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Open Burning/Open Detonation (OB/OD) Guidance Documents
Many Army Installations have on-site OB/OD Units in which waste military munitions are treated. Some installations operate their unit in accordance with permits issued by their state, under the authorization of Resource Conservation and Recovery Act (RCRA), as administered under the Environmental Protection Agency (EPA). Other installations operate their unit in interim status awaiting issuance of the final permit by the regulators. Permitting and operating costs for these units are expensive, in some cases exceeding $1 million. These costs present a challenge to the installation commanders regarding whether to continue operating the units and pursue a final permit; withdraw their permit application and close the unit; hold on to the permit or turn it in and proceed to closure. The OB/OD Guidance Documentation to prepare the Installation Commander for making those decisions.
OB/OD Closure/Post-Closure Guidance
As part of the overall program, USAEC developed a RCRA Subpart X guidance document for Closure/Post-Closure of OB/OD Units. This 1997 document is intended to provide technical guidance to assist Army installations in preparing closure/post-closure plans for these units. The guidance represents a compilation of regulatory information and Army-wide closure process experiences, which can minimize the cost of preparing a closure plan. In addition, recommendations are provice for what to include in the closure plan, which can potentially result in significantly reduced closure costs. This guidance document is currently available on DENIX (user account and password required) in the DoD Users File Library (OBOD1.zip through OBOD5.zip)
OB/OD Closure/Post-Closure Guidance, Update
The USAEC is in the process of updating the OB/OD Closure/Post-Closure Guidance Document. A number of changes in EPA regulations, policy and guidance have occurred since the document was originally prepared in September of 1997. The revised document will incorporate these changes, and should become available later this fiscal year.
The following major regulatory documents have been issued by the EPA subsequent to the issuance of the OB/OD closure guidance:
- "Risk-Based Clean Closure" policy memorandum (March 1998)
- Reaffirms site-specific, risk-based clean closure standards
- Clarifies acceptability of fate and transport modeling to support clean closure determinations
- New interpretation regarding non-residential exposure assumptions
- "Standards Applicable to Owners and Operators of Closed and Closing Hazardous Waste Management Facilities: Post-Closure Permit Requirements and Closure Process: Final Rule" (October 1998)
- Expands options to address site-specific environmental needs at facilities that need post-closure care
- Facilitates coordination of site-specific RCRA closure and corrective action requirements
- "Use of Monitored Natural Attenuation at Superfund, RCRA corrective Action, and Underground Storage Tanks Sites" guidance (November 1997)
- Defines role of natural attenuation in remediation
- Identifies implementation criteria for natural remediation
- Specifies performance-monitoring requirements
- "Management of Remediation Wastes Under RCRA" guidance (October 1998)
- Clarifies remediation waste management policies
- Facilitates greater remediation waste management flexibility
OB/OD Management Guide and Closure Cost Guidance Document
The USAEC developed this document to complement the Closure/Post-Closure Guidance Document and assist retail installations in making decisions about whether to close or continue to maintain an OB/OD facility. It also helps determine if closure is a viable option, and explains how to estimate and budget for the cost of closure.
Retail installations are those installations that serve troop missions, as opposed to depots or arsenals that are "wholesale" installations. Army policy, as stated in AR 200-1, is to "minimize the need for Army-owned or operated permitted hazardous waste treatment, storage, and disposal facilities." An OB/OD unit is such a facility; however, there may be instances where it is justifiable for OB/OD units to remain in use at retail installations.
This document explains the regulations that govern construction, operation and closure of OB/OD facilities, including a discussion of permitting requirements. It further explains the on-site and off-site alternatives to OB/OD (e.g., off-site incineration), the availability of those alternatives, and the tangible and intangible liabilities associated with each alternative. It also explains what is involved in closing an OB/OD facility, and the costs typically involved in such closure and long term monitoring/maintenance of closed facilities.
The cost guidance portion is designed to help affected installations determine and budget the cost of closing their OB/OD units. It was particularly designed to assist in determining out-year costs of post-closure (such as soil/groundwater monitoring). This portion contains a spreadsheet model that allows installations to input site-specific data (e.g., soil and groundwater analyses), from which final cost are determined. USAEC has developed this model with up-to-date cost data, based on recent experience.
The document also recommends the development of specific site characterization information needed to evaluate the long-term viability of the OB/OD unit. This document has been distributed to the Army, and is available on DENIX (user account and password required).
Optimization of DoD OB/OD Detonation Units
In 1988, installations were required to submit a Subpart X permit application to operate their Open Burning/Open Detonation (OB/OD) Units to the EPA or to their authorized state. Permitting costs for these units have far exceeded original estimates; some have exceeded $1 million. Even units that treat relatively small quantities have incurred substantial costs. In addition, once a unit is permitted, there are annual maintenance costs for soil and groundwater sampling and analysis and required training. These costs present a challenge to the installation commanders whether to continue pursuing a final permit or to withdraw their permit application and possibly close their unit. For those holding a final permit, the challenge is whether to keep the permit or turn it in and proceed to closure.
These challenges lead to the formation of the OB/OD Permit Optimization Focus Group (focus group) comprised of both demilitarization and environmental personnel from each of the services to perform a Department of Defense (DoD) wide evaluation of DoD capabilities and efficiencies. The evaluation was initiated in 1996 and coordinated by the Joint Ordnance Command Group (JOCG) Munitions Demilitarization/Disposal Subgroup and Environmental Subgroup, and endorsed by the OEESCM. The focus group conducted an analysis to determine the relative effectiveness of the units in terms of their mission, capacity, capability, and utilization; and develop documentation based on the recommendations. The study is a result of the Military Services desire to optimize Resource Conservation and Recovery Act (RCRA) permitted OB/OD units for DoD. The goals of the study are to reduce liability (financially and environmentally) while maintaining an optimum OB/OD capability/capacity and to demonstrate that OB/OD is protective of human health and the environment.
The Phase I report documented the initial results of the study, and was released in November 1998. This report concluded that Service actions since RCRA was enacted resulted in the withdrawal of 53 of the original 114 permit applications. Data including permit status, costs, and restrictions; installation missions, capability, capacity, and operational requirements; and roadblocks to obtaining permits was collected for the sites remaining open. The focus group modeled the data collected using the analytic hierarchical process (AHP). This modeling effort resulted in a prioritized relative effectiveness ranking of the 56 viable DoD OB/OD units evaluated. The final evaluation of DoD mission essential OB/OD units, environmental and financial implications, conclusions and recommendations for future OB/OD permit withdrawal actions and/or site closures is contained in The Phase II report "Final Analysis and Recommendations", Draft, October 1999. The Phase II Report contains final evaluation of DoD mission essential OB/OD units, environmental and financial implications, conclusions and recommendations for future OB/OD permit withdraw actions and/or site closures.
The Phase I and Phase II Optimization Reports will soon be available on DENIX (user account and password required).
OB/OD Environmental Baseline Surveys
The Focus Group also revealed the need to develop an effective way to determine the environmental viability of an OB/OD unit. Environmental baseline surveys (EBS) need to be conducted to make information available at the local level regarding the nature and extent of environmental contamination at the OB/OD sites. The EBS can be used to establish the nature, magnitude, and spatial extent of any contamination in and around the permitted facility. Data from the EBS investigations will be beneficial in:
- Formulating a permitting, closure and/or remediation strategy
- Developing budgetary closure cost estimates
- Providing critical input for conducting follow-on risk assessments
- Determining site-specific environmental performance standards
- Providing advantages to installations to better decide on pursuing a permit or proceed to a closure.