Storage of hazardous wastes at UMCD has been conducted in accordance with regulations implementing the Resource Conservation and Recovery Act of 1976 (RCRA) at both the federal and state levels. In 1984 a Hazardous Waste Storage Permit was issued jointly by the U.S. Environmental Protection Agency (EPA) and the DEQ to UMCD. The conditions of the 1984 Storage Permit defined how UMCD would manage hazardous wastes generated by operational activities not involving chemical weapons.
The storage of chemical munitions that have been declared waste (waste CMs), and the agent-contaminated wastes that result from maintenance of the chemical weapons, are regulated separately under the RCRA "Interim Status" provisions of 40 CFR 265 and other applicable RCRA regulations, as adopted in Oregon Administrative Rules(OARs). In March 2001 changes in the OARS called for the chemical weapons and bulk items in the UMCD inventory to be classified as hazardous wastes. The storage units have been upgraded to the meet the new requirements and an increased monitoring schedule has been implemented. DEQ inspects the UMCD every quarter, and conducts a joint inspection with the Environmental Protection Agency (EPA) at least once a year. DEQ will issue a Notice of Non-Compliance if there are any environmental violations noted during an inspection.
The 1984 Storage Permit issued to UMCD has since expired, but it will continue to apply until a new Permit is issued. A RCRA "Part B" Storage Permit Application, to update conditions applicable to hazardous waste storage operations at UMCD, was submitted by the U.S. Army and has been determined by DEQ to be substantially complete. The Permit Application review process involved resolution of storage issues with the Army, development of draft Permit language, formal comment period(s) and public meeting(s) to receive input from members of the general public and other interested parties. The RCRA Part B Storage Permit addresses conventional and agent-related wastes and governs all aspects of hazardous waste storage operations at UMCD.
The UMCDF Resource Conservation and Recovery Act (RCRA) Hazardous Waste Storage and Treatment Permit was issued in 1997. Hazardous waste activities allowed by the Permit include treatment by incineration; storage and treatment in tanks; and treatment by separation of munition components. Conditions in this Permit include requirements for waste analysis, air monitoring, training, security, emergency response, pollution prevention, design, construction, and operational parameters. The DEQ conducts weekly inspections of the UMCDF and issues a Notice of Non-Compliance if the inspectors note any environmental violations. The DEQ has a written history of enforcement actions(1987-2000) and (2001 - 2003).
The UMCDF Hazardous Waste Storage and Treatment Permit is considered an operating document, and many modifications of the document are expected to occur over the duration of the project. Modifications are required if there are alterations to the originally permitted facility, new information becomes available to the Permittee or to DEQ, or there are new regulations that apply to the facility. All Permit Modification Requests (PMR) are tracked through a DEQ database and are available in PMR report form.
RCRA Hazardous Waste Treatment and Storage Permit
Each module is updated with Permit Modifications on a quarterly basis as needed. The Module revision date is located in the upper right hand corner of each page.
The following documents are modified excerpts from the permittee’s RCRA Part B Permit Application. The listed documents are hereby incorporated, and made part of this Permit. The Department has modified specific language in the Attachments. These incorporated Attachments are enforceable Conditions of this Permit, as may be modified by the specific Permit Conditions. Specific Permit Conditions (Module I through IX), supersede the language of the Attachments if the Permit Condition and Attachment language are found to be in conflict.