PAGE 10 BY BRIAN SPEER Waste Characterization Study The contractor is conducting onsite visits at 28 of the 33 municipal solid waste landfills in the state. While onsite, the contractor sorts incoming waste into various material types, weighing each type. The onsite waste characterization will help us understand the portion of the waste stream made up by various materials that could potentially be reduced, reused, or recycled. In addition to the onsite waste characterization, the contractor will survey individuals and companies in the state and conduct research to understand potential opportunities. The study will improve awareness of the material types being disposed of, reused, or recycled, as well as identify methods that may currently be underutilized in market regions throughout the state. Data from the study will provide a better understanding of the perceived and actual social and economic support for sustainable materials management in Utah. The contractor will complete a report of the findings, and the report will be utilized to update the Utah Solid Waste Management Plan. This plan is required by state law and the update will discuss the state's ability to minimize waste and recycle. With the update, we hope to develop a sustainable materials management strategy for consideration by policymakers, to improve reduction, reuse, and recycling of waste materials. The strategy is intended to prioritize recommendations based on the greatest potential benefit to community health, the environment, and the economy. Waste Characterization Utah is the 10th highest oil-producing state in the nation, and waste generated by the industry in the state has historically been regulated by the Utah Division of Oil, Gas, and Mining (DOGM). Over the last three years, the Solid Waste Section has been in close coordination with DOGM to transition the regulatory oversight of Exploration and Production (E&P) waste facilities to our Division in answer to a legislative change. This transition has resulted in two new solid waste rules, Utah Admin. Code R315-321, Class VII Exploration and Production Waste Landfill Requirements, and Utah Admin. Code R315-322, Solid Waste Surface Impoundment Requirements. The first of these provides protective standards to regulate exploration, development, and production waste from the oil and gas industry. The second rule will apply to any nonhazardous waste management facility that is required to have a permit from the Division and accepts high-liquid waste into a surface impoundment. During the rulemaking process, an informal comment period was open to the oil and gas industry beginning in March. The formal rulemaking comment period opened on August 1, 2024. Comments received were responded to and can be found in the Waste Management and Radiation Control Board’s archived meeting packet for October 10, 2024. This is available at: https://deq.utah.gov/category/waste-management-and-radiation-control/waste-management- and-radiation-control-board-archive For details on the rule changes, visit: https://deq.utah.gov/waste-management-and-radiation-control/e-and-p-waste-management Solid Waste Section PAGE 11 BY BRIAN SPEER Exploration & Production Waste and Surface Impoundments E&P Waste LandfillSurface Impoundment This year came to an exciting conclusion for the LLRW section with the completion of a section- wide project two and a half years in the making. On October 15, 2024, the new East Side Rotary Facility (ESRF) at the Energy Clive site was put into service. The ESRF facility is designed to roll or remove radioactive waste from rail cars for placement into haul trucks which transport waste to the cell for disposal. The addition of this new facility is critical to Energy operations to increase in the waste management capacity at the Clive site. Completion of this project required the efforts of the entire LLRW section in the design of the facility, facility construction, and implementation of operational procedures, including modifications to the Energy Ground Water Quality Discharge Permit and an amendment to the Energy Radioactive Materials License. Low Level Radioactive Waste (LLRW) Section BY BAILEY ANDERSON East Side Rollover Facility (ESRF) PAGE 12 East Side Rotary Facility at Energy Clive 3/25/2021 6/23/2021 4/27/2022 4/24/2023 10/15/2024 East Side Rotary Facility Timeline Request for Modification, Proposal to construct East Side Rotary Facility Request for Modification, Proposal to construct the East Side Rotary Facility Radioactive Material License UT2300249, Conditional Approval East Side Rotary Construction Area Survey Release Report Condition 48.C - East Side Rotary Facility As Built Report RML 249 (Amendment 28) and modifications to GWQDP UGW450005 approved by Doug Hansen, Director of DWMRC East Side Rotary The Corrective Action Section will be undergoing a rebranding this year. This fall, the United States Environmental Protection Agency (USEPA) announced that the “Resource Conservation and Recovery Act (RCRA) Corrective Action Program” will become the “Hazardous Waste Cleanup Program.” The term “corrective action” refers to the cleanup of hazardous waste and constituents. The Division will also be renaming the “Corrective Action Section” to the “Hazardous Waste Cleanup Program”. We hope the new name will make the purpose of our program more transparent. Corrective Action Section PAGE 13 Hazardous Waste Cleanup Program BY PAIGE WALTON An update to the Division’s “Technical Guidance for Risk Assessment: Utah Administrative Code R315-101 (TGRA)” was released in May of this year. The guidance provides focused direction on how to complete human health and ecological risk assessments. One of the major changes to risk assessment this year was the USEPA updating the residential levels for lead contamination in soil. The Division updated to TGRA to address the new soil lead guidance for residents. Looking forward to early 2025, updates to the TGRA will include checklists to assist in ensuring risk assessments include all the required components outlined in Utah Admin. Code R315-101. Additional updates will include more information on how to ensure representative sampling. The TGRA contains a summary of changes for easy tracking of updates. An update to the Contained-Out policy will also be updated soon. The updated guidance provides a more streamlined approach to determining when a contained-out may be appropriate and how to apply for the determination. Links to the TGRA, Contained-Out policy, and other guidance and templates are found at: https://deq.utah.gov/waste-management-and-radiation-control/environmental-cleanup- program Guidance and Risk Assessment PFAS Regulations One of the many questions we received this year was regarding per- and polyfluoroalkyl substances (PFAS). In February of this year, the USEPA proposed regulations adding nine PFAS compounds as hazardous constituents listed in 40 Code of Federal Regulations (CFR) Part 261 Appendix VIII. It is estimated that the regulations will become effective in 2025. Once promulgated, the Division will regulate PFAS as hazardous constituents and may require PFAS to be addressed in site investigations and cleanup actions. The Section worked on over 40 Environmental Cleanup Program (ECP) sites this year, assisting in environmental investigations, remediation, and promoting revitalization efforts for hazardous waste sites across Utah. An exciting change for the Section is that ECP sites are now eligible to apply for the Revolving Loan Funds managed by Salt Lake County Office of Regional Development and governed by the Wasatch Brownfields Coalition Board. More information on this fund is available at https://www.saltlakecounty.gov/regional- development/economic-development/ As part of improvements to the ECP process, updates to the Comfort Letter Request Forms and Environmental Covenant Templates were conducted. These updated documents are available on our website at: https://deq.utah.gov/waste-management-and- radiation-control/environmental-cleanup- program PAGE 14 Environmental Cleanup Program BY PAIGE WALTON Post Remediation and Re-Development (Photo credit: Jasin Olsen) Active Investigation and Remediation (Photo credit: Jasin Olsen) Corrective Action Section Staff (Photo credit: Paige Walton) Section members presented at City Council meetings, technical conferences, participated in public meetings and interviews, continuing to ensure the public understands our commitment to protection of human health and the environment and ensure access to information on sites in their neighborhoods. Corrective Action Section Used Oil & Outreach Section BY LEONARDO CALCAGNOUsed Oil and Utah Farms & Dairies PAGE 15 Transporters 14,732,896 gallons Transfer & Processor Facilities13,662,094 gallons UOCCs223,944 gallons Transfer and Processor facilities Transporters UOCCs 2022 20230 5000000 10000000 15000000 20000000 25000000 30000000 PAGE 16 Used Oil & Outreach Section BY LEO CALCAGNO Gallons of Used Oil Collected Per Year Used Oil Collected 2023 Used Oil Collection Centers NEW DWMRC EMPLOYEES LEXI ADAMS HAZARDOUS WASTE The Division Welcomed 8 New Employees in 2024! BEATRIZ AVILA SOLID WASTE NATHAN NICOLODEMOS SOLID WASTE INVA BRAHA LLRW JORDAN PAYNE HAZARDOUS WASTE ETHAN UPTON CORRECTIVE ACTION PAGE 17 ANDREW ZEHR LLRW THOMAS WELBY HAZARDOUS WASTE The Radioactive Materials (RAM) and Uranium Mill section has been split into two sections. Phil Goble continues to manage the RAM section, and Adam Wingate became the Uranium Recovery section manager in February 2024. Adam was previously an Environmental Engineer in the Hazardous Waste section. The Hazardous Waste and Used Oil section has been split into two sections. Deborah Ng continues to manage the Hazardous Waste section, and Ted Sonnenburg became the Used Oil and Outreach section manager Division Reorganization PAGE 18 Division Reorganization BY ADAM WINGATE AND DEBORAH NG PHILLIP GOBLE RADIOACTIVE MATERIALS ADAM WINGATE URANIUM RECOVERY DEBORAH NG HAZARDOUS WASTE TED SONNENBURG USED OIL & OUTREACH 2024 DWMRC Employee Retirement Boyd Swenson was a dedicated DEQ employee for 38 years and served under five different Division Directors. During his career with the Division, he was a lead project engineer on Clean Harbors Aragonite and Safety Kleen and supported other facilities such as Tooele Chemical Demilitarization Facility (TOCDF), EnergySolutions, Clean Harbors Grassy Mountain, Hill Airforce Base, and Utah Test and Training Range. Boyd was considered the Division technical expert on Permitting and Financial Assurance issues. Boyd is well respected by his peers, management, and the regulated community for his fairness and willingness to find solutions. Happy Retirement Boyd! BOYD SWENSON HAZARDOUS WASTEHappy Retirement! DAVID EDWARDS LLRW Our friend and colleague Otis Willoughby passed away June 29, 2024. He was a valuable member of the Division for over 34 years and worked in many programs, most recently he was the manager of the Low Level Radioactive Waste Section. Otis’ positive outlook and sincere interest in the people he worked with both internally and externally was admired. He loved to connect with experiences and was always ready to talk about hiking, woodworking, biking, world adventures and most recently building boats. Our time with him was memorable and as Otis said “Don’t let the things you can’t do, get in the way of the things you can do”. OTIS WILLOUGHBY LOW LEVEL RADIOACTIVE WASTE In Loving Memory of Otis Willoughby PAGE 19 BY JALYNN KNUDSEN Doug Hansen, Division Director Kelly Pingree, Facilities Coordinator Stevie Norcross, PhD, Assistant Director Jalynn Knudsen, Assistant Director Adam Wingate, Uranium Recovery Program Manager Deborah Ng, Hazardous Waste Program Manager Paige Walton, Corrective Action Program Manager Larry Kellum, Low Level Radioactive Waste Program Manager Brian Speer, Solid Waste Program Manager Tom Ball, X-Ray and Technical Support Section Manager Eleanor Divver, Small Business Environmental Assistance Program (SBEAP) Leonardo Calcagno, Used Oil Rachel Boyer, Used Oil Bailey Anderson, Low Level Radioactive Waste Gabrielle Marinick, Hazardous Waste Judith Moran, Hazardous Waste Kari Lundeen, Hazardous Waste Thomas Welby, Editor, Hazardous Waste PAGE 20 Stay informed on the latest Solid Waste, Hazardous Waste, or Used Oil activities by signing up for our email list, at deq.utah.gov/communication/email-alerts! Select your area of interest to receive notices on topics including: permit actions, closure and clean-up decisions, site management plans, rule changes, Waste Management and Radiation Control Board agendas and public comment periods/public hearings. You can also sign up for email notices regarding Air Quality, Water Quality, or other public participation activities. Division of Waste Management and Radiation Control Mailing List Newsletter Contributors Questions? Contact Us! P.O. Box 144880 Salt Lake City, UT 84114-4880 (801) 536-0200 Submit electronic documents via email at DWMRCsubmit@utah.gov