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Fact Sheet

Hazardous Waste Permit Modification
Iowa Army Ammunition Plant

BACKGROUND: The U.S. Environmental Protection Agency (EPA) issued a hazardous waste management permit to the Iowa Army Ammunition Plant (IAAAP), Middletown, Iowa, November 8, 1989. Changes and additions to the permit were made October 13, 1995, when IAAAP was granted a Class 3 permit modification. This permit allows IAAAP to store hazardous wastes in eight storage units and operate two treatment tanks and one incinerator. The storage units may hold spent solvents, corrosive solutions, incinerator ash, open burning/open detonation ash, and waste explosives, including explosives-contaminated materials. The treatment tanks are used to treat wastewaters generated in on-site laboratories. The incinerator -- called the Explosive Waste Incinerator -- is used to destroy explosive wastes.

IAAAP has also closed four areas of the facility for which they did not seek operating permits: the gravel filter beds and the treatment tanks at the Line 6 area, the billet splitter, and the waste laboratory chemical storage in Building 1-03-7.

IAAAP has closed several permitted hazardous waste treatment units, including 14 treatment tanks at Line 4A, the black powder treatment system at Line 6 and the deactivation furnace (an incinerator). These units have been deleted from the permit and can no longer be used for hazardous waste management.

IAAAP is also authorized to conduct miscellaneous hazardous waste treatment operations. These miscellaneous operations include open burning, open detonation, and other destructive treatments. They are conducted under interim status until a final permit decision is made on them.

PERMIT MODIFICATIONS: IAAAP requested a Class 3 permit modification January 30, 1996, to add additional storage in Building 23-53. This is an existing building that will be modified to meet EPA's regulations for storage of hazardous wastes. It is intended for wastes received from off-site hazardous waste generators for storage and treatment in on-site units. Wastes to be stored in the proposed storage area include spent solvents, corrosive solutions, incinerator ash, open burning/open detonation ash, and waste explosives, including explosives-contaminated materials.

A Resource Conservation and Recovery Act (RCRA) permit establishes a facility's operating conditions for managing hazardous waste. A modification to a facility's RCRA permit becomes necessary when a facility needs to modify equipment or operating procedures. Modifications are categorized in three classes. IAAAP can make Class 1 modifications by notifying EPA and persons on its mailing list of the changes.

A facility must receive EPA approval for Class 2 or Class 3 modifications. To request a Class 2 or 3 modification, a facility must publish a notice in a major local newspaper. The newspaper notice marks the beginning of a public comment period, when the public can review the proposed modifications. The facility must also hold a public meeting. All comments are considered by EPA before a final decision is made on the modification request.

IAAAP requested several Class 3 permit modifications in April 1993. EPA added Building BG-12 to that modification request because the application for it was received too late to have been included in the original (1989) permit. IAAAP requested a Class 3 modification for an additional hazardous waste storage facility in February 1995 for Igloo C-13. These modifications to the permit were approved by EPA October 13, 1995.

PUBLIC INVOLVEMENT: IAAAP has conducted the following public involvement activities for the modification request for Building 23-53:

CORRECTIVE ACTION: All permits issued by EPA after the RCRA Hazardous and Solid Waste Amendments of 1984 were enacted must contain provisions for corrective action if there have been any releases of hazardous waste or hazardous constituents from solid waste management units. EPA completed an assessment of the IAAAP facility and reported in September 1987 that releases had occurred.

EPA had also entered into an interagency agree- ment with the Department of Defense September 20, 1990, to further clean up the site under the Comprehensive Environmental Response, Compensation and Liability Act (Superfund). The permit allows RCRA and Superfund activities at the site to be coordinated under this agreement. EPA can require IAAAP to do additional remedial work if the Superfund remedial activities do not satisfy RCRA requirements.

INFORMATION AVAILABILITY, PUBLIC HEARING AND COMMENT PERIOD: The administrative record, which includes the draft permit, the permit application, and other background information, is available for public review from November 6, 1996, to December 21, 1996, at the Burlington Public Library; the Iowa Department of Natural Resources (IDNR) office, Des Moines; IDNR Southeast Region, Washington, Iowa; and the EPA Region 7 Information Center, Kansas City, Kansas.

A public hearing for this permit modification request has not been scheduled. EPA will hold a public hearing if a written notice of opposition to the draft permit and request for a hearing is received by December 23, 1996. The notice of opposition and request should be sent to Ken Herstowski at the address below. EPA will provide notice of a public hearing at least 30 days in advance.

Public comments on the draft permit modification are requested. The comment period starts with the publication of a public notice in The Hawk Eye November 6, 1996, and ends December 21, 1996. Comments should be submitted to Ken Herstowski at the address below. If a public hearing is held, the comment period will automatically be extended to the close of the hearing.

Anyone wishing to obtain the index from the administrative record, or specific documents, and anyone who wants to be included on the mailing list to receive information on RCRA permit actions at the IAAAP facility, should contact: 

                  Ken Herstowski, ARTD/RCRA
                      U.S. EPA Region 7
                    726 Minnesota Avenue
                  Kansas City, Kansas 66101
                    Phone:  913-551-7631 
                      Fax:  913-551-7947
           Internet:  herstowski.ken@epamail.epa.gov
Mr. Herstowski may also be contacted through Region 7's toll-free Environmental Action Line, 800-223-0425.

Copies of the fact sheet and draft permit modification may also be obtained from EPA Region 7's web site at http://www.epa.gov/region07.

 

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