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UPDATE: EXPLO SYSTEMS, INC., CAMP MINDEN, LA

May 5, 2016

The Louisiana Military Department (LMD) is posting the redacted, Comprehensive Performance Test plan (CPT) to their website at Exithttp://geauxguard.la.gov/camp-minden-m6/camp-minden-documents.  The document describes the tests to be performed to demonstrate the Contained Burn System is in compliance.  This document is currently under review by the Environmental Protection Agency (EPA), the Louisiana Department of Environmental Quality (LDEQ) and contains Confidential Business Information (CBI). The CBI claim is made by the LMD’s contractor.  Examples of CBI in the document might include system design parameters and system schematics.  If you have feedback regarding this document, please email EPA at R6_Camp_Minden@epa.gov by May 12, 2016. 


Site Background

In 2012, an explosion occurred at the Explo Systems, Inc. operations within Camp Minden. The Louisiana State Police, the primary emergency response authority in Louisiana, responded and discovered large quantities of explosive and propellant materials improperly stored at Camp Minden. The Louisiana State Police immediately ordered Explo Systems, Inc. to store materials providing protection from the weather (heat, rain, cold) conditions. Weather conditions have a direct impact on the stabilizer used in explosives and propellants, and cause the stabilizer to deteriorate.

After completing the relocation of materials into enclosed structures (buildings and bunkers) within Camp Minden, Explo Systems, Inc. filed bankruptcy and abandoned the materials in August 2013. The Louisiana National Guard (Military Department) took ownership of the abandoned materials located on their property (Camp Minden).

In April 2014, EPA signed Administrative Order on Consent (AOC) with Hercules, Inc. to conduct a CERCLA removal action for about 3 million pounds of materials associated with previous ownership. This activity will be completed by June 2015.

On October 28, 2014, a CERCLA settlement agreement negotiated by Department of Justice was signed by EPA, LDEQ, Louisiana National Guard and Department of Army. The agreement was effective on November 4, 2015. On March 18, 2016, EPA issued a modification of the CERCLA Time-Critical Removal Action memorandum for Camp Minden. The amended action memo allowed alternative technologies to be considered in disposing of material abandoned by Explo and left deteriorating at the site.

Camp Minden is almost 15,000 acres in size and located in Webster Parish, Louisiana. The facility was formerly known as the Louisiana Military Ammunition Plant, which is a National Priorities List Superfund site primarily because of problems caused by groundwater contamination, remediation is on-going.

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Current Actions

Foundations for the Contained Burn System (CBS) are being prepared at Camp Minden. The crews have been preparing the soil, framing the slabs, and pouring the concrete. Roads on the Camp are also being surveyed and widened to allow for the delivery of the contained burn chamber. The 100 feet long and 23 feet in diameter chamber is expected to be delivered to the Camp after the first week in January 2016. The construction of the chamber and the various components of the pollution abatement system are on schedule. The components will soon be delivered and staged for installation at the Camp. The control room, air monitoring trailers, and other support structures are also being assembled.

The State of Louisiana entered into a contract with Explosive Service International (ESI) on June 17, 2015, to conduct the destruction of approximately 15,687,247 pounds of M6 propellant and approximately 320,890 pounds of Clean Burning Igniter currently stored at Camp Minden, in Minden.

The initial contract was for $19,292,648 and may be increased to approximately $34-$35 million dollars. This is based on receipt of additional funding that comes from the U.S. Treasury's Judgment Fund on behalf of the U.S. Army for the work.

Concurrently, ESI was issued a Notice to Commence Work for the contract from the Office of State Procurement.

The LMD and ESI held several community meetings where ESI discussed the destruction process. More information will be provided as soon as possible.

The EPA, in accordance with provisions of the Camp Minden Administrative Order, notified the Louisiana Military Department (LMD) that the Agency will not exercise its right to disapprove any or all contractors and/or subcontractors outlined in the states April 14, 2014 recommendation for the alternative disposal of materials at Camp Minden. EPA continues to support an alternative technology for disposal and is quickly working to conclude efforts necessary in helping the state finalize its plans.

LMD recommended Explosive Service International (ESI) and their Contained Burn method of disposal be utilized for the disposal of the 15 million pounds of M6 Propellant and 320,000 pounds Clean Burning Igniter (CBI). The recommendation includes accepting the advanced air pollution control options to maximize safety and flexibility in handling the rapidly decomposing materials and deteriorating storage and packaging materials. The EPA completed an extensive review of the state's recommendation with the safety of the public as our most important consideration.

June 30, 2015, Community Meeting Presentation by LMD Contractors (PDF)(41 pp, 2 MB, About PDF)

Final Camp Minden ARAR Letter (PDF) (23 pp, 783 K, About PDF)

May 8, EPA Response to LMD (PDF) (2 pp, 500 K, About PDF)

EPA Letter – Enclosure, Technology Comments (PDF) (2 pp, 95K, About PDF)

EPA Review of Recommendation using Dialogue Committee Attributes (PDF)  (1 pp, 15 K, About PDF)

Attachment 1 Attributes Comparison (PDF) (2 pp, 71 K, About PDF)

Attachment 2 – Attributes Efficiency (PDF)(1 pp, 464 K, About PDF)

Summary of Technology (PDF)(2 pp, 113 K, About PDF)

April 14, LMD Recommendation to EPA (PDF) (2 pp, 59 K, About PDF)

LMD Letter – Enclosure 2 Key Personnel (PDF)(10 pp, 153 K, About PDF)

LMD Letter – Enclosure 3 Relevant Projects (PDF) (8 pp, 788 K, About PDF)

LMD Letter – Enclosure 4 Relevant Projects (PDF)(19 pp, 2 MB, About PDF)

LMD Letter – Enclosure 5 Key Advantages (PDF) (2 pp, 34 K, About PDF)

LMD Letter - Enclosure 6 Pricing (PDF)(2 pp, 81 K, About PDF)

On March 18, 2016, EPA signed an amended action memo that allowed alternative technologies to be considered in disposing of the materials at the site. The amendment cleared the way for the Louisiana Military Department to review quotes for alternative methods and select a company to dispose of the M6 and CBI.

Action Memorandum Time-Critical Removal for M6 and CBI – Amended (3/18/2015) (PDF)(23 pp, 1 K, About PDF)

Earlier in March 2016, the Dialogue Committee participant's input regarding key attributes to a successful cleanup and identification of technologies that show promise for addressing the problem at Camp Minden were released in a public report. The report was the result of a tremendous commitment by the community to seek alternative solutions to address the materials at Camp Minden. It represented the culmination of endless hours of work, tireless study and research, and the incredible understanding and knowledge of the participants.

A Community Advisory Group (CAG) has been established and is holding meetings to share information about the cleanup at the site.

EPA Letter to Ron Hagar, Chairperson of Camp Minden Community Advisory Group (PDF)(1 pg, 226 K)

As work continues by LMD to complete contracting requirements for an alternative technology to dispose of material at Camp Minden, we are continuing to develop the necessary plans to support the state's efforts. Last month, EPA sought public feedback on the draft baseline sampling plan and the final plan is available. Sampling field activities began this week and will continue for 5 to 6 weeks.

On May 22, 2015, LMD officially requested written assurance from the Department of Justice and the Army that the Army would fund the alternative method of disposal.

LMD letter to US DOJ, May 22, 2015 (PDF) (2 pp, 807 K, About PDF)

On May 28, 2015 the US Department of Justice provided LMD written assurance to pay 100% of cost for on-site destruction of materials using a contained-burn system.

US DOJ letter to LMD, May 28, 2015 (PDF) (2 pp, 131 K, About PDF)

On May 28, 2015 EPA, LMD, LDEQ and Army representatives participated in a community meeting at the Doyline Baptist Church to provide an update and answer questions. A copy of the presentation is available on the Reference Documents webpage. The next community meeting is scheduled for June 11, 2015 at the Minden High School.

On April 9, EPA held the first in a series of educational workshops in the community on environmental sampling and monitoring. On April 23, EPA hosted another educational workshop on preparedness. A copy of the workshop materials is available on the Reference Documents webpage. Additional workshops are being planned at the request of participants.

On March 24, 2015 EPA released the latest Department of Army technical assistance visit (TAV) report to the public. The visit was requested by Louisiana Military Department (LMD) after discovering condensation inside one of the magazines storing materials at Camp Minden. The assistance visit of the Clean Burning Igniters (CBI) and M6 propellant was completed from March 9 to 11, 2015. On Friday, March 20, 2015, EPA and LMD received a copy of the TAV report. A copy of the full March report is available. EPA worked closely with LMD to address the recommendations by Department of Army to secure the material stored in magazines and reduce exposure to moisture. EPA also directed the offsite disposal of the nitrocellulose container. EPA and LMD will closely monitor on-site conditions and request additional technical assistance from Department of Army as needed.

EPA recognized that the legal negotiations that led to the previous remedy approach and to the Administrative Settlement Agreement between Louisiana National Guard, Louisiana Department of Environmental Quality, EPA and the Department of Army did not provide the opportunity for public comment. A Dialogue Committee made up of citizens, community leaders, local representatives and state officials was established to review alternatives.

On March 13, 2015 the Camp Minden Dialogue Facilitator's Report was released and is available.

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Future Actions

The safety of the public is our most important consideration. We agree the concerns of local elected officials and people living in the community should be addressed before proceeding to destroy the M6 propellant and other materials at Camp Minden.

Future Actions include the assembly of the CBS. Crews will connect the contained burn chamber to the pollution abatement system which includes a cyclone, catalytic reaction chambers, bag house, and HEPA filter. When the CBS is complete, the crews will run a series of tests as they begin ramping up the system. A Comprehensive Performance Test will be performed according to the prevailing regulations and that will set the parameters for the CBS to meet the strict emission standards.

Air sampling and monitoring equipment will be deployed throughout the area. This is in addition to the Continuous Emission Monitoring that will take place right at the stack of the CBS. Once the system is operating, citizens can view the daily status at the Geauxguard.com webpage.

Through a Technical Assistance Services to Communities (TASC) contract, EPA is working to provide independent technical expertise to the Citizens Advisory Group (CAG).

The December Camp Minden CAG meeting was moved to December 8, 2015, and will be attended by TASC, EPA (which will include the former Louisiana Army Ammunition Plant [LAAP] Remedial Project Manager), and the Army National Guard Project Manager (LAAP Site) to discuss the request from the CAG to sample water wells outside the post and collect surface water as it leaves the installation boundary.

A late January 2016 community meeting is being planned in conjunction with the CAG.

We look forward to finding ways to increase the involvement of local officials and the community in the remedy as we move forward in addressing the dangerous situation facing us at Camp Minden.


Site Timeline

  • October 2012 - A bunker explodes at the Explo site at Camp Minden.

  • May 2013 - Explo secures all explosives under Louisiana State Police order.

  • August 2013 – Explo abandons materials at Camp Minden.

  • October 2013 – To protect the community, EPA begins negotiations with the potentially responsible parties (PRPs).

  • April 2014 – Administrative Order of Consent (AOC) is signed with commercial PRPs.

  • October 2014 – AOC signed with DOA, LDEQ, LMD to address M6 and CBI.

  • December 2014 – Camp Minden Website goes live.

  • December 2014 – Community Meeting

  • January 2015 – Minden Dialogue Committee formed.

  • February 2015 – 1st Alternative Remedy Meeting for Minden Dialogue Committee

  • March 2015 – 2nd Alternative Remedy Meeting for Minden Dialogue Committee

  • March 2015 – Minden Dialogue Process Facilitators’ Report released.

  • April 2015 – Environmental Workshop #1, Air Monitoring

  • April 2015 – Environmental Workshop #2, Response Preparedness

  • May 2015 – Began collection of background environmental data.

  • May 2015 – Public Announcement of alternative remedy and contractor.  

  • May 2015 – Citizens Advisory Group Meeting

  • May 2015 – LMD began the best and final negotiations with Contractor.

  • May 2015 – Public Meeting: Contained Burn System

  • June 2015 – Contract Award

  • June 2015 – Public Meeting

  • July 2015 – Work Plan submitted to EPA.

  • August 2015 – Environmental Workshop #3, Work Plan and Sampling Plan

  • September 2015 – Environmental Workshop #4, LAAP Groundwater Discussion

  • November 2015 - Environmental Workshop #5, Data Results

 

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