Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities (2010) / Chapter Skim
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5 Regulatory Requirements Affecting Closure
5 Regulatory Requirements Affecting Closure
Pages 35-48
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From page 35... ...
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)
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From page 36... ...
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.
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From page 37... ...
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)
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From page 38... ...
.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.
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From page 39... ...
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)
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From page 40... ...
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.
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From page 41... ...
This practice was conducted successRecommendation 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)
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From page 42... ...
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 genhave indicated that they will pursue a clean closure erated in the course of agent disposal processing and a pproach.
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From page 43... ...
government property at the baseline chemical the off-site treatment, storage, and disposal facility. agent disposal facilities to be closed must be evaluDisagreements about what constitutes proper waste ated for suitable reuse at another Chemical Matericharacterization have the potential to cause significant als Agency (CMA)
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From page 44... ...
A general concern for each of the basehazardous 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.
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From page 45... ...
The that pertain specifically to closure of the igloos and to Army has already experienced delays in similar situaobtain 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.
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From page 46... ...
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 EnviChemical Agent Disposal Facility begins.
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From page 47... ...
Unlike the Oregon regulatory authorities, the closure performance standard and may remain on the tribes' interpretation of background applies to the surinstallation well beyond the completion of closure of face of the land but not to buried waste and munitions. the Umatilla Chemical Agent Disposal Facility.
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From page 48... ...
2009. Disposal of Activated Carbon from Chemical Agent Disposal Facilities.
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