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Hazardous waste permit reissued

In a public notice posted on its website last week, the Tennessee Department of Environment and Conservation (TDEC), Division of Solid Waste Management (DSWM), announced it had decided to reissue a hazardous waste management permit to Nuclear Fuel Services, Inc. (NFS).
According to the DSWM public notice, the reissued permit, which is TNHW-157 (formerly TNHW-108), “is for the container storage of mixed (hazardous and radioactive) waste in Building 310 Warehouse.”
“There is no increase in the 140-cubic-yard (28,276-gallon) capacity,” the DSWM public notice states. “The types of mixed waste allow have been reduced from 12 to three.”
The DSWM previously reported that the only three hazardous wastes allowed under the reissued permit are lead, mercury and pyridine.
The reissued permit also includes corrective action conditions for the solid waste management units at the Erwin facility.
“NFS is required to investigate any release of hazardous waste or hazardous constituents at the facility, regardless of when waste was placed in a unit, and to take appropriate corrective action,” the public notice states. “This permit also approves a no further action remedy for SWMU 10, Demolition Landfill, as all wastes and contaminated soils were shipped off-site. The permit conditions require NFS to notify DSWM of imminent hazards and to comply with the requirements developed under land disposal restrictions and organic air emission standards when applicable.”
“We are pleased that the Tennessee Department of Environment and Conservation renewed our permit after its review process,” NFS Media and Communications Managing Advisor Karen F. Randall said in an email to The Erwin Record. “Nuclear Fuel Services is committed to responsible environmental stewardship.”
NFS’s previous hazardous waste management permit was issued on Sept. 30, 2002 and was set to expire in September 2012.
“NFS submitted their permit renewal application to DSWM on March 28, 2012, six months before the expirations date, thus enabling the facility to continue to operate under the current permit until a final decision is made on the renewal application,” a press release issued by TDEC in July 2014 said.
This press release also announced the date and time of a public hearing to be held in Erwin on Aug. 26, as well as a 45-day public comment period on the permit, which ended on Aug. 26. According to the public notice from the DSWM, during the public hearing and the public comment period the DSWM received several comments, both written and oral, regarding the permit application.
One of the comments, which is included in the DSWM public notice, asked if TDEC performs unannounced inspections, how many and when, and if the inspections are performed on Building 310 Warehouse?
“All DSWM inspections to evaluate compliance with the hazardous waste storage permit and hazardous waste, used oil, and universal generator standards of Rule 0400-12-01 are unannounced,” the public notice states. “EPA grant commitments only require the DSWM to inspect NFS every two years. Since the existing permit was issued on Sept. 30, 2002, the DSWM conducted inspections in 2002, 2003, 2004, 2005, 2007, 2009, 2010, 2011, 2013 and 2014. Normally inspections are conducted on an annual basis. DWSM staff does have access to Building 310 and they physically see the hazardous waste in storage.”
Included in the public notice is a summary of the DSWM inspections at NFS since 2002. According to this information, from 2002 to 2005 no violations were identified at NFS at the time of inspection.
In May 2007, according to the public notice, a “notice of violation” was issued. This involved an open 5-gallon bucket of universal waste and for an open container of hazardous waste.
“The universal waste container violation was corrected at the time of the inspection,” the notice states. “A follow up inspection was conducted on June 12, 2007, and the open hazardous waste container violation had been corrected.”
No violations were reported from 2009 to 2011.
During an inspection in July 2013, a notice of violation was issued by the DSWM to NFS “for exceeding the 1-year accumulation time for six boxes of universal waste fluorescent tubes.” According to the notice, this violation had been corrected when a follow inspection took place in September 2013.
Another notice of violation was issued to NFS in July 2014 “for one 55-gallon drum not being labeled ‘Hazardous Waste’ and not having an accumulation state date.” The results of the follow up inspection regarding this event were not published in the public notice. The follow up was scheduled to take place after Aug. 25, 2014.
The public is invited to review the reissued permit and the response to comments. Copies are available at the Johnson City Public Library, 100 West Millard St., and at the Unicoi County Public Library, 201 Nolichucky Ave., Erwin. Copies are also available at the TDEC Johnson City Environmental Field Office, Public Access Area, 2305 Silverdale Road, Johnson City.