Background

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The U.S. Department of Energy’s (DOE) Sandia National Laboratories (SNL or Sandia) in Albuquerque, New Mexico had an expensive waste cleanup problem. Historic bomb testing on the desert hinterlands of Kirtland Air Force Base behind Sandia had created approximately 45,000 cubic meters of contaminated soil, waste, and debris. Superfund required that it be cleaned up. To comply with Superfund at Sandia, DOE created an Environmental Restoration (ER) Program. ​

 

Meanwhile in Washington, Congress had amended the nations’ hazardous waste management and disposal law, the Resource Conservation and Recovery Act (RCRA), to require all hazardous waste (whether it be generated fresh off the factory floor or excavated by Superfund type clean up) to be treated in high temperature incinerators before being placed in the ground in a RCRA Subtitle C landfill for ultimate disposal.

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Assessment

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However, Smith and his colleague M.J. Davis at SAIC had determined that excavation, off-site transportation, and incineration of Sandia’s 45,000 cubic meters of cleanup waste was not practical or affordable. Most of the waste to be shipped off to be incinerated would be very slightly contaminated soil and water. So expensive was the incineration option that just Sandia’s site, the 29,000 cubic meters CWL, would cost $32 to transport and incinerate.

 

Smith did his research into RCRA corrective action regulations and found that EPA headquarters allowed industries conducting corrective action on hazardous waste mismanagement to use a on-site Corrective Action Management Unit (CAMU). Smith talked to his contacts at EPA and got headquarters’ blessing. Then Smith took his proposal to Sandia management: the idea was use the CAMU option at Sandia before the land disposal ban’s blunt force deadlines made the best option - the CAMU option - impossible.

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Solution

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Smith’s got Sandia management approval. Next Smith went to EPA Region 6 in Dallas, told them of headquarters’ blessing and explained how the CAMU would clean up the environment to the same level but would actually be safer than transporting all that waste off site for incineration. Rail and truck accidents happen. Region 6 approved. Last Smith took the plan to the New Mexico Environment Department (NMED) and began forming a Citizens Advisory Board to get a local approval and feedback method in place. Smith got local approval by explaining how treating and disposing the ER waste onsite at the CAMU would create many well- paying local, long term jobs (e.g., onsite construction and management of the CAMU for decades to come. ​

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Implementation

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Smith prepared the first of several permit modifications to Sandia’s RCRA permit so the CAMU could be built. Next, DOE, which funds Sandia, put a Request for Proposals for the CAMU implementation and construction contract (competitive bidding). Unfortunately for Smith, SAIC teamed with a company that had built a CAMU before. It was Smith’s to win, but another company won the contract. Smith gracefully stepped away and continued to make himself available for advice or advocacy concerning the CAMU when needed.

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NAICS codes: 541620, 541621.7, 541621.3