by Max Brantley
UA NEWS RELEASE
FAYETTEVILLE, Ark. – The Environmental Health and Safety Office of the University of Arkansas recently completed three “cleanup” projects that required more than eight years of work and almost $6 million.
“I’m very proud of the work that the Environmental Health and Safety Office did on these projects, and continues to do every day on our campus,” said Mike Johnson, associate vice chancellor for facilities. “It’s a big part of our mission to be a responsible steward of the environment, and I don’t know of another university that has made a commitment of this size, complexity and cost within our region.”
The university had always followed the standard procedures of the time when it came to disposing of hazardous materials or low-level radioactive waste, and in the 1960s the accepted procedure was to bury the waste in lined trenches. Disposal sites were carefully chosen based on the accepted criteria of the time, including soil characteristics, groundwater flow, depth of the water table and distance of the site from populated areas.
By the 1990s, however, the environmental rules were changing.
“The Environmental Protection Agency was starting to turn its attention to colleges and universities and holding them accountable in the same way they held businesses accountable,” said Miriam Lonon, who was hired as manager of the environmental health and safety office of facilities management in 1998. “At that point the University of Arkansas had no problems with the EPA, but it was really just a matter of time.”
One concern for the university was the status of its hazardous chemical and low-level radioactive waste disposal site on university property on Harmon Road in Washington County. The university started burying the waste material from research in the arts and sciences, agriculture and engineering colleges in 1965, following the standard practices approved by the Radiation Control Division of the Arkansas Department of Health. At the time, studies conducted by the university’s Division of Agriculture confirmed that the site met all the accepted criteria of the time and posed no radiological threat to human health or the environment.
In 1984, however, the Arkansas Department of Pollution Control and Ecology declared the Harmon Road site a “Hazardous Waste Landfill” because of the chemicals being buried there. The agency assumed jurisdiction over the site, which by this time was subject to the requirements of the Resource Conservation and Recovery Act. In the face of new regulations and expensive requirements, the university decided to close down the disposal site.
The university further stabilized the closed site in 1993 by covering it with a clay cap and installing wells to monitor groundwater, as required by the RCRA permit. The permit also required the university to take quarterly samples of groundwater from the wells, have them analyzed for a variety of chemical and radiological contaminants and report the results to the newly named Arkansas Department of Environmental Quality. Then, in 1999, the university took a further step when the environmental health and safety office finalized the terms of a permit for monitoring and maintaining the site.
“At this same time, the university was also aware of other sites that needed action,” Lonon said, “preferably before state or federal agencies got involved.”
The first and smallest of these was known as the Gregg site, a parcel of about one acre on Chris Hollow Road, between Fayetteville and Johnson. During the 1960s the university had performed a one-time disposal of laboratory chemicals on this land. The chemical containers, most of them glass, had been carefully buried in trenches and surrounded by Vermiculite, a material designed to absorb any spills. Starting in 2000, the environmental health and safety office began working to find the exact location of these trenches and then to carefully excavate the site. When the waste was removed from the ground, most of the glass containers were still intact and soil samples confirmed that no contamination had leaked from the site. This project was completed in 2003 and was so successful that EPA Region 6 and the ADEQ certified the site as part of the “Ready for Reuse” program, acknowledging that the “environmental conditions on the property are protective of human health and the environment, based on its current and anticipated future use as a residential development.” The Gregg site was the first public facility in Arkansas, and only the third facility in Region 6, to be certified as ready for reuse.
The total project cost the university $377,371.
The Gregg site wasn’t the only “legacy waste” that the university had to address, however: there were others on the main campus itself. University researchers had conducted experiments from the 1950s through the 1970s using a neutron particle accelerator that was housed in an underground laboratory beneath the Chemistry Building. In addition, the university had, for many years, stored low-level radioactive waste and other hazardous materials in the former Geology Building, in several areas of the Chemistry Building, and in various other sites on campus.
“Holding radioactive waste until the radioactivity decays is legal and is still standard practice, but it is best done with isotopes having short half-lives,” Lonon explained. “Some of this material was no longer, in fact, radioactive, but was mixed with chemicals or other materials that required special handling and disposal procedures. We knew several other universities had been fined heavily by the EPA for failing to clean up similar storage areas and that the old procedures were no longer considered adequate.”
In 2001, while the office was still researching the Gregg site and monitoring the Harmon Road site, Lonon and her staff began a four-phase project to remove and dispose of all the radioactive and mixed hazardous waste on campus, including everything in the underground laboratory that had housed the neutron particle accelerator. First, a contractor was hired to determine what materials were being stored in these buildings and the best way to dispose of them. Another contractor handled the removal and decontamination of the storage areas. Finally, the accelerator and all other materials were removed and the rooms were extensively decontaminated. Still, a few small radiation “hot spots” remained. In late 2007 the underground laboratory was permanently sealed and completely filled with flowable concrete to prevent any future spread of contamination. The area was posted, with a warning that future excavations on the site are forbidden, and will remain so in perpetuity. The total cost of this project was $1,155,068.
All during this period the university was paying more than $50,000 a year to monitor and maintain the Harmon Road site. Although there was no evidence that any chemical or radioactive contaminants ever left the site, by 2004 it was becoming obvious that something different needed to be done.
“The situation had changed,” said Lonon. “The area was growing, and it was obvious that the Harmon Road site could no longer be considered ‘isolated.’ Everyone involved agreed we had a responsibility to do the right thing, environmentally, in light of those changes and that it made sense for the university to spend the money to clean up the site, once and for all.”
In 2005 the university negotiated a new agreement with the ADEQ for a permit to close the Harmon Road site. All of the waste material from the site was removed and shipped to Oak Ridge, Tenn., for incineration, then buried at a radioactive waste site in Utah. Test samples of the remaining soil and two studies conducted at the site in 2006 showed that all contamination had been removed, but the Arkansas Department of Health ruled the excavated soil was itself a radioactive waste. The university was required to ship the soil, several tons of it, to Utah for burial. That work began in 2007 and was completed the following year. Then the ground at the site was leveled, seeded and by the end of 2008 it was returned to green space. The area is no longer under state or federal regulation and is no longer considered a hazardous site. Total cost of the three-year clean up was $4,386,685.
“I’m very pleased to have these projects behind us,” Lonon said. “All of us in this office, in facilities management and across the entire campus research community want our legacy to be a ‘clean house’ at the university. We have come a long way toward that goal. Now it’s our responsibility to be sure everyone who works with hazardous materials on campus knows how to handle them and dispose of them safely.”
The environmental health and safety office is still actively involved in removing and disposing of chemical and radioactive waste.
“Our current emphasis is to help researchers reduce the waste stream, so there is less hazardous material to deal with,” Lonon said. “There are now other, nonradioactive alternatives to use in some experiments, for example. Members of the research community are also encouraged to buy chemicals in the smallest amounts needed for their projects, because the cost to dispose of surplus materials is usually higher than any savings they get by buying in bulk.”
The office now maintains a state of the art hazardous materials storage facility to handle the waste that is produced on campus. Chemical waste is picked up within three days of a pickup request and is disposed of within 90 days. Short-lived radioisotopes are still held for decay, but in a single location and under the watchful eye of the radiation safety officer and others on the office staff. The days of burying hazardous materials “out in the country” are ancient history as the University of Arkansas continues its commitment to keeping a clean house.