2001 CPEO Military List Archive

From: CPEO Moderator <cpeo@cpeo.org>
Date: 29 Jan 2001 20:08:44 -0000
Reply: cpeo-military
US EPA Region 4
January 24, 2001


The U.S. Environmental Protection Agency (EPA), in consultation with the
Tennessee Department of Environment and Conservation (TDEC), announced today
that an Administrative Order has been issued to Volunteer Army Ammunition Plant
(VAAP), requiring corrective action at the now defunct U.S. Army TNT
manufacturing facility in Chattanooga, Tennessee. The order was issued on
January 19, 2001 under the authority of Section 3008(h) of the Resource
Conservation and Recovery Act (RCRA), as amended. 

The Order directs the Army to fully evaluate the nature and extent of releases
of hazardous waste and constituents into the environment and to take corrective
action necessary to mitigate any migration of releases at or from the facility.
Under the provisions of the Order, the Army also is responsible for addressing
contamination that has migrated to property not currently owned by the Army.
This order is not directed to the City of Chattanooga or Hamilton County in any
manner regarding their recently acquired 940-acre tract.

The purpose of this order is to ensure and require a sustained and appropriate
level of cleanup response from the Army. The Agency and TDEC expect the
issuance of the order to raise the priority the Army places on response to
contamination of the facility. Future property transfers will not relieve the
Army of its obligations under the Order.

Under the terms of the order, the Army is required to do the following:

perform a RCRA Facility Assessment on the entire plant to identity areas of
contamination that have not yet been discovered; 

prepare a Current Conditions Report for all areas of known contamination or
areas that warrant further environmental investigation; 

perform Interim Stabilization Measures, if necessary, to protect threats to
human health and the environment; 

perform a RCRA Facility Investigation (RFI) to determine the nature and extent
of any release of hazardous waste/constituents; 

perform a Corrective Measures Study (CMS) to identify and evaluate alternatives
and identify the most environmentally beneficial corrective measure(s); 

and, implement the corrective measure(s) selected by EPA in consultation with

All work done under the Order must be consistent with RCRA and its regulations.

Under EPA regulations, the Army has 30 days to appeal the Order and request a
hearing. If no request is made, the Order becomes final and effective after the
30 days. Failure or refusal to carry out the terms of the order may subject the
facility to a civil penalty not to exceed $27,500 for each day of

Public review and participation will be an integral part of the entire process
to ensure that the public is fully aware of what is proposed and conducted at
the facility. The final report of the Corrective Measures Study will be made
available for public review and comment.

VAAP began operations in July 1942 as a TNT production facility and operated
intermittently until 1977. By 1945, the facility had produced more than
800,000,000 pounds of TNT. Production facilities were modernized in the

The facility generated hazardous waste associated with TNT production and
operated an open burning hazardous waste treatment unit until 1994. The
contaminated soil associated with this unit was removed in 1999 with TDEC's
oversight and approval. Site investigations have revealed contamination in
groundwater, surface water, soil, and sediments from multiple plant processes
and waste management practices. 

0- January 24, 2001

CONTACT: Dawn Harris, EPA Media Relations, 404-562-8421

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