Current Permit Status

The currently approved version of the TOCDF RCRA permit includes a basic closure plan (Army, June 2009). The Army is presently pursuing a permit modification for both CAMDS and TOCDF that combines active operations of both facilities, including closure, under the TOCDF permit.4 Utah officials have indicated that they will soon be ready to act on permit modification approvals, following RCRA public involvement and administrative actions.5

TOCDF has held initial discussions with the UDEQ regarding closure, focusing on specific issues. A RCRA permit modification to establish details for the regulatory-required closure plan is planned for submittal by June 2010. TOCDF closure plans within the existing (prepermit modification) permits indicate that the closure performance standard will be based on an industrial future use scenario.

The TOCDF closure plans also indicate that the incinerators and other units will be decontaminated as needed and dismantled. Some structures for TOCDF (primarily those used for nonagent operations) may remain following closure. Presently, TOCDF plans to remove all materials, including scrap metal and demolition wastes (e.g., concrete) from structures. Current requirements call for all of these materials to be disposed of in a hazardous waste landfill as designated F999 wastes. Some wastes, such as demilitarization protective ensemble suits, may retain the combined P999/F999 waste code (discussed later under Utah Regulatory Requirements) following decontamination.

Waste analysis to meet waste control limits (WCLs) and other criteria have been required for both chemical agent and for agent degradation products prior to the off-site transport of various wastes generated during disposal operations (such as decontaminated munitions casings). However, analytical methods for these analytes in certain closure wastes (such as concrete and carbon) are still under development and will require regulatory approval.

End Use and End Use Status

The site is envisaged at present to be closed to meet an industrial end use specification and will become part of the Tooele Army Depot following closure. Complete closure of the TOCDF site and remediation to levels of residual contamination for industrial use is envisioned.

4

Information here has been taken from a question-and-answer session between Ted Ryba, Site Project Manager, TOCDF Field Office, and the committee, on October 22, 2009.

5

Information in the final sentence of this paragraph and from the next three paragraphs is from a question-and-answer session between Dennis Downs, Director, Utah Department of Solid and Hazardous Waste, and the committee, on October 22, 2009.



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