Sierra Army Depot Emergency Permit
Summary
SCH Number
2004058259
Public Agency
California Department of Toxic Substances Control
(DTSC)
Document Title
Sierra Army Depot Emergency Permit
Document Type
NOE - Notice of Exemption
Received
Posted
5/17/2004
Document Description
Department of Toxic Substances Control (DTSC) has granted an emergency permit to Sierra Army Depot (SIAD) to treat hazardous waste munitions by open detonation (OD) in the existing RCRA OD unit pits located in the Demolition Area within the Upper Buning Grounds. This permit is pursuant to Title 22 Cal. Code Regs., Section 66270.61. SIAD received a Notification of Ammunition Reclassification (NAR) No. NAR04-0223-0256. This NAR classified specific lots of munitions as having a stability category of D, "Less than 0.20 Remaining Effective Stabilizer (RES) - Unacceptable stabilizer loss." The permit is effective May 10 through June 28,2004.
Munitions to be treated are (55) 5 inch- 38 caliber munitions weighing a total of 840 lbs., and a total of (59) 8 inch- 55 caliber munitions weighing 4,623 lbs. The total weight of the munitions is 5,463 lbs. The emergency detonations will be conducted by US Army EOD personnel specially trained in the process of open detonation in accordance with specified Standard Operating Procedures (SOP). The detonations will occur in the OD pits which were established and used for demilitarization OD operations from the 1950's until 2001. The number and size of detonations will be controlled by safety considerations, packaging, and handling required by the specific lots once they are removed from the bunkers.
The identified munitions present a potential safety hazard and are an unacceptable risk for continued storage as bulk propellant, bulk packed components, or as separate loading propelling charges. The risk of auto-ignition of propellant in Stability Category - D increases with time. SIAD has determined that the munitions are too unstable for transportation, thus treatment by an off-site facility is not feasible and there are no alternative on-site treatment methods available. The munitions in question are too large to be handled by any available transportable treatment chamber that could be brought to the site. DTSC concurs with SIAD's assessment that alternative treatment methods are not available and the material should not be transported offsite.
Contact Information
Name
Lorraine Larsen-Hallock
Agency Name
Department of Toxic Substance Control-No Cal Permitting Branch
Contact Types
Lead/Public Agency
Phone
Location
Counties
Lassen
Other Location Info
Herlong
Notice of Exemption
Exempt Status
Emergency Project
Type, Section or Code
sec 15269 (c)
Reasons for Exemption
DTSC found that a potential for an imminent and substantial endangerment to human health and the environment exists as a result of unstable munitions within a larger munitions storage area. This temporary emergency permit is necessary to prevent such an emergency from threatening human life.
The emergency permit includes measures to minimize adverse environment impacts during the treatment, particularly those which may extend offsite. Control measures in the permit include the following:
-Munitions detonation configuration in smaller volumes and in multiple OD pits, as safety and packaging allows;
-Time delays between individual pit detonations to reduce cumulative noise and shock effects;
-Detonation under optimized atmospheric conditions to reduce noise and shock waves to the greatest extent possible;
-Use of the minimum necessary donor charges for detonation;
-SIAD will be required to address the potential waste residuals investigation and management after treatment in accordace with the proposed closure plan upon approval by DTSC;
-Air emissions will be tracked using SIAD's Munitions Analytical Compliance System computer program and reported in their annual Air Emissions Report for calendar year 2004.
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