Independent review of inappropriate identification, storage and treatment methods of polychlorinated biphenyl waste streams

The purpose of the review was to evaluate incidents involving the inappropriate identification, storage, and treatment methods associated with polychlorinated biphenyl (PCB) waste streams originating from the V-tank system at the Test Area North (TAN). The team was instructed to perform a comprehensive review of Lockheed Martin Idaho Technologies Company (LMITCO`s) compliance programs related to these incidents to assess the adequacy and effectiveness of the management program in all respects including: adequacy of the waste management program in meeting all LMITCO requirements and regulations; adequacy of policies, plans, and procedures in addressing and implementing all federal and state requirements and regulations; and compliance status of LMITCO, LMITCO contract team members, and LMITCO contract/team member subcontractor personnel with established PCB management policies, plans, and procedures. The V-Tanks are part of an intermediate waste disposal system and are located at the Technical Support Facility (TSF) at TAN at the Idaho National Engineering and Environmental Laboratory (INEEL). The IRT evaluated how a waste was characterized, managed, and information was documented; however, they did not take control of wastes or ensure followup was performed on all waste streams that may have been generated from the V-Tanks. The team has also subsequently learned that the Environmental Restoration (ER) program is revising the plans for the decontamination and decommissioning of the intermediate waste disposal system based on new information listed and PCB wastes. The team has not reviewed those in-process changes. The source of PCB in the V-Tank is suspected to be a spill of hydraulic fluid in 1968