Book Description

A major Clean Water Act (CWA) Federal Facilities Compliance Agreement was signed on March 25, 1991 by the US Department of Energy, Rocky Flats Field Office (DOE, RFFO) and the Water Enforcement Division of the Environmental Protection Agency (EPA), Region VIII. The agreement revised the Rocky Flats Plant's National Pollutant Discharge Elimination System (NPDES) permit and arose from pemittee-requested changes in effluent monitoring points and permit violations, most notably the February 22, 1989 Chromic Acid Incident. The Rocky Flats Plant, now called the Rocky Flats Environmental Technology Site (Site) near Golden Colorado was operated at that time by Rockwell International Corporation, who later plead guilty to six misdemeanor and felony counts of the CWA (the aforementioned NPDES permit violations) and paid a $4 million fine on March 26, 1992. The Compliance Agreement, hereafter referred to as the NPDES FFCA, called for three separate remedial action plans and contained a schedule for their submittal to the EPA. The compliance plans focussed on: (1) Waste Water Treatment Plant (WWTP) performance upgrades, (2) source control and surface water protection, and (3) characterization of the impacts from past sludge disposal practices. Projects that implemented the compliance plans were initiated soon after submittal to the EPA and are forecast to complete in 1997 at a total cost of over $35 million. This paper presents a case history of NPDES FFCA compliance projects and highlights the successes, failures, and lessons learned.