Cal/EPA Base Closure Env. Advisory Group meeting.

[zweifel@nexus.chapman.edu]

Posting from Don Zweifel <zweifel@nexus.chapman.edu>
Subject: Cal/EPA Base Closure Env. Advisory Group meeting.

To: Fellow net recipients

 Our advisory panel met on 12 July 1995 at San Francisco State 
University. 

 We were privileged to hear Julie Anderson speak on behalf of the 
USEPA's Region IX as one of its directors. Julie indicated that her 
organization has been mandated to establish new regulations pertaining to 
UXO's or Unexploded Ordnance by 31 Oct. of this year. 

 " A UXO may be categorized as corrosive, toxic, ignitable and/or
reactive, any one of which would be actionable," she stated. The question 
one might ask is when do UXO's become a RCRA (Resource Conservation and 
Recovery Act) solid waste? This is a concern that the USEPA is currently 
addressing.

 One rule of thumb seems to be that ordnance utilized for its intended
purposes are not covered under RCRA. Firing ranges become solid waste 
mgmt sites that warrant RCRA corrective action because of the hazardous wastes 
from UXOs, and we might add, exploded ordnances including the numerous 
slugs manufactured from lead and copper. Each of these sites most 
probably, have literally tons of lead deposited in the revetments 
(which act as backstops for the spent ordnance!).

 Recycling these minerals would be the most expeditious and 
cost-effective methodology, n'est ce pas?

 The USEPA has a draft document available regarding RCRA UXOs that
we believe pertains to an RRA (Relative Risk Assessment).

 The next presentation was by Al Hurt, Deputy West Coast 
interagency exec. for DON (Dept. of the Navy). Al spoke on the BRAC DoD 
budget update.

 In essence, he alluded to a important revision in the budget 
strategy. BCT or BRAC Clean-up Team priorities will be more reuse driven.
There will be a "bias to clean-up" rather than studying a site to death.
And a new emphasis or bias to "high relative risk," in other words, 
tackling that which is most hazardous to human health or potentially so.

 Basically Congress is not satisfied with the snail's pace that 
remediation has been on, and has therefore tried to build a fire under 
the regulators and DoD to expedite clean-up or expect to find BRAC and 
DERA funding cut to the bone.

More later...
 Don Zweifel