site and the potential for exposure for as long as the buried CWM remain on-site; and

•  Short-term and long-term risk.

The final remedy is selected from the protective alternatives. The parties appear to be proceeding in good faith, but whether the cleanup will proceed via a CERCLA FFA or the RCRA corrective action or both regulatory authorities is unresolved as of the drafting of this report. The committee notes that these delays could increase the overall cost of whatever actions are taken at RSA.

Maximizing Regulatory Flexibility

As discussed in Chapter 3, remediation policies provide that the amount and kind of data and the choice between interim action and remedial action are determined on a site-specific, case-by-case basis. The committee believes that, consistent with such policies, the cleanup decision should be based on the regulatory factors just described, including a scientific evaluation of the site-specific risks. What constitutes adequate data will therefore vary. Adequate data may consist of historical information, and be based on geological investigations, limited test-pitting, sampling, and experience with evaluations of the various remediation technologies. At Redstone, site-specific factors have led to the selection of remediation based on interim actions rather than on the conclusions of a feasibility study, and the Army and the state are developing work plans. Particularly at sites containing buried CWM, the committee judges that extensive, new data may not be required to select the remedies. At sites where the efficient use of data allows expeditious decisions on the remedies to be employed, available funding can be focused on risk reduction.

Corrective Action Management Units, Temporary Units, and Area of Contamination Concept

As indicated in Chapter 3 and in Appendix D, the management of remediation waste is complex. While the present discussion is intended to provide broad suggestions on the regulatory issues that pertain to RSA, it is beyond the scope of this report to delve into the intricacies of the regulatory requirements for the wastes that may be generated there. However, the concept of establishing corrective action management units (CAMUs), temporary units (TUs), and areas of contamination, as discussed in Chapter 3 and in Appendix D, is very appealing for a site as large and complex as RSA. Assuming that acceptable locations can be identified for them, the establishment of CAMUs, TUs, and areas of contamination could be a cost-effective approach for RSA. For example, remediation waste placed in a disposal CAMU may include large amounts of contaminated and noncontaminated empty munition bodies, empty agent containers, debris such as equipment from the demolition of agent manufacturing and handling facilities, and contaminated soils and debris. The management of remediation waste in such units and areas may help mitigate the risks and costs of treating materials removed from the trenches and of dealing with residuals from that treatment.


Alabama’s Madison County and the town of Huntsville, which surround the RSA, are experiencing significant economic development.27 While some of the area’s recent construction activity can be attributed to RSA’s status as a BRAC “gaining facility,” much of the community’s economic expansion began before that impact. Indeed, the area’s economic growth has been identified as an important factor in ADEM’s preference for a removal and cleanup remedy rather than a leave-in-place remedy.28

Contaminants have been identified in the vicinity of the RSA site, including solvents, metals, pesticides, CWM, and hazardous remnants from rocket fuel R&D and testing, such as perchlorate. These contaminants have impacted ground-water, soil, sediments, and surface waters in the region29 and are of concern for both public health and economic prosperity. The proximity to the Tennessee River, which is used for drinking water and recreation, increases the importance of selecting the best remediation approach.30

Public engagement and education will be critical during the protracted and complex cleanup of RSA. It will be important that the Army, the state of Alabama, the federal regulatory agencies, and the community work closely together to maximize the efficiency of the cleanup program and protect the health and environment of the community.31,32

The committee judges that the long-term cleanup at the Spring Valley FUDS in Washington, D.C., offers an important lesson to be learned for remediation efforts at RSA. The committee received briefings on the Spring Valley FUDS; from EPA Region 3; the Army Corps of Engineers, Baltimore District; the District of Columbia Department of


27Huntsville Regional Economic Growth Initiative, 2007. Available at Accessed April16, 2012.

28Terry de la Paz, Chief, Installation Restoration Branch, Environmental Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspective,” presentation to the committee on November 2, 2011.

29U.S. EPA Superfund Record of Decision: U.S. Army/NASA Redstone Arsenal. EPA/ROD/R04-04/662. 09/29/2004. Available at: Accessed April 16, 2012.


31Stephen A. Cobb, Chief, Government Hazardous Waste Branch, Land Division, ADEM, “Remediation of Buried CWM in Alabama: The State Regulator’s Perspective,” presentation to the committee on November 2, 2011.

32Terry de la Paz, Chief, Installation Restoration Branch, Environmental Management Division, RSA, Alabama, U.S. Army, “Remediation of Buried CWM at Redstone Arsenal, Alabama: The Installation Manager’s Perspective,” presentation to the committee on November 2, 2011.

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