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Information Requirements
Physical and Chemical Characteristics of Waste and Residues
Waste Analysis Plan
Waste and Residual Characterization
Prevention of Releases to Groundwater and Subsurface Environment
Prevention of Releases to Surface Water or Wetlands or to Soil
Closure and Post-Closure Care
Environmental Performance Standards
Remediation and Performance Criteria
References
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Information Requirements
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A Subpart X permit applicant must provide both
general and specific information about the miscellaneous
units described in the permit application.
General information requirements for all RCRA
permit applications, including those for miscellaneous
units, are specified in 40 CFR §270.14. The
specific information requirements for Subpart X
units, set forth in 40 CFR §270.23, include a
detailed description of the unit, environmental
settings, pathways of exposure and receptors, and
demonstration of effectiveness of treatment.
The following subsections provide guidance for
evaluating information submitted by permit applicants
in response to the specific, and some of the
general information requirements. Appendix A of
this document contains a check list that summarizes
the information requirements that must be addressed
in a Subpart X permit application. Permit writers
also should refer to the RCRA Miscellaneous
Treatment Units Permitting and Compliance Training
- Available Information and Tools, General Technical
Issues and Specific Technical Issues presentations
for assistance in reviewing Subpart X permit
applications. In addition, a number of states have
also developed Subpart X guidance. |
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Physical and Chemical Characteristics of Waste and Residues
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| Information Requirements |
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Description: A Subpart X permit applicant must provide both
general and specific information about the miscellaneous
units described in the permit application.
General information requirements for all RCRA
permit applications, including those for miscellaneous
units, are specified in 40 CFR §270.14. |
| Physical and Chemical Characteristics of Waste and Residues |
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Description: The permit application for a miscellaneous unit, must
include waste characterization data that are sufficient
to assure that the wastes managed by the facility can
be (1) adequately and safely stored at the facility
and (2) effectively treated in the miscellaneous unit. |
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Waste Analysis Plan
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| Waste Analysis Plan |
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Description: The Subpart X permit applicant must submit a waste
analysis plan, as required by §270.14(b)(3), which
includes analytical parameters and the rationale for
the selection of such parameters, test methods, and
methods and frequency of sampling. |
| Analytical Parameters |
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Description: The waste analysis plan must list the parameters for
which analysis of the waste and the residues of
waste treatment will be conducted. The parameters
must be specific to the type of waste to be analyzed,
and the rationale for their selection must be
provided. |
| Analytical Methods |
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Description: The waste analysis plan must list test methods for
evaluating wastes for the parameters of concern.
When possible, the test methods must be taken from
SW-846, Test Methods for Evaluating Solid
Wastes. |
| Frequency of Analysis |
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Description: The waste analysis plan should specify the frequency
with which analysis will be conducted to ensure
successful treatment of the waste. |
| Analysis of Waste Generated Off Site |
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Description: Additional requirements for analysis of wastes are
applicable to facilities that receive waste from offsite
generators. The waste analysis plan for such a
facility must specify procedures for using information
supplied by off-site generators in lieu of actual
analysis of the waste at the site. |
| Additional Requirements for Waste Analysis |
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Description: The owner or operator that treats, stores, or
disposes of ignitable or reactive waste or mixes
incompatible wastes or incompatible wastes with
other materials must provide documentation. |
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Waste and Residual Characterization
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| Waste and Residual Characterization |
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Description: A permit writer should require that a Subpart X
permit applicant characterize the waste that is to be
treated or disposed of (as generated wastes) and, if
applicable, the residues of the treatment process. |
| Munitions, Explosives, and Other As-Generated Wastes |
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Description: There are two major issues of special interest to
permit writers with regard to the analysis of wastes
to be treated or disposed of in Subpart X units.
First, many of the wastes that will be treated in
Subpart X units, and OB/OD units in particular,
already may be well characterized in information
provided by manufacturers and other sources. |
| Use of DoD Data Sheets and Technical Manuals |
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Description: DoD data sheets may be used to characterize some
wastes that are treated in OB/OD units. The
Secretary of the Army is the sole manager for the
procurement, production, supply, and maintenance
of conventional ammunition for all military services. |
| Waste Analysis for Ignitable and Reactive Wastes |
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Description: Permit writers should allow treatment of ignitable
and reactive wastes in OB/OD units only if such
wastes cannot be managed safely in other units. |
| Residuals Characterization |
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Description: Residues from the treatment of wastes in Subpart X
units include solid wastes and air emissions. Permit
writers should require that applicants provide a
means for characterizing the hazardous constituents
in such residues. |
| Air Emissions |
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Description: OB/OD thermal treatment methods are currently the
primary means of demilitarization employed by DoD
for the disposal of energetic materials. To meet the
need for identification and quantification of emissions
from these treatment methods, DoD instituted a
comprehensive test program commonly referred to
as the “BangBox” study. |
| Solid Residues |
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Description: Permit applicants should provide permit writers with
a description of the process to be used to
characterize solid residues such as scrap metal
generated by Subpart X treatment units. |
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Prevention of Releases to Groundwater and Subsurface Environment
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| Prevention of Releases to Groundwater and the Subsurface Environment |
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Description: This section discusses the areas the permit writer
should focus on in reviewing the section of the
permit application in which prevention of releases to
ground water and the subsurface environment is
discussed. |
| Volume and Physical and Chemical Characteristics of the Waste |
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Description: The volume and physical and chemical
characteristics of wastes have a direct bearing on the
potential that contaminants will reach ground water
or contaminate the subsurface environment.
Information about those factors is crucial to the
permit writer to support a determination of the
potential to release. |
| Open Burning Units |
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Description: The wastes treated at OB units typically will have
been well characterized and will be present in the
unit itself for only a brief period before the burn is
initiated. Residues from OB operations, such as ash
and air emissions, are of the greatest concern in
identifying the potential for release to ground water
and the subsurface environment. |
| Open Detonation Units |
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Description: The management of wastes before placement in OD
units is similar to that for OB units. The wastes
usually will be well contained (that is, in packages),
and usually will remain in the unit only for a very
short time before treatment. |
| Potential for Migration through Soil, Liners, or Other Containment Structure |
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Description: The permit applicant should use information
pertaining to the volume and physical and chemical
characteristics of the wastes managed at these units
to assess the potential for migration of such wastes
through, soil, liners, or other containment devices. |
| Hydrologic and Geologic Characteristics of the Unit and the Surrounding Area |
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Description: Like other land-based units, characterization of sitespecific
hydrology and geology at the facility is
necessary to adequately define aquifer system(s),
bedrock formation material(s), and subsurface soil.
Information required for defining the hydrogeologic
environment of the area in the vicinity of the Subpart
X unit includes the quality, quantity, and gradient of
the existing ground water; the locations of current
and future ground water users; the current and
potential rates of withdrawal of water; and local
land-use patterns. |
| Existing Quality of Groundwater, Quantity and Direction of Groundwater Flow, and Proximity to Current and Potential Withdrawal Rates of Groundwater Users |
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Description: Once again, the permit writer should ascertain that
the information provided by the permit applicant is
complete. The permit writer must use best
professional judgment in determining whether the
information provided is adequate. |
| Potential for Deposition or Migration of Waste Constituents |
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Description: Most of the information described above is intended
to support a discussion of the potential for migration
of wastes into the subsurface soil and ground water
and subsequent migration into the rooting zones of
food crops and other vegetation. |
| Potential for Occurrence of Health Risks Caused by Human Exposure to Water Constituents |
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Description: The human health risk portion of the risk assessment
should address directly the potential for the
occurrence of health risks associated with direct or
indirect exposure to wastes released from the unit. |
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Prevention of Releases to Surface Water or Wetlands or to Soil
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| Prevention of Releases to Surface Water or Wetlands or to Soil |
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Description: The issues associated with prevention of releases to
surface water, wetlands, or soil are similar to those
related to releases to ground water or the subsurface environment. |
| Volume and Physical and Chemical Characteristics of Waste |
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Description: The issues associated with these factors
were discussed in this section and
are essentially the same here. |
| Effectiveness and Reliability of Containing, Confining, and Collecting Systems and Stuctures in Preventing Migration |
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Description: This part of the permit application should discuss the
engineering and operational controls in place to
minimize the potential for release from Subpart X
units. |
| Hydrologic Characteristics of the Unit and the Area in its Vicinity, Topography of the Land in the Vicinity of the Unit, and its Proximity to Surface Water |
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Description: This part of the permit application must discuss the
general topography and hydrology of any surface water in the area
of the unit and its location nearest the unit. |
| Pattern of Precipitation in the Region |
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Description: Discussion of the pattern of precipitation in the
region must rely on rainfall data from a nearby
NOAA weather station, or from a privately
maintained weather station. Many military facilities
maintain their own weather stations. |
| Current and Potential Uses of Nearby Surface Waters and Water Quality Standards Established for Nearby Surface Waters |
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Description: A Subpart X permit application must include a
complete discussion of the potential uses of nearby
surface waters and water quality standards that
govern them. |
| Existing Quality of Surface Waters and Surface Soils, Including Other Sources of Contamination and Their Cumulative Effect on Surface Waters and Surface Soils |
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Description: This information should be included in the
environmental and risk assessments. The
information presented probably will be a
combination of information from state reports,
USDA soil survey reports, and analytical data
obtained from sampling and analysis upgradient and
down gradient of the unit. |
| Pattern of Land Use in the Region |
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Description: The permit application also must discuss patterns of
land use in the region. Typical sources of
information for the discussion are county or city
zoning and land-use maps and data from the Bureau
of the Census. |
| Potential for the Occurrence of Health Risks Caused by Human Exposure to Waste Constituents |
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Description: The human health risk portion of the risk assessment
should address directly the potential health risks
associated with direct or indirect exposure to wastes
released from the unit. |
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Closure and Post-Closure Care
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| Closure and Post-Closure Care |
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Description: Subpart X permit
applicant must prepare and submit plans for closure
and, if applicable, post-closure care, as part of the
permit application. Section 264.601 requires that a
Subpart X unit be closed in a manner that will ensure
protection of human health and the environment. |
| Requirements for Closure Plans |
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Description: The general requirements of the closure plan are
specified in §264.112(b). These requirements are
applicable to all Subpart X units. |
| Post-Closure Care Requirements |
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Description: Requirements for post-closure care are specified in
40 CFR §§264.117 through 264.120. The
requirements will apply if the Subpart X unit will
leave wastes in place after closure (e.g., a geologic
repository). |
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Environmental Performance Standards
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| Environmental Performance Standards |
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Description: This section provides permit writers guidance for
determining compliance with standards for siting,
design, construction, operation, and maintenance of
miscellaneous units. It also describes the information
that must be included in a Subpart X permit
application to demonstrate protection of human
health and the environment. |
| Location Requirements |
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Description: A miscellaneous unit, such as an OB/OD unit, must
be constructed at a remote location to protect
personnel and property from the potentially
destructive effects of explosions. |
| Design and Construction |
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Description: The applicant for a Subpart X permit must provide
detailed information about the design and
construction of the unit. A detailed description of
the unit being used or proposed for use must be
provided in the Subpart X permit application. |
| Operations and Maintenance Procedures |
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Description: According to §270.23(a)(2), the applicant for a
Subpart X permit must describe in the permit
application how the unit will be operated and
maintained to comply with the environmental
performance standards set forth under Part 264,
Subpart X and all other relevant provisions of Part
264. |
| Detection and Monitoring Requirements |
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Description: Detection and monitoring procedures must be
developed to ensure protection of human health and
the environment. Location of the site, design of the
unit, quantity of wastes to be treated in the unit, and
hydrogeologic characteristic at the site are some of
the factors that must be evaluated to determine
whether surface water or ground-water monitoring is
required at the unit, both during the operating life of
the unit and, for Subpart X disposal units, during post-closure care. |
| Effectiveness of Treatment |
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Description: Based on BangBox and full scale field testing, the
effectiveness of OB/OD treatment is dependent on a
number of factors. |
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Remediation and Performance Criteria
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| Remediation and Performance Criteria |
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Description: This section discusses the appropriateness of the
phasing of remediation activities under the closure
schedule. It also discusses the development of data
quality objectives for both monitoring and
remediation programs. Finally, the section briefly
discusses the use of innovative technologies in the
cleanup of residues from OB/OD operations. |
| Phasing of Remediation Activities |
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Description: Because of the process operations of the OB/OD
units, remediation usually will be required before the
closure of such units. It is likely that the units will not
be closed until the facility at which they are located
itself is closed or its mission altered substantially. |
| Data Quality Objectives |
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Description: EPA has developed detailed guidance on the
development and implementation of DQOs (EPA
1994). When reviewing plans for remediation, the
permit writer should insist that the DQOs are explicit
and that plan provides for actually making use of
them. |
| Innovative Technologies |
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Description: There are few innovative technologies specifically
designed for the remediation of explosives
contaminated soil and ground water contaminated
with explosives. |
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References
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| Refereces |
| Description: A list of references relevant to Subpart X Units is provided. |
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