5
Regulatory Requirements Affecting Closure

BACKGROUND

In closing the baseline chemical agent disposal facilities, the Army must comply with regulations established under a number of different environmental regulatory statutes. The most challenging among these are the facility closure regulations established under the Resource Conservation and Recovery Act (RCRA) (40 CFR Part 264, Subpart G). This chapter focuses on RCRA closure and related issues. It also addresses the influence of Base Realignment and Closure (BRAC) and cleanup programs under RCRA and the Comprehensive Environmental Response, Compensation and Liability Act. It is interesting to note that the Chemical Weapons Convention (CWC), which dictated many requirements pertaining to the destruction of chemical warfare materiel, is not a factor during closure.1 Once the stockpile is destroyed, the substantive requirements of the CWC have been satisfied.

General RCRA Closure Requirements

Under RCRA, the Environmental Protection Agency (EPA) was charged with developing regulations that define certain wastes as hazardous and establishing controls for their management. States adopt these regulations but may choose to be more stringent. Moreover, through their authority to dispense RCRA permits, some states impose conditions that are not reflected in their established regulations. Of the four states with baseline incineration sites, Utah and Oregon have established more stringent regulations than those of the EPA, and all have imposed permit conditions that go beyond regulatory requirements.2 All are different in regard to how the chemical agent disposal facilities were regulated during operations and are to be regulated during closure.

RCRA closure regulations require facilities to comply with a “closure performance standard” (40 CFR 264.111). This qualitative standard requires facilities to close in a manner that is protective of human health and the environment and that minimizes post-closure releases of hazardous waste or hazardous waste constituents. When a facility is “clean-closed,” the performance standard is typically translated into risk-based quantitative criteria (e.g., concentrations) that are determined to be protective of human health and the environment for specific constituents contained in waste materials, media, and debris. These criteria are dependent on the future use of the site. Criteria developed for residential uses are generally more protective (i.e., have lower allowable concentrations) than those developed for industrial uses.

1

Formally, the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and Their Destruction. The treaty was signed by the United States in 1993 and ratified by Congress in 1997.

2

Several of the states addressed in this report that have baseline incineration sites have specifically identified waste containing chemical warfare agents as hazardous waste, whereas such waste is not so identified under the federal hazardous waste laws.



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5 regulatory requirements affecting closure BacKgrouNd through their authority to dispense RCRA permits, some states impose conditions that are not reflected in In closing the baseline chemical agent disposal their established regulations. Of the four states with facilities, the Army must comply with regulations baseline incineration sites, Utah and Oregon have established under a number of different environmental established more stringent regulations than those of regulatory statutes. The most challenging among these the EPA, and all have imposed permit conditions that are the facility closure regulations established under go beyond regulatory requirements.2 All are different the Resource Conservation and Recovery Act (RCRA) in regard to how the chemical agent disposal facilities (40 CFR Part 264, Subpart G). This chapter focuses on were regulated during operations and are to be regu- RCRA closure and related issues. It also addresses the lated during closure. influence of Base Realignment and Closure (BRAC) RCRA closure regulations require facilities to com- and cleanup programs under RCRA and the Compre- ply with a “closure performance standard” (40 CFR hensive Environmental Response, Compensation and 264.111). This qualitative standard requires facili- Liability Act. It is interesting to note that the Chemical ties to close in a manner that is protective of human Weapons Convention (CWC), which dictated many health and the environment and that minimizes post- requirements pertaining to the destruction of chemical closure releases of hazardous waste or hazardous waste warfare materiel, is not a factor during closure.1 Once constituents. When a facility is “clean-closed,” the the stockpile is destroyed, the substantive requirements performance standard is typically translated into risk- of the CWC have been satisfied. based quantitative criteria (e.g., concentrations) that are determined to be protective of human health and general rcra closure requirements the environment for specific constituents contained in waste materials, media, and debris. These criteria are Under RCRA, the Environmental Protection Agency dependent on the future use of the site. Criteria devel- (EPA) was charged with developing regulations that oped for residential uses are generally more protective define certain wastes as hazardous and establishing (i.e., have lower allowable concentrations) than those controls for their management. States adopt these regu- developed for industrial uses. lations but may choose to be more stringent. Moreover, 1 Formally, 2 Several the Convention on the Prohibition of the Develop- of the states addressed in this report that have baseline ment, Production, Stockpiling and Use of Chemical Weapons and incineration sites have specifically identified waste containing Their Destruction. The treaty was signed by the United States in chemical warfare agents as hazardous waste, whereas such waste 1993 and ratified by Congress in 1997. is not so identified under the federal hazardous waste laws. 

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES state-specific rcra closure requirements The RCRA closure regulations further require facili- ties to submit detailed closure plans as part of the permit Utah application submitted during the permitting process. The closure plan becomes part of the permit when the In adopting EPA’s RCRA regulations, Utah has permit is issued. The closure plan may be amended imposed more stringent regulations as well as permit for a number of reasons, but such amendments require conditions that go beyond regulatory requirements.5,6 facilities to undergo a permit modification. Permit Utah has listed “Nerve, Military, and Chemical Agents” modifications are designated Class 1, 2, or 3, reflecting as an acute hazardous waste7 under waste code P999 an increase in impact and complexity. Closure plans and “Residues from Demilitarization, Treatment and are typically amended one or more times as the date for Testing of Nerve Military and Chemical Agents” as actual facility closure approaches. Some closure permit a listed waste8 under hazardous waste code F999. modifications can be processed as Class 1; more com- Throughout the disposal campaigns at the Chemical plex modifications would be processed as Class 2 or 3. Agent Munitions Disposal System (CAMDS) and the The decision as to the class of a modification is made by Tooele Chemical Agent Disposal Facility (TOCDF), the regulatory authority, often in consultation with the waste materials resulting from treatment of the P999 permittee. In addition, especially with complex facili- waste were designated F999. In accordance with the ties, more detailed closure plans for specific operations RCRA “derived from rule,”9 residues from treatment, may be prepared that, although not officially part of storage, or disposal of F999 waste retain the hazard- the permit, may still require regulatory approval. These ous waste designation and the code F999. Thus, waste supplemental closure documents may also be modified materials produced during closure, even those that as a closure approaches and as it is under way. result from treatment of F999 waste, are required to Under RCRA regulations, there are also strict require- be managed as F999 hazardous waste, even if they are ments pertaining to the time allowed for closure, but known or suspected to contain no detectable agent or extensions to these deadlines may be approved by the other hazardous constituents.10 regulatory authority. At the completion of closure, Utah has also established specific requirements for requirements for submitting certifications and survey “Cleanup Action and Risk-Based Closure Standards.” plats must likewise be met. If a facility is closed in con- Risk-based closure performance standards are deter- formance with a residential performance standard, few if mined on a case-by-case basis for nearly all facility any limitations are placed on future land use. However, closures. Closure performance standards for CAMDS if a facility is closed in conformance to an industrial and TOCDF facilities may be expected to be at least standard, use restrictions may be imposed to prevent uses as stringent as those established using a risk-based requiring a more protective cleanup (e.g., residential). approach for nonchemical agent facilities in Utah. Both non-agent and agent-contaminated waste mate- rials, residues, and contaminated media would also be expected to be generated during closure.3 These could 5 Utah’s hazardous waste management program was established be treated if required and disposed of on-site, reused by the Utah Solid and Hazardous Waste Act and is defined within or recycled, or sent off-site to a commercial treatment, R315 of the Utah Administrative Code (R315-1 to 17, 50, 101 and storage, and disposal facility (TSDF). For the third 102). option, off-site TSDF permits would need to be broad 6 Stringency, in this context, means additional requirements im - enough to allow acceptance of closure waste. How- posed on chemical demilitarization facilities that are not imposed on commercial treatment storage and disposal facilities within Utah ever, TSDFs would not be obligated to accept agent- or across the United States. associated4 or other waste. 7Acute hazardous wastes are established under the RCRA pro - gram at 40 CFR 261.33(e) (Utah R315-2-9). 8 F999 is added to the EPA listing of hazardous waste from non - specific sources found in 40 CFR 261.31 (Utah R315-2-11). 3 Review of Chemical Agent Secondary Waste Disposal and Regu- 9 The derived-from rule is established under the RCRA program latory Requirements provides an overview of the types of wastes at 40 CFR 261.3 (c)(2)(i) (Utah R315-2-3 (c)(2)(i)). 10While RCRA and the Utah regulations provide means of dem - that would likely be generated during closure (NRC, 2007). 4 The term “agent associated” is used to refer to wastes that re - onstrating that listed wastes are not hazardous (e.g., “delisting”), tain the agent designation but may, nevertheless, not contain agent the demonstration required is often arduous and prohibitively above analytical detection limits. expensive.

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 REGULATORY REqUIREMENTS AFFECTING CLOSURE Dual Waste Code for Some Materials. Some types of Utah has also established the following permit con- ditions pertaining to chemical agent operations that go waste materials, primarily permeable solids, can be dif- beyond regulatory requirements. ficult to sample and analyze for chemical agents. A good example is demilitarization protective ensemble suits for Agent Vapors. Utah includes as F999 waste those worker protection, which become waste after being used. waste materials that result from actual or potential Because of the difficulty in sampling and analyzing these contact with agent vapors. Consequently, significant suits, application of a WCL is problematic for this waste. additional volumes of various types of materials, which In these cases, Utah has required decontamination of the have or potentially have contacted agent vapors even if materials and application of a dual P999/F999 waste such materials present little or no risk, could be regu- code prior to off-site transport for disposal. lated as hazardous waste during closure. Generator Knowledge. R CRA allows hazardous Off-Site Restrictions. Utah has placed restrictions on waste generators to use generator knowledge in lieu of transport of potentially agent-contaminated waste off- actual testing in characterizing waste as hazardous or not.11 In many cases throughout the commercial sec- site for further treatment and/or disposal. In Utah, waste must be tested against waste control limits (WCLs) tor, generator knowledge is used to identify waste as and may only be transported off-site if these levels are nonhazardous without any testing. Utah has been cau- met. The WCLs are based on meeting the Army’s own tious, and in some cases reluctant, to allow CAMDS criteria for what were initially developed as drinking and TOCDF the use of generator knowledge for char- water standards for soldiers in the field (U.S. Army, acterizing agent-related waste. A good example would 2007). Even if the WCL is met, these waste materials be using generator knowledge to classify waste as are still controlled as hazardous waste under the State non-F999 based on its having had a low potential for contact with agent vapors.12 F999 waste code (NRC, 2008). Waste Characterization. Since the early days of the Arkansas chemical stockpile disposal program, the Army, being concerned primarily with worker exposure to hazard- In adopting EPA’s RCRA regulations, Arkansas ous agent vapor, has applied a vigorous program of retained its primary structure, but in contrast to Utah, vapor screening of materials and waste that have been the state did not specifically designate chemical agents or chemical munitions as listed hazardous waste. 13 exposed to chemical agents (AR 385-61). In contrast, RCRA has historically relied upon a system of direct Hence, in Arkansas, chemical agent-associated waste analysis of waste for constituents of concern (EPA, is considered hazardous waste only if it exhibits any of 2009). Utah has been reluctant to accept vapor screen- the four hazardous waste characteristics (ignitability, ing as a means of waste characterization for chemical corrosivity, reactivity, or toxicity; 40 CFR 261.21 to 261.24)14,15 Arkansas has not imposed more stringent agent-associated waste. In those limited cases where Utah has accepted vapor screening, Utah has required the Army to apply more stringent criteria than the Army has established. Further, some waste streams—par- 11 Review of Chemical Agent Secondary Waste Disposal and ticularly those that may absorb chemical agent—are Regulatory Requirements (2007) provides a definition and discus- required to have been decontaminated before being sion on generator knowledge (NRC, 2007). 12Testing of wood pallets upon which chemical munitions or bulk cleared for off-site shipment. agents are stored is typically required even if there is no history of agent leaking from the munitions or bulk containers. Waste Carbon and P999. Waste carbon that is actu- 13Arkansas’s hazardous waste management program was estab - ally or potentially contaminated with chemical agent lished by Regulation 23. is designated P999 in Utah. Because P999 waste may 14 Generators may manage waste as hazardous even if the waste would not otherwise be classified as hazardous waste. not be sent off-site for treatment and disposal in Utah, 15 The most likely characteristic that would be exhibited would be the Army must develop appropriate on-site treatment the RCRA toxicity characteristic, which assesses leachable hazard - options or other means of ensuring that the carbon ous constituents. Of these constituents, arsenic and mercury are of does not pose an unacceptable risk during subsequent primary concern. Additional characteristics that may be exhibited handling—including transport, treatment, or disposal. would include corrosivity and, potentially, reactivity.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES administrative changes only.18 Alabama has not specifi- regulations but has established some permit conditions pertaining to chemical agents or associated wastes. cally designated chemical agents or chemical munitions At the Pine Bluff Chemical Agent Disposal Facil- as listed hazardous waste. Hence, in Alabama, chemical ity (PBCDF), generator knowledge, quality assurance agent-associated wastes would be considered hazardous data, and analytical data are used to make waste charac- waste only if they exhibited any of the four hazardous waste characteristics (40 CFR 261.21 to 261.24).19,20 terization decisions. Under the PBCDF RCRA permit, the term “chemical agent free”16 refers to contaminated Alabama has not imposed more stringent regulations, or potentially contaminated solid materials that have but the state has established some permit conditions been tested per the PBCDF waste analysis plan and pertaining to chemical agents or associated waste. found to be below the WCL or to have been thermally The Anniston Chemical Agent Disposal Facility treated for 15 minutes at 1,000°F (NRC, 2008). ( ANCDF) RCRA permit defines “chemical agent f ree” 21 a s agent concentrations below the lowest Under the waste analysis plan, PBCDF waste may be shipped off-site for treatment and/or disposal only if: achievable method detection limits as specified by the analytical method used. In addition, any waste at • The waste was not agent contaminated (as deter- ANCDF not exposed to chemical agent liquids or to mined via generator knowledge), or vapors >1 STL (short-term limit) is nonhazardous with • The waste meets the criteria established in the respect to chemical agent and may be disposed of off- site as nonhazardous waste (NRC, 2008). 22 permit for chemical agent free, or • The waste has been decontaminated and/or moni- Under the ANCDF waste analysis plan, EPA’s ana- tored to a vapor concentration less than the short- lytical methods must be used to determine whether a term exposure limit (NRC, 2008).17 sample contains agent or other hazardous constituents. Methods developed by the Army are used for materials Under the PBCDF waste analysis plan, waste from with no prescribed EPA methods. The ANCDF waste areas where a chemical agent may be present must be analysis plan allows agent vapor monitoring for non- sampled and tested for the agent, or the vapor space porous waste that has been exposed to liquid chemical above the waste must be monitored. For those batches agent or chemical agent vapor concentrations >1 STL of waste characterized by sampling and testing, extrac- to determine suitability for off-site shipment (NRC, tion and analysis is used to determine agent concentra- 2008). tions. Agent vapor space monitoring is performed by Under the ANCDF waste analysis plan, specific placing wastes in a container (e.g., drum or bag) and waste streams are screened based on the STL values for allowing at least 4 hours at 70°F for the agent vapor each chemical agent. If the concentrations are <1 VSL in the headspace of the container to reach equilibrium. (vapor screening level) this waste may be shipped to After equilibrium is reached, the concentration of agent an off-site TSDF. Only nonporous solid waste that is in the headspace is measured. The specific methodol- ogy to be used for characterization analysis of wastes is detailed in the waste analysis plan (NRC, 2008). 18Alabama’s hazardous waste management program is defined within the Alabama Administrative Code 335-14-2. 19 Generators may manage wastes as hazardous even if the waste Alabama would not otherwise be classified as hazardous waste. 20 The most likely characteristic that would be exhibited would In adopting EPA’s RCRA regulations, Alabama be the RCRA toxicity characteristic, which assesses leachable retained the primary structure of the RCRA regulations hazardous constituents. Of these constituents, arsenic and mercury and adopted EPA’s regulations verbatim, with minor would be of primary concern. Additional characteristics that may be exhibited would include corrosivity and, potentially, reactivity. 21 The term “chemical agent free” or “agent-free” is used by some 16 The term “chemical agent free” or “agent-free” is used by some of the stockpile states to refer to waste that is “safe” for off-site of the stockpile states to refer to waste that is “safe” for off-site han- handling. The committee notes that in reality these terms denote dling. The committee notes that in reality, these terms denote waste waste that has been treated to a certain specification or tested and materials that have been treated to a certain specification or tested shown to not contain agent above analytical detection limits. 22 The STL is a concentration typically expressed in terms of and shown not to contain agent above analytical detection limits. 17 The short-term exposure limit is defined as an exposure that is milligrams of a specific agent per cubic meter of air. It is similar acceptable for a short period of time, i.e., averaged over 15 minutes in numerical value to the exposure limits found in the STEL but without a respirator. without the 15-minute time component.

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 REGULATORY REqUIREMENTS AFFECTING CLOSURE they are known or suspected to contain no detectable combustible in nature or objects that do not possess agent or other hazardous constituents. occluded spaces may be evaluated for off-site disposal Oregon has also established some permit conditions using chemical agent vapor monitoring (NRC, 2008). that go beyond regulatory requirements. Examples of In addition to RCRA requirements, Alabama—like a these additional requirements are described below. number of other states—recently established a program of uniform environmental covenants. The Alabama Off-Site Restrictions. The Umatilla facility’s haz- Uniform Environmental Covenants Act places limita- ardous waste permit requires on-site treatment of all tions on properties undergoing a response action (e.g., agent-contaminated waste. This would include waste, RCRA closure) that are not approved for unrestricted use.23 Specifically, this statute includes a new “Uni- residues, and media generated during closure. form Environmental Covenants Program” that places “Agent-Free” Criterion. Oregon also has an “agent- statewide restrictions on hazardous waste facilities that free” criterion.27 Permit compliance concentration chose to close according to an industrial standard.24 (PCC) limits establish levels at which waste materials This new law might force the facility to close according to residential standards.25 are considered agent-free. At UMCDF, waste must be agent-free prior to shipment to an off-site TSDF. Samples are considered agent-free if they are below the Oregon established PCCs. The PCCs included in the UMCDF permit were selected based on (1) generator knowledge; Oregon has specifically listed chemical agents as acute hazardous waste, similar to what Utah has done.26 (2) similar waste streams at Johnston Atoll Chemical Agent Disposal System and TOCDF; and (3) RCRA Blister agents such as mustard are listed under the haz- land disposal restriction (LDR) requirements.28 These ardous waste code P998, and nerve agents, including PCCs are lower than the WCLs for GB and Vx used GB and Vx, are listed under the hazardous waste code at CAMDS and TOCDF, and they may be difficult to P999. The Oregon regulations also list residues from achieve using the existing analytical methods for some demilitarization, treatment, and testing of blister agents closure waste, residues, and media (see Chapter 6 for a as F998, and residues from demilitarization, treatment, discussion on analytical issues) (NRC, 2008). and testing of nerve agents as F999. The Oregon regulations define “demilitarization” as Analytical Methods. At UMCDF, PCCs are deter- all processes and activities at both the Umatilla Chemi- mined using EPA’s analytical methods unless another cal Depot (UMCD) and the Umatilla Chemical Agent methodology is approved. For detection of chemical Disposal Facility (UMCDF) from the start of operations agents, UMCDF standard operating procedure UM- through approval for closure of all permitted treatment, 0000-M-559, “Agent Extraction and Analyses,” is storage, and disposal units and facility-wide correc- used. This procedure tailors the analysis to the sample tive actions. Also, as with Utah, the derived-from rule matrix (NRC, 2008). would render waste produced during closure—includ- ing waste that result from treatment of listed waste—to be managed as listed hazardous waste materials even if 23 Question-and-answer 27 The session between Timothy Garrett, Site term “chemical-agent-free” or “agent-free” is used by Project Manager, ANCDF, and the committee, January 27, 2010. some of the stockpile states to refer to wastes that are “safe” for 2 4 T he Uniform Environmental Covenant Act is a uniform off-site handling. The committee notes that in reality these terms statute drafted by the National Conference of Commissioners on denote waste that has been treated to a certain specification or Uniform State Laws and enacted by Alabama in 2007. The statute tested and shown to not contain agent above analytical method i s available online at http://www.law.upenn.edu/bll/archives/ detection limits. 28 In short, the LDR program requires hazardous wastes to be ulc/ueca/2003final.htm. The Alabama Uniform Environmental Covenant Program is available online at http://www.adem.state. treated prior to land disposal to reduce the toxicity or mobility of al.us/alEnviroRegLaws/files/Div5Eff5-26-09.pdf. hazardous constituents and minimize short- and long-term threats 25 Question-and-answer session between Timothy Garrett, Site to human health and the environment. Regulations establishing Project Manager, ANCDF, and the committee, January 27, 2010. LDR requirements may be found in 40 CFR Part 268. A summary 26 Oregon has incorporated by reference the federal RCRA regu - of the LDR program is available online at http://www.epa.gov/osw/ lations under Oregon Administrative Rules [OAR] 340-101-0001. inforesources/pubs/hotline/training/ldr05.pdf.

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0 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES Background Concentrations Closure Performance Facility closure under RCRA can be conducted Standard. The RCRA permit issued to UMCD goes independent of BRAC realignment or closure, but it is important to consider future land use during the RCRA beyond conventional residential standards to require closure process. Hence, RCRA closure and BRAC the entire depot to be closed to background concentra- should be coordinated. Because PBCA, ANCA, and tions. Closure according to background can be con- Deseret Chemical Depot (DCD) will remain under sidered a type of residential standard; however, it is a Army control, there is more flexibility at these instal- considerably more stringent requirement. lations to consider a range of closure performance standards under RCRA; an industrial or residential The influence of Base realignment and closure standard may be pursued depending on situation- specific factors. Since the late 1980s, many military installations At UMCD, which will be transferred from Army or portions of installations have been identified for ownership, closure according to residential standards realignment or closure under BRAC. BRAC is the pro- may preserve a broader range of future land uses, to cess the Department of Defense uses to “reorganize its include farming or residential use. Even at UMCD, if installation infrastructure to more efficiently and effec- portions of the land are to be slated for post-closure tively support its forces, increase operational readiness and facilitate new ways of doing business.”29 industrial use, closure to an industrial performance standard will be significantly less expensive and time- Two of the four baseline disposal facilities addressed consuming. As indicated above, however, Oregon cur- in this report are impacted by BRAC: rently requires that the closure performance standard over the entire installation be set based on background • The Deseret Chemical Depot is expected to be concentrations. closed under BRAC. However, much of the facil- ity, including storage igloos, land, and remaining structures, is expected to be turned over to the ProgrammaTic coNsTraiNTs Tooele Army Depot.30 • The Umatilla Chemical Depot, which includes risk during closure versus risk during operations the UMCDF, will close entirely under BRAC. The committee noted in its letter report (Appendix The Umatilla Army Depot Re-Use Authority A) that the restrictive practices the state regulatory ( UMADRA), which includes representatives agencies have used to address disposal operations at the f rom Umatilla County, Morrow County, the baseline chemical agent disposal facilities were devel- Port of Umatilla, the Confederated Tribes of the oped early in the program, when there was little experi- Umatilla Indian Reservation, and two ex officio ence with managing the risks of materials exposed to state representatives, have proposed a reuse plan agent. During closure, in contrast with agent disposal that would divide the property among the Oregon operations, there will not be any significant amount of National Guard (20 percent), the U.S. Fish and agent present and there will be no munitions. Thus, the Wildlife Service (40 percent), and the reuse risks to human health and the environment from agent authority (40 percent). Under this plan, UMCDF and munitions will be significantly reduced during clo- would be transferred to UMADRA and then to the sure from those that existed during disposal processing. Port of Umatilla for future use. This difference in risk represents a fundamental change in the working environment that will exist during clo- The Pine Bluff Chemical Activity (PBCA) and sure operations from that which will have existed dur- Anniston Chemical Activity (ANCA) are not subject ing disposal operations, and it should provide a basis to BRAC. Following closure, the land and remaining for considering less restrictive practices. structures at the disposal facilities will be returned to the respective installations. Finding 5-1. The risk of exposure to chemical agents during closure operations is expected to be significantly 29A dditional information is available online at http://www. lower than what potentially could be encountered defense.gov/brac/definitions_brac2005.html. Last accessed June during agent disposal operations. The regulatory stan- 9, 2010. dards and practices used by some states for controlling 30 This is the current status and may be subject to change.

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 REGULATORY REqUIREMENTS AFFECTING CLOSURE agent-contaminated materials were developed early this manner, gutting of the internal units and equipment in the program, when there was little experience with within the building may be conducted as a normal part managing the risks of materials exposed to agent. of facility operations, rather than as part of the official These practices and regulations may be more restrictive closure. By keeping the building environmental con- than necessary considering the nature of the closure trols in place during this dismantlement and removal operations. period, protection of human health and the environment is maintained. This practice was conducted success- Recommendation 5-1. The Army should evaluate fully during closure of the Aberdeen Chemical Agent the reduced risk of exposure to chemical agents and Disposal Facility (Bechtel Aberdeen, 2007). their degradation products from closure operations Finding 5-2. Closure will not entail dealing with sig- and waste materials in view of restrictive regulatory practices. It should also consider negotiating with the nificant amounts of agent or munitions. The following regulatory community to obtain less restrictive, but still are examples of practices that can be used to expedite safe, regulatory practices that allow for more efficient the overall closure schedule while still protecting closure operations. human health and the environment: (1) expanded use of generator knowledge for waste characterization; One of the means by which less restrictive but (2) relaxed requirements for off-site transportation still protective requirements could be employed is by of agent-associated waste; and (3) allowing baseline allowing more use of generator knowledge for waste facilities to initiate formal closure after building classification during closure activities. As indicated environmental controls (operation of the carbon filter previously, some states have been cautious, and in some system) have been turned off. cases reluctant, about allowing stockpile facilities to Recommendation 5-2. The Army should consider use generator knowledge for characterizing agent waste as either hazardous or nonhazardous. proposing to regulatory authorities and the public (1) Another means to tailor current regulatory practices expanded use of generator knowledge for waste char- to the conditions likely to be faced during closure is to acterization; (2) more tailored requirements for off-site use tailored (more appropriate) off-site requirements. transportation of chemical agent-associated waste; and As indicated above, most of the baseline facility RCRA (3) allowing baseline facilities to initiate formal closure permits restrict off-site transportation of chemical after building environmental controls (operation of the agent-associated waste. Instead they require that such carbon filter system) have been turned off. waste meet state-specific “agent-free” criteria prior to being able to be released off-site. There are other areas as well where more tailored Because closure does not normally entail dealing practices may be employed during closure while still with materials having significant agent contamination, protecting human health and the environment. The tailoring requirements to closure conditions such as committee has not examined all of these but urges those described above can be a reasonable approach the Army to continually identify additional means of that does not compromise worker or public safety. replacing prior regulatory practices that may have By focusing on controlling only wastes that are truly been needed during operations with more tailored and hazardous, the Army could actually strengthen its appropriate practices. protection of human health and the environment. Fur- thermore, if regulatory authorities and the public are rcra closure Plan and decommissioning made aware of the Army’s intention to focus on waste Work Packages that is truly hazardous, they are likely to support such a strategy. Closure operations are already under way for One additional area where more tailored practices CAMDS, and planning for closure is under way at can be employed during RCRA closure is in allowing TOCDF. The approach taken has been to prepare a baseline facilities to delay the formal commencement general RCRA closure plan that describes the type of closure operations until building environmental of closure and standards that will be established, but controls (e.g., operation of the carbon filter system) to rely on decommissioning work packages (DWPs) have been turned off and actual demolition begins. In that are not part of the permit for closure of individual

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES units and processes.31 In this manner, the most signifi- degradation products, and other hazardous constituents cant regulatory issues associated with closure can be that will be constituents of concern are regulated. settled during the development of the official closure Finding 5-3. While it appears that the type of risk- plan that becomes part of the permit. Issues that may be associated with individual units or processes can based approach to closure (industrial versus residential) thus be addressed outside the permitting process, sav- has been established by the Army at each baseline ing time and preserving the overall closure schedule. chemical agent disposal facility site, the Army has not For example, at CAMDS, the Army anticipates that as negotiated quantitative closure standards for wastes, many as 15 individual DWPs will ultimately be nec- residues, and media with the regulatory authorities at essary. The practice of developing a general closure all of these facility sites. plan that is part of the permit and DWPs for individual Recommendation 5-3. At the earliest possible time, units or processes provides a means to save time and preserve the overall closure schedule. the Army should initiate the negotiation process with state regulatory authorities at all the baseline chemi- cal agent disposal facility sites for the closure per- Managing Permit Modifications Associated with Closure formance standards that will need to be achieved in The above process for establishing a general RCRA wastes, residues, and media, with the goal of having closure plan and associated DWPs notwithstanding, these standards established well before facility closure permit modifications may still be needed prior to or actually begins. during the closure process. Class 1 RCRA permit modi- fications are far less arduous and time-consuming than Analytical Methods are Class 2 or 3 RCRA permit modifications. Where permit modifications associated with closure Each facility will have to identify analytical meth- are necessary, the Class 1 modifications would expedite ods that will be used for measuring compliance with the approval process. Where Class 2 or 3 permit modi- closure standards in waste, residues, and media. Some fications are anticipated, discussion of the nature of the modifications to analytical methods may be needed to modification and processes and procedures with the achieve state-specific closure standards, and in these regulatory authority well before anticipated submittal cases, significant time and effort may be required for would facilitate processing and approval. the technical development of these modifications and for achieving regulatory authority approval. Analytical methods are discussed further in Chapter 6. Closure Performance Standards Without exception, the Army’s baseline chemi- Secondary Waste cal agent disposal facilities addressed in this report Secondary waste materials are those that were gen- have indicated that they will pursue a clean closure erated in the course of agent disposal processing and a pproach. 32 I t appears, however, that closure for similar waste that may be generated during closure P BCDF, CAMDS, and TOCDF will be based on activities. In addition to waste from demolition, large an industrial closure standard, whereas closure for amounts of secondary waste may need to be managed ANCDF and UMCDF will be based on a residential during closure. These waste materials may contain standard. Further, it appears that the residential stan- agent degradation products and/or RCRA hazardous dard at UMCDF will go beyond conventional levels constituents; they may also exhibit RCRA character- protective of the general population by requiring clo- istics. Common hazardous constituents that may be sure to background, a much more stringent standard. encountered include polychlorinated biphenyls (PCBs) Each facility is also unique with respect to the way and a variety of heavy metals, including arsenic and the respective state authorities determine how agents, mercury.33 Activated carbon that is contaminated with mercury will present a special challenge, a topic dis- 31Among the baseline facilities, a variety of terms have been used to refer to the same type of document. 32 Question-and-answer session between Timothy Garrett, Site 33 PCB disposal is regulated under the Toxic Substances Control Project Manager, ANCDF, and the committee, January 27, 2010. Act (40 CFR Part 761).

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 REGULATORY REqUIREMENTS AFFECTING CLOSURE cussed in detail in two prior NRC reports (NRC, 2008, ing closure activities along with any preexisting (i.e., 2009). Any of the four RCRA characteristics (ignitabil- legacy) and newly generated secondary waste. These ity, corrosivity, reactivity, or toxicity; 40 CFR 261.21 materials may contain agent degradation products, but to 261.24) may also be exhibited. in many cases they will also exhibit Resource Conser- For secondary waste to be treated or disposed of, it vation and Recovery Act (RCRA) characteristics and must be properly characterized. As with many RCRA therefore will be subject to the RCRA land disposal requirements, regulatory authority acceptance will be restrictions. required for a determination of the adequacy of proper Recommendation 5-5. To facilitate handling and characterization. In addition, secondary waste will need to be sufficiently characterized to allow acceptance by disposal of closure waste, residues, and media, as well off-site TSDFs. Disagreements between the Army and as any legacy and newly generated secondary waste, the regulatory authority, or between the Army and off- the Army should ensure that its tracking system facili- site TSDFs, as to what constitutes proper waste charac- tates segregation of materials by subsequent handling, terization have the potential to cause significant delays. including land disposal restriction treatment require- In addition, even if the permit issued for off-site TSDFs ments, so as to avoid unnecessary handling, including allows acceptance of the Army’s secondary waste, the treatment, of some waste types. off-site TSDF must agree to accept the waste. reuse or recycling of valuable materials Finding 5-4. The determination of the adequacy of proper characterization of secondary waste will require In accordance with federal acquisition regulations, regulatory authority acceptance and acceptance by U.S. government property at the baseline chemical the off-site treatment, storage, and disposal facility. agent disposal facilities to be closed must be evalu- Disagreements about what constitutes proper waste ated for suitable reuse at another Chemical Materi- characterization have the potential to cause significant als Agency (CMA) facility, some other government delays. facility, or commercial facilities. For example, at the Aberdeen Chemical Agent Disposal Facility (ABCDF), Recommendation 5-4. The Army and the regulatory where bulk stocks of mustard agent were destroyed authority, as well as off-site treatment storage and using a chemical neutralization (hydrolysis) process, disposal facilities, should agree on the definition and reusable nonagent-contaminated equipment (e.g., Min- process for proper characterization of secondary waste iature Chemical Agent Monitoring Systems, laboratory well before closure operations begin. instruments, electrical equipment) was transferred to other facilities. Generator knowledge was used to iden- tify materials that were not contaminated with agent Land Disposal Restrictions for Waste, Residues, (Bechtel Aberdeen, 2007). and Media Materials known to have been exposed to liquid RCRA LDR requirements impact many of the waste agent or agent vapor, along with reusable or recyclable materials, residues, and media that will be generated items, are decontaminated and tested using monitoring during closure, as well as the legacy waste from storage and analytical methods as required by the RCRA permit. activities and other secondary waste present at TOCDF. Scrap metal is of particular concern due to its intrinsic These waste materials may contain RCRA hazardous value. At ABCDF, scrap material was segregated for constituents at levels above LDR treatment require- recycling. This included uncontaminated structural ments and may exhibit RCRA characteristics as well, steel, steel rebar, electrical conduit, wire, pipe supports thus requiring treatment prior to ultimate disposal. The and racks, and vent piping. Approximately 1,350,000 Army has already established a classification system pounds were recycled (Bechtel Aberdeen, 2007). for segregating waste produced during closure, but it is The steel from the hydrolysate storage tanks at unclear whether this system adequately considers treat- ABCDF was also evaluated for scrap potential. The ment requirements for LDR compliance (URS, 2008). tanks were cleaned, but an odor caused by the presence of residual hydrolysate was present. Consequently, Finding 5-5. Large amounts of many different types the recycling alternative was not considered viable of waste, residues, and media will be generated dur- (Bechtel Aberdeen, 2007). Attempts were also made

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES to release titanium tanks at ABCDF to allow recycling. Maintaining the confidence of recyclers, regulatory The tanks were tented and monitored to determine if authorities, and the public in the safety of materials they would meet the general population limit (GPL) received for recycling, as well as in reused or recycled for mustard agent. However, monitoring results were products, is an important consideration. invalidated by interference from residual hydrolysate, Finding 5-6. Many valuable high-grade materials, which prevented detection of mustard agent at the GPL. Further attempts to address the residual hydrolysate or including steel, tungsten, and other metals, are used monitor other tanks were not attempted (Bechtel Aber- within or constitute materials of construction at base- deen, 2007). The steel from the ABCDF hydrolysate line chemical agent disposal facilities. At some of these storage tanks and the titanium tanks were landfilled as facilities, the Army is planning to dispose of these hazardous waste. In both cases, the committee believes materials in hazardous waste landfills. that decontamination is effective in reducing chemical Recommendation 5-6. To the extent feasible, the Army agents to below levels of concern. In view of the above experience, the Army has should avoid landfilling valuable materials and instead expressed concern that the costs associated with release seek ways in which to reuse or recycle them. Where of materials for reuse and recycling may outweigh chemical analyses are insufficient to definitively classify a the benefits of reuse or recycling.34,35 The committee material as below levels of concern (as was the case with believes that it would be best if valuable materials could tungsten at the Aberdeen Chemical Agent Disposal Facil- be decontaminated as needed and reused or recycled. ity), generator knowledge can provide additional assur- At TOCDF and CAMDS, for example, the Army has ance that materials are suitable for reuse or recycling. indicated that it intends to dispose of all materials from the facility as hazardous waste even after decontamina- state resources tion. The committee believes it is undesirable to take up valuable landfill space with materials that can be State regulatory permitting and oversight programs recycled and have so much intrinsic value. have been losing staff to other programs as the baseline Regulatory authorities and the public are typically chemical agent disposal facilities approach and begin in favor of recycling, although they may show some the closure process. At the same time, state resources are reluctance to accept recycling of materials from chemi- required to review and approve closure plans, DWPs, cal agent disposal facilities. However, if the public is data produced during closure, permit modifications, made aware of the environmental and financial ben- administrative closure documents, and similar activities efits associated with reuse and recycling of materials, both from within the baseline facilities and from non- including those that have been safely and thoroughly military industrial facilities in each state that compete decontaminated, it is likely to support strategies that for the attention of state regulatory personnel. distinguish such materials from those that are truly Finding 5-7. A general concern for each of the base- hazardous and thus require treatment and subsequent disposal in a hazardous waste landfill. While members line chemical agent disposal facility sites is that state of the public might not necessarily be interested in resources for reviewing and approving closure plans helping the Army save money, they are likely to support and related documentation and data are expected to strategies that divert materials from disposal through become limiting factors for achieving timely review reuse or recycling, as long as it can be determined that and approval by the respective regulatory authorities. such practices are safe. In addition, the Army must Recommendation 5-7. The Army should coordinate ensure that materials sent for reuse and recycling are safe for the receiving facility to handle, and that future upcoming review and approval needs concerning clo- uses of reused and recycled materials are safe as well. sure plans and documentation of the baseline chemical agent disposal facilities with state regulatory authori- ties well ahead of anticipated deliveries to them. 34Amy Dean, Environmental Engineer, Project Manager for Elimination of Chemical Weapons, CMA, “Status of Overall Clo- The Army schedules for facility closures assume a sure Planning,” presentation to the committee, March 1, 2010. 3-month period for administrative closure. The Army 35 Question-and-answer session between Brian O’Donnell, Chief, defines administrative closure as “everything associated PMCSE Secondary Waste and Closure Team, CMA, and the com- with Contract closeout, including everything necessary mittee, March 2, 2010.

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 REGULATORY REqUIREMENTS AFFECTING CLOSURE iNsTallaTioN-sPeciFic coNsTraiNTs to close out facility permits (most notably administra- tive closeout of the RCRA Permit).”36 Administrative As a result of discussions between the committee closeout includes the period required by state regulatory members and Army personnel and contractors at the authorities to review all data and information provided baseline facilities, as well as with CMA staff, a number to show that closure performance standards have been of installation-specific issues were identified. achieved and to officially approve the facility as closed. While administrative closure of 3 months is possible, camds/TocdF experience at complex facilities, such as the Johnston Atoll Chemical Agent Disposal System, shows that Legacy Waste administrative closure can take considerably longer. At DCD there are 2 million pounds of legacy waste Finding 5-8. The time allotted by the Army for admin- stored within storage igloos adjacent to TOCDF that istrative closure of the baseline chemical agent disposal will require disposition as part of closure (Appendix facilities is just three months. The committee believes A). These materials may contain agent degradation that the assumption of three months for achieving products and/or RCRA hazardous constituents; they administrative closure is unlikely to be achieved. may also exhibit RCRA characteristics. Common haz- ardous constituents that may be encountered include Recommendation 5-8. The Army should be more PCBs and a variety of heavy metals, including arsenic realistic about the time it assumes will be needed for and mercury.37 This waste may also contain asbestos. administrative closure of the baseline chemical agent Any of the four RCRA characteristics (ignitability, disposal facilities. corrosivity, reactivity, or toxicity; 40 CFR 261.21 to 261.24) may also be exhibited. disposition of igloos used to store chemical Most of the legacy waste was generated from opera- munitions and Waste tion of the chemical agent storage facilities at DCD over a period of decades. Examples include discarded In addition to closure of the baseline destruction samples, spill cleanup materials, used personal protec- facilities, the igloos used to store chemical muni - tive equipment, metals parts, laboratory and sampling/ tions and other wastes (e.g., secondary wastes, legacy monitoring waste, and used/spent decontamination wastes) will also need to undergo closure in accor- fluids. The exact nature of the materials may be uncer- dance with RCRA requirements. Storage (and the tain. However, in order for this waste to be treated/dis- closure/disposition of igloos) is conducted under an posed of, proper characterization will be necessary. As entirely different RCRA permit from the chemical with other secondary waste, the determination of the agent destruction facility. In some cases, ownership adequacy of proper characterization for legacy waste of the storage permit is by a different entity within the will require regulatory authority acceptance. Potential Army. For example, the permit for the igloos used to disagreements between the Army and the regulatory store munitions and other wastes at TOCDF belongs to authority on what constitutes proper waste character- DCD. RCRA closure of the igloos is beyond the scope ization for these wastes may cause significant delays. of the committee because closure of the chemical agent Many of the drums containing these wastes are expected disposal facilities does not entail closure of the igloos to be heterogeneous in content, and physical sampling used for storage. Nevertheless, it would be prudent and analysis of the materials in all of the drums would for the Army to prepare closure planning documents entail a significant effort with substantial delay. The that pertain specifically to closure of the igloos and to Army has already experienced delays in similar situa- obtain regulatory authority approval for these planning tions: at TOCDF, for instance, it had to sample many documents well before chemical agent disposal facility of the ton containers and munitions containing mustard closure begins, so as not to impede closure plans for the agent to ensure that levels of arsenic and mercury were chemical agent disposal facilities. In addition, closure activities should be coordinated. 37 Thecommittee recognizes that As is formally a metalloid. 36 Personalcommunication between Raj Malhotra, Deputy, Mis- However, it is treated in a manner similar to other metals by the sion Support Directorate, CMA, and Nancy Schulte, study director, EPA. Thus, in the vernacular of this report, As is referred to as a April 27, 2010. metal.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES adequately determined. Similar delays were also expe- were it to pursue an industrial standard in compliance rienced in sampling the M55 rocket shipping tubes for with the covenant. However, the committee did become the presence of PCBs. aware of a similar situation at Redstone Arsenal, also located in Alabama and subject to the covenant. Spe- Finding 5-9. Disagreements between the Army and the cifically, the Record of Decision for a cleanup action regulatory authority on what constitutes proper waste at Redstone Arsenal establishes an institutional control characterization of legacy waste at Deseret Chemical to prohibit future use of the property for anything other than industrial use.39 Thus, at the Redstone Arsenal, Depot has the potential to cause significant delays for facility closure at the site. industrial use was selected for the remedy even though the facility was subject to the Alabama Uniform Envi- Recommendation 5-9. The Army and the regulatory ronmental Covenant Act. authority should agree on the definition and process for Finding 5-10. The Army recognizes that it must comply proper characterization for legacy wastes at Deseret Chemical Depot well before closure of the Tooele with the requirements of the Alabama Uniform Envi- Chemical Agent Disposal Facility begins. ronmental Covenant Act in closing ANCDF. Although the Army initially considered closing ANCDF against an industrial standard, due to the provisions of the PBcdF covenant and the internal legal hurdles it would face There appear to be no significant facility-specific in pursuing an industrial closure standard, the facility regulatory closure constraints at PBCDF. By monitor- may instead choose to close against a residential stan- ing closure progress carefully the Army will be ready dard. Closing against a residential standard may entail to respond to unforeseen challenges. a significant increase in closure costs and may extend the closure schedule as well. aNcdF Recommendation 5-10. T he Army should weigh the costs and benefits of legal requirements and use Uniform Environmental Covenant Provision limitations associated with closure against an industrial in Alabama standard with those associated with cleanup against a The one significant facility-specific constraint for more stringent residential standard. If the costs and ANCDF deals with the new Uniform Environmental benefits of closure against a residential standard out- Covenant provision in Alabama, as discussed earlier. weigh those associated with an industrial standard, the The Army recognizes that it must comply with the Army should endeavor to overcome its internal legal requirements of the Alabama Uniform Environmental hurdles and close ANCDF according to an industrial Covenant Act in closing ANCDF. closure standard. Prior to the Restricted Covenant provision, the Army had planned to close the ANCDF site according to an umcdF industrial standard. This would make sense since the property would revert back to Anniston Army Depot. Closure Performance Standards (Agent-Free Criterion However, the Army has indicated that this new law and Background) might force the facility to close against residential standards simply because of the internal Army legal As indicated previously, the RCRA permit issued to hurdles that ANCDF would face were it to pursue an UMCD goes beyond conventional residential standards industrial standard in compliance with the provisions to require the entire depot to be closed according to back- of the covenant.38 The committee did not further investigate the internal 39 Record of Decision for RSA- 122, Dismantled Lewisite Manu - legal hurdles that would be encountered by the Army facturing Plant Sites; RSA-056, Closed Arsenic Waste Ponds; and RSA-139, Former Arsenic Trichloride Manufacturing; Disposal Area, Operable Unit 6 the Redstone Arsenal in Alabama at 1-2 38 Question-and-answer session between Timothy Garrett, Site (September 2009), available online at http://www.epa.gov/region4/ Project Manager, ANCDF, and the committee, January 27, 2010. waste/npl/nplal/redsrod122_056_arpond_139_ou6_artri.pdf.

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 REGULATORY REqUIREMENTS AFFECTING CLOSURE ground concentrations. There is no explicit state regula- subject to cleanup under the Federal Facility Agreement tion that requires such a stringent cleanup level. More- and the Army’s Military Munitions Response Program over, this background closure requirement is inconsistent from other areas of the depot that can be closed to meet with EPA regulations and with the risk-based closure the background performance standard. requirements established by other states under RCRA. The standard for the agents and the breakdown prod- BRAC ucts of concern would be based on the limits of detection of the analytical methods used, in concert with any ana- Another complication particularly relevant to UMCD lytical interference or similar challenges posed by closure is that the installation will close entirely under BRAC, waste, residues, and media. As indicated previously, the with its land and remaining facilities most likely being Army will need to carefully evaluate the analytical meth- turned over to a local land-reuse authority, the U.S. Fish ods that will be used for the types of wastes, residues, and and Wildlife Service, and the Oregon National Guard media that will be produced during closure. for a mix of potential future uses, including industrial. A complication that affects the state’s requirement The proposed reuse plan supported by the Confeder- that UMCD be closed to background concentrations is ated Tribes of the Umatilla Indian Reservation calls that, like many military installations across the United for transfer of the UMCDF site to the Port of Umatilla States, UMCD is in the middle of a cleanup program for for industrial reuse. The expectation is that the existing its hazardous waste sites. Umatilla was placed on the infrastructure will be retained in support of that reuse. Comprehensive Environmental Response, Compensa- The tribes have indicated that these areas should be closed to an industrial standard.41 tion and Liability Act National Priorities List (Superfund site) in 1987, and a Federal Facility Agreement was Finding 5-12. Future industrial use is planned for the signed in 1989. Records of Decision have been signed and a number of remediations are ongoing. In addition, Umatilla Chemical Agent Disposal Facility; however, several areas within UMCD may be contaminated with the state of Oregon is requiring closure according to munitions and explosives of concern and are subject to background. the Army’s Military Munitions Response Program.40 Recommendation 5-12. The Army should work with The areas undergoing long-term cleanup will likely need to remain under federal control until the state and all stakeholders to close the Umatilla Chemical Agent stakeholders agree that cleanup requirements have been Disposal Facility according to an industrial-based clo- met. Such requirements may include leaving wastes or sure performance standard. contamination in place with long-term monitoring and institutional controls. If areas remain contaminated, The Confederated Tribes of the Umatilla Indian enforceable long-term institutional controls limiting Reservation, in asserting their treaty rights to custom- access and use will need to be put into place. ary use of the Umatilla Chemical Depot (UCD), want open areas of the depot (outside of UMCDF) cleaned Finding 5-11. Old disposal sites and contaminated to background as part of the UMCDF closure. How- areas at Umatilla Chemical Depot, including landfills ever, the confederated tribes’ interpretation of the term and areas with munitions and explosives of concern, “background” is different from the conventional use of will be difficult to close according to a background the term. Unlike the Oregon regulatory authorities, the closure performance standard and may remain on the tribes’ interpretation of background applies to the sur- installation well beyond the completion of closure of face of the land but not to buried waste and munitions. the Umatilla Chemical Agent Disposal Facility. The tribes have proposed that surface soil downwind from UMCDF be sampled for contaminants that may Recommendation 5-11. The Army should open a have been emitted from UMCDF. Their intent is to have dialogue with Oregon regulatory authorities and other stakeholders to separate Umatilla Chemical Depot areas 41 Teleconferencewith Rodney S. Skeen, Manager, Engineering and Modeling Program, Department of Science and Engineering, 40Additional information is available online at http://deparc. Confederated Tribes of the Umatilla Indian Reservation; Todd xservices.com/PDFS/Installation_Summary/OR021382091700. Kimmell and Leonard Siegel, committee members; and Nancy pdf. Last accessed June 9, 2010. Schulte and Harrison Pannella, NRC staff; May 26, 2010.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES reFereNces the Army remove compounds of potential concern that exceed naturally occurring levels. Munitions or other Bechtel Aberdeen. 2007. 24719-100-30L-B93H-00009—Revision 0 Aber- waste buried below depths of concern for hunting and deen Chemical Agent Neutralization Facility RCRA Closure Certifica - farming are not a concern for the Umatilla tribes.42 tion Report. APG Edgewood Area, MD: Bechtel Aberdeen. EPA (U.S. Environmental Protection Agency). 2009. SW-846 Test Methods It is beyond the scope of the committee’s work to for Evaluating Solid Waste, Physical/Chemical Methods. Washington, consider cleanup standards outside the UMCDF por- D.C.: U.S. Environmental Protection Agency. tion of the UCD, but the Army should work with the NRC (National Research Council). 2007. Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements. Washington, Oregon regulatory authorities and UMADRA to resolve D.C.: The National Academies Press. the tribes’ request so as to avoid unnecessary delays to NRC. 2008. Review of Secondary Waste Disposal Planning for the Blue completing closure. Grass and Pueblo Chemical Agent Destruction Pilot Plants. Washington, D.C.: The National Academies Press. NRC. 2009. Disposal of Activated Carbon from Chemical Agent Disposal Facilities. Washington, D.C.: The National Academies Press. 42 Teleconferencewith Rodney S. Skeen, Manager, Engineering URS. 2008. Decommissioning Plan Appendix 3: Material and Waste Man- and Modeling Program, Department of Science and Engineering, agement Plan. Princeton, NJ: URS. Confederated Tribes of the Umatilla Indian Reservation; Todd U.S. Army. 2007. TB MED 577: Sanitary Control and Surveillance of Kimmell and Leonard Siegel, committee members; and Nancy Field Water Supplies. Washington, D.C.: Headquarters, Department Schulte and Harrison Pannella, NRC staff; May 26, 2010. of the Army.