DATE:
October
7,
2003
PARTICIPANTS:
Bill
Fortune
(
DOE),
Jerry
Coalgate
(
DOE),
Richard
Martin
(
DOE­
Oak
Ridge),
Nancy
Dailey
(
ORNL),
Paul
Taylor
(
ORNL),
Phil
Kirkham
(
ORNL),
Laura
Coughlan
(
EPA)
and
Lisa
Lauer
(
EPA)

SUBJECT:
Conference
call
between
EPA
staff
and
DOE
representatives
concerning
DOE's
comment
regarding
the
proposed
addition
of
benzene
to
the
headworks
exemption
with
the
contingent
management
practices.

The
purpose
of
the
call
was
to
gain
a
better
understanding
of
Oak
Ridge
National
Laboratory's
(
ORNL)
wastewater
treatment
system.
The
ORNL
WWTU
system
was
the
focus
of
certain
comments
submitted
by
the
Department
of
Energy
(
DOE).
In
the
comments,
DOE
requested
that
EPA
reconsider
the
proposed
condition
that
mixtures
containing
benzene
must
be
managed
only
in
aerated
biological
wastewater
treatment
systems,
and
allow
benzene
to
be
discharged
to
the
headworks
of
wastewater
treatment
units
(
WWTU)
(
at
the
1ppm
total
headworks
limit)
as
is
allowed
for
the
other
solvents
listed
in
§
261.3(
a)(
2)(
iv)(
A)
(
Document
ID#
RCRA­
2002­
0028­
0117).
DOE
stated
in
the
comments
that
ORNL's
WWTU
uses
a
combination
of
air
strippers
and
granular
activated
carbon
columns
to
remove
organic
compounds,
and
that
this
treatment
system
is
as
effective
as
an
aerated
biological
treatment
unit.

During
the
phone
discussion,
DOE
representatives
described
the
ORNL
WWTU
in
more
detail
(
see
attached
fax
of
simplified
flow
diagram).
Wastewater
is
first
filtered
for
any
solids
and
minerals
are
removed
through
precipitation.
The
sludge
produced
from
this
clarification
is
disposed
of
as
solid
low­
level
waste.
After
clarification,
the
wastewater
is
air
stripped
of
volatile
organic
compounds,
the
resulting
air
stream
is
emitted
directly
to
the
atmosphere,
and
the
resulting
water
effluent
is
sent
through
activated
carbon
to
adsorb
any
remaining
contaminants
prior
to
discharging
into
the
White
Oak
Creek.
The
activated
carbon
is
also
disposed
commercially.
The
DOE
representatives
explained
that,
while
the
ORNL
site
is
a
large
quantity
generator
of
RCRA
waste,
the
facility
currently
prohibits
the
routine
discharge
of
any
listed
wastes
into
the
wastewater
treatment
system
and
generally
has
very
low
levels
of
organic
compounds
entering
their
WWTU.
Therefore,
the
wastewater
and
resulting
solids
of
the
treatment
process
are
not
hazardous
wastes.
The
DOE
representatives
also
stated
that
ORNL
currently
has
no
streams
targeted
for
the
proposed
headworks
exemption,
and
does
not
presently
foresee
using
the
headworks
exemption
on
any
particular
waste
streams
at
the
facility.
The
DOE
representatives
stated
that
the
primary
purpose
of
their
comments
regarding
the
removal
of
the
contingent
management
requirements
was
to
ascertain
why
EPA
was
being
restrictive
with
respect
to
the
type
of
waste
treatment
units
that
are
acceptable.
In
addition,
DOE
representative
explained
that
a
secondary
concern
relates
to
the
nature
of
the
ORNL
facility.
The
ORNL
is
a
multi­
program
science
and
technology
laboratory
with
numerous
individual
labs
and
research
activities
with
changing
missions
and
research
priorities.
Consequently,
future
lab
activities/
efforts
could
potentially
result
in
small
volumes
of
other
chemical
constituents
entering
the
wastewater
system
(
that
could
be
effectively
handled
by
the
WWTU).

In
response,
the
EPA
staff
explained
that
the
restrictions
were
a
direct
result
of
the
risk
modeling
conducted
for
the
proposed
rule.
The
DOE
representatives
suggested
that
EPA
add
regulatory
language
that
would
allow
aerated
biological
treatment
or
an
equivalent
method
to
be
used
to
qualify
for
the
exemption.
The
EPA
staff
stated
that
additional
modeling
would
be
needed
if
such
language
were
added,
since
only
the
most
common
treatment
technology
currently
used
by
facilities
to
treat
these
wastes,
biological
treatment,
was
modeled.
The
DOE
representatives
questioned
the
need
for
additional
modeling
(
i.
e.,
in
order
to
incorporate
such
regulatory
language),
and
indicated
that
maybe
something
similar
to
the
land
disposal
restrictions
(
LDR)
demonstration
of
equivalent
treatment
could
be
considered.
