Remediation of Buried Chemical Warfare Materiel (2012) / Chapter Skim
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3 Treaty and Regulatory Framework and Public Involvement Considerations
3 Treaty and Regulatory Framework and Public Involvement Considerations
Pages 39-48
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From page 39... ...
CERCLA This chapter provides only a very general overview of the environmental regulatory programs applicable to discarded Overview chemical warfare materiel, with a focus on those legal and regulatory issues that have the most significant impact on CERCLA is a federally implemented hazardous waste implementation of the buried CWM remediation program. cleanup program and has been used to clean up hazardous More detailed information on these regulatory programs and waste sites all over the United States, including military sites how they apply to the Army's overall remediation responsi- that contain CWM.
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From page 40... ...
, which provides a detailed selection criteria apply to DOD sites and are discussed in agreement concerning the process and timing by which the detail below. site investigation is performed, the remedy selected, and the remedial action implemented, including the regulatory CERCLA Remedy Selection Factors review (EPA, 1988, 1999.)
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From page 41... ...
as its corrective action guidance. to use treatment to address the principal threats posed by a site whenever 8CERCLA includes explicit statutory remedy selection criteria which practicable and cost-effective" (EPA, 1996b)
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From page 42... ...
range from potential to actual hazards," but the statute Existing Army guidance for performing remedial would not "compel a reversion to pristine environmental investigations at munitions response sites, detailed in the conditions."11 Army's Final Munitions Response Remedial Investigation/ Feasibility Study Guidance (MMRP RI/FS Guidance)
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From page 43... ...
Army managers of CWM projects A "multitude of challenges make the RI/FS at CWM should fully implement the TPP process as described in the sites unique," including the "potential for exposure to toxic MMRP RI/FS Guidance as early as possible when planning chemical agents," the presence of explosive material, and the and implementing CWM cleanups. co-location with nonchemical munitions or hazardous wastes (U.S.
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From page 44... ...
If these munitions are detercleanup programs would entail completion of a full-blown mined to be hazardous waste, they are subject to RCRA's r emedial investigation or RCRA facility investigation waste management requirements. even if insufficient data are available to enable evaluation In addition, and as indicated previously, should the muniof cleanup options and a cleanup decision.
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From page 45... ...
EPA established a number of different types As indicated above, one of the options for cleaning up of units to allow flexibility in the selection of the approach waste disposal or treatment units located on operational for managing remediation waste and contaminated soil, other ranges is removal of exploded munition bodies and decon- media, and debris. As indicated in Appendix D, remediation taminated chemical munitions and the removal and destruc- wastes can be managed in corrective action management tion of intact munitions, including both conventional and units (CAMUs)
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From page 46... ...
Similarly, at the Camp Sibert, Alabama, FUDS, RCWM have Similar to CAMUs, Areas of Contamination, as described been in storage for over a year in an IHF awaiting eventual treatment in an EDS or EDT.14 RCRA corrective actions in Appendix D, could also be used to manage remediation wastes. If the concept of an Area of Contamination can be would be considered to be an ARAR under CERCLA, and shown to be protective of human health and the environment, only the substantive aspects of RCRA regulations would be considered applicable.15 Storage in excess of 90 days is typiand pending regulatory acceptance, remediation wastes, including contaminated soils, could also remain in such cally not an issue at sites being addressed under CERCLA, Areas.
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From page 47... ...
Some states may wish to employ the conven- emergency response, one or more of the large remediation tional RCRA permitting process as a means of approving use sites could be used for this purpose in the future. Each of the of the EDS or one of the EDTs at a RCRA CWM munitions large buried CWM sites will require investigation and some response site (MRS)
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From page 48... ...
information to the media. The key issue facing the Army as Munitions response actions are governed by a number it starts to remediate large buried CWM sites is whether to of laws at the federal, state, tribal, and local levels.
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