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National Academies of Sciences, Engineering, and Medicine“Alternatives for the Demilitarization of Conventional Munitions”
Ken Shuster – August 22, 2017U.S. Environmental Protection AgencyOffice of Resource Conservation and Recovery
OB/OD Background/HistoryOB/OD UniverseStatusRCRA Permit ProceduresRCRA OB/OD Permit ConditionsStatus of EPA Projects Underway:OB/OD ContaminationOB/OD Corrective Action/Clean Closure Procedures, Successes; Clean-up CostsAlternatives to OB/OD
Background of Open Burning and Open Detonation (OB/OD) under RCRA
1978 EPA proposed to ban all open burning of hazardous wastePublic comments (including DOD and private sector): Need to allow OB/OD of energetic wastes in cases where there are no safe alternatives1980 Final Rule: OB/OD of all hazardous waste is prohibited, except for explosives/propellants when there are no safe alternatives or it is an emergencyThis OB/OD exemption for energetics was considered temporary pending development of alternative technologies (preamble to final rule)
OB/OD RCRA Universe
OB/OD Universe182 RCRA OB/OD sites:57% closed (104)33% active (60) (53 active and 7 interim status)10% inactive (18)54 Superfund OB/OD NPL sites (includes some RCRA)Lots of OB/OD outside this universeRange cleanupTrainingEmergencies
OB/OD Facilities, by Ownership
OB/OD Universe (cont)
OB/OD Functions
DemilitarizationManufacturingResearch & DevelopmentRange CleanupEmergenciesTrainingOBOD
OB/OD Tons Treated 2005-2013
All Open Burning/Open Detonation Facilities
RCRA and Superfund Facilities
Operating Status of OB/OD Facilities
State Aggregate of OB/OD Facilities
What is a Resource Conservation and Recovery Act (RCRA) Permit?
RCRA Permits are built from a standard foundation of RCRA regulatory requirements, then customized per facility.The foundation requirements are 40 CFR Parts 260 to 270.Authorizing/empowering the state equivalent requirements, 40 CFR Part 271.States can become authorized to implement the RCRA program and thus states typically issue RCRA permits.The Permit Writer must ensure that:A permit is consistent with the regulatory requirements.A permit identifies what is regulated, approves the facilities’ chosen or modified regulatory controls (e.g., design, monitoring), and speaks to how regulatory compliance will be measured.A permit is not issued if the application or results of inspection demonstrate noncompliance or has conflicting information.
What is a RCRA Permit?
The Permit establishes a detailed specification of parameters established to measure compliance (e.g., the remedy to be constructed, groundwater cleanup standard to be met).The Permit includes Schedules of Compliance to complete specified documentation to be submitted, construction, investigations, and other remedy decisions or work.The Permit may also impose unique “Omnibus Authority” conditions.Section 3005(c)(3) of RCRA, referred to as the “Omnibus Authority,” requires that each RCRA permit contain terms and conditions as the Administrator or State Director determines necessary to protect human health and the environment. This provision, codified at 40 CFR 270.32(b)(2), and its associated information requirement at 40 CFR 270.10(k), gives permit writers the authority to impose permit conditions in addition to applicable permit standards found in 40 CFR 264, if needed for the permit to be protective.
Who Needs a RCRA Permit?
RCRA requires a permit for the treatment, storage, and disposal of any hazardous waste identified or listed in 40 CFR Part 261.Owners or operators of facilities that treat, store, or dispose of hazardous waste must obtain an operating permit under Subtitle C of RCRA.Treatment, storage, or disposal facilities (TSDFs) in existence on or beforeNovember 19, 1980,operate under interim statusuntil a final permit decision is made.New TSDFs (i.e., those that were not in operation on or before November 19, 1980) are ineligible for interim status and must receive a RCRA permit before construction can commence.
RCRA Permitting ProcessFlow Diagram
Applicantholdsinformalmeetingwiththepublic priortopermitapplication
ApplicantsubmitsPartAandPartB permitapplications
Permittingagencyannouncesreceiptofpermitapplication,makesapplicationavailableforpublic reviewandcomment,andreviewsapplicationtoverifycompleteness
Ifapplicationisincomplete,the permittingauthority issuesaNoticeofDeficiency(NOD)directing correction and completion
Permittingagencyevaluates whetherpermitsatisfiestechnical requirementsandmakes preliminarydecisiontoissueordenythepermit
If decisiontodenypermit,permittingauthorityissuesnoticeofintenttodeny
If application iscomplete,the permitting authority notifies permittee of application’s completeness
If decision toissue permit, permitting authority issues an application complete determination and drafts permit
Public has 45 days to comment on the decision; public can request hearing
Permitting agency announcesdecision and issues Record of Decision explaining decision
RCRA Permit Conditions
All RCRA permits generally have conditions that address the following:General facility standards (e.g., waste analysis, security, inspections, training, requirements for ignitable-reactive-incompatible wastes, location standards)Preparedness/preventionContingency plan and emergency proceduresRecordkeeping/reportingCorrective action/site remediation of contaminated media
RCRA Permit Conditions
General permit conditions applicable to all permits (continued)Closure/post closureFinancial assuranceUse and management of tanks/containersMany other requirements based on the specific operations and design of the facility
Types of OB/OD RCRA Permit Conditions
Treatment operations such as OB/OD thatdo nothavespecificregulatory design/operation requirements must be permitted pursuant to 40 CFR 264, Subpart X requirements.Subpart X stipulates that permits for these “miscellaneous units” must contain terms and provisions as necessary to protect human health and the environment.
Types of OB/OD RCRA Permit Conditions
This includes permit conditions that generally cover requirements applicable to:Treatment unit design, operation, and monitoringPrevention of releases to ground, surface water and air that pose unacceptable riskResponses to releases of hazardous waste or hazardous constituentsOB/OD permit limits differ and are site-specificHowever, all permits must ensure protection of human health and the environment
Types of OB/OD RCRA Permit Conditions
Example OB/OD operating conditions from permits – each permit will not necessarily include all these requirementsWaste restrictions (e.g. energetic/reactive waste only, on-site generated waste only)Daily/annual/event limits on amount OB/OD’dSome have waste concentration limitsDays/hours of operation restrictions# of days per week, during daylight hours onlyWeather condition restrictionsWind speed, rain forecast, lightening, etc.Some prohibit operations on O3action days
Types of OB/OD RCRA Permit Conditions
Example OB/OD operating conditions from permits – each permit will not necessarily include all these requirementsFire hazard managers required on scenePeriodic soil, groundwater monitoringRequirements specific to risk thresholdsOperations shall not cause carcinogenic risk of 1X10-6to be exceeded offsiteOperations shall not cause non-carcinogenic chronic hazard index of 1.0 to beexceeded offsiteSome permits require periodic assessments of the info used to model pollutant transport and risk, including emission factors and appropriateness of risk determination assumptions
Types of OB/OD RCRA Permit Conditions
Example OB/OD operating conditions from permits – each permit will not necessarily include all these requirementsNotification requirements, access restrictionsSiren, clearing nearby river of boaters, etc.Signs, gates, surveillance teamsPublic complaint proceduresClearing dry grass, leaves, and other combustiblesWater run on/off controls (stormwater control)Pre and post burn/detonation inspectionsSpilled waste management requirements
Types of OB/OD RCRA Permit Conditions
Example OB/OD operating conditions from permits – each permit will not necessarily include all these requirementsExample operating conditions specific to Open DetonationManagement/retrieval of kickoutMunition burial depth prior to detonationNoise restrictionsWaste transport requirementsDonor charge requirementsUnit maintenance (e.g., wetting)Minimum protective distances
Types of OB/OD RCRA Permit Conditions
Example operating conditions specific to OBBurn pad design (height, refractory design, precipitation covers, waste kept below critical height to prevent detonation)Hazardous waste shall not be used as burn pan accelerantsBurn box shall remain closed when waste is not being burned/treatedSome permits require periodic assessments of theavailability of alternatives to OB/OD
EPA Projects Examining OB/OD
Contamination at OB/OD sitesCorrective action, clean closure procedures, metrics, and successes, and associated costsAlternatives to OB/OD
EPA Projects - Contamination
Contamination Observedat OB/OD Sites
SoilsExceedances of ResidentialScreening levelsRDX[5.6 mg/kg EPA residual screening level]Chemtronics, Inc. 290 mg/kg52XCamp Minden (LA AAP) 100mg/kgTNT[19 mg/kg EPA residential screening level]Umatilla Army Depot, OR 36,045 mg/kg1897XChemtronics, Inc. 280 mg/kgPerchlorate[15 µg/L]Redstone Arsenal 106,000 µg/kg7067X(Army/NASA)Worst concentrations tend to be close in and further out.
It is difficult to parse out contamination from current OB/OD operations from historical contamination.
Contamination Observed at OB/OD Sites
GroundwaterExceedances of GroundwaterQuality StandardsRDX[2 µg/L]Bangor Ordnance Disposal (Navy) 10,000 µg/L5,000XNebraska Ordnance Plant 534 µg/LMass Military Reservation 370 µg/L, 7300ftplumeDahlgren Naval Warfare Center 127 µg/LRedstone Arsenal (Army/NASA) 96 µg/LTNT[2 µg/L]Banger Ordnance Disposal (Navy) 40 µg/L (stormwater)20XNebraska Ordnance Plant 39 µg/LPerchlorate[15 µg/L]Mass Military Reservation 500 µg/L, 10,000ftplume33X
EPA Projects – Corrective Action,Clean Closure, Costs
Cleanup Costs for Sites Associated with OB/OD Facilities
EPA Projects - Alternatives
Alternative Technologies Project
Assessing alternative technologies that may be used in place of OB/ODParameters of assessment include:Technology type with applicable subcategorizations ;Type of waste and constituents the technology is designed for (e.g., bulk energetics including:tetrytol, M28 propellant, M8 propellant, or fireworks, flares, etc.);The scale with which the technology has been used(e.g., bench, pilot, full-scale use);Throughput capability (e.g., pounds per hour);Whether the technology requires pre-treatment and/or post-treatment technologies;Output associated with technology (e.g., air emissions, hazardous or solid waste, wastewater);
Parameters (continued)Whether or not approved for use by the Department of Defense Explosives Safety Board (DDESB);The manufacturer of the technology including contact information;Cost to purchase, install, and operate the treatment unit;Where the technology is or has been used and the type of waste treated;Ability to treat: thin-walled; thick-walled; bulk itemsAbility to treat unarmed v. armed munitionsMost importantly, the focus is the waste stream to be treated so that we can determine which technology type(s) are suitable.
Alternative Technologies Project
Examples of Alternative Technologies
Case Disassembly1) Reverse AssemblyManualb) RoboticII.Case Penetration and Energetic Removal2) Fluid Jet Cuttinga) With or w/o abrasivesb) Various fluids (e.g., water, ammonia)3) Cryogenica) Liquid nitrogencryofracturingb) Dry ice (CO2) blasting at supersonic velocity
Examples of Alternative Technologies
Case Penetration and Energetic Removal (cont.)4) Laser Cuttinga) Ultra short laser pulses (Femtosecond) with no heat5) Acid Digestiona) Nitric acid6) Removal by Meltinga) Autoclavemeltoutb) Microwavemeltout7) Fluid Shredding or Drilling8) Ultrasonic separation in fluids9) Vacuum InfusionNote: Fluids include water, ammonia, solvents (Methylene chloride, methyl alcohol, acetone, toluene), carbon dioxide, nitric acid.
Examples of Alternative Technologies
III.Destruction10)Controlled Detonation Chambersa) Stationary or mobile treatment units (MTUs)11) Thermala) Direct flame (contained burn, incinerator, rotary kiln, car-bottom furnace, flashing furnace)b) Indirect/external heat (microwave, fluidized bed, rotary thermal tube, plasm arc, hot gas decontamination)12) Chemicala) Base hydrolysis, neutralization, supercritical water oxidation, wet air oxidation, electro-chemical oxidation,peroxydisulfateoxidation, oxidation with sulfur (Adams process)13) Biological
AlternativeTechnologiesPermitted* and/or Deployed
DDESB Approved Technologies
Explosive Disposal Alternatives Team
Contact Information:
Ken Shuster/Sasha GerhardU.S. EPA HeadquartersArlington, VAShuster.Kenneth@epa.gov703-308-8759Gerhard.Sasha@epa.gov703-879-8501





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