Chemical Waste Management, Inc. Emelle, Alabama EPA I.D. Number ALD FACT SHEET

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1 Chemical Waste Management, Inc. Emelle, Alabama EPA I.D. Number ALD FACT SHEET A draft Alabama Hazardous Wastes Management and Minimization Act (AHWMMA) variance has been prepared for the Chemical Waste Management, Inc. facility. This hazardous waste treatment, storage and disposal facility is located in Emelle, Alabama. This fact sheet has been prepared to briefly advise the public of the principal issues of the variance. I. VARIANCE PROCESS Chemical Waste Management, Inc. has submitted a request for a variance from a treatment standard in accordance with ADEM Admin. Code r (5). If approved, Chemical Waste Management, Inc. would be required to comply with hazardous waste management conditions established during the effective period of the variance, which would end six months from the variance issuance date. II. PROCEDURES FOR REACHING A FINAL DECISION The Alabama Department of Environmental Management (ADEM or Department) is proposing to issue Chemical Waste Management, Inc. a variance from a treatment standard for disposal of hazardous debris (concrete filled rocket missile casings generated at Redstone Arsenal, Huntsville AL). ADEM Admin. Code r (5) incorporates by reference 40 CFR , which describes the requirements for a variance from a treatment standard. The Department is soliciting public comment on the proposed issuance of a variance. The Department will accept public comment for a period of 30 days beginning on July 13, All persons wishing to comment on the proposed variance or the variance petition should submit comments in writing to the Alabama Department of Environmental Management, Permits and Services Division, 1400 Coliseum Blvd. (zip ), P.O. Box (zip ) Montgomery, Alabama, ATTENTION: Mr. Russell A. Kelly. ADEM will consider all written comments received during the comment period when making a final decision regarding the proposed variance. When the Department makes a final decision, notice will be given to the applicant and to each person who has submitted written comments or requested notice of the final decision. III. FACILITY DESCRIPTION Chemical Waste Management, Inc. is a hazardous waste treatment, storage and disposal facility operating under AHWMMA Permit Number ALD This facility manages hazardous waste in containers, tanks, and containment buildings, and disposes of waste in its landfill. IV. SUMMARY OF PROPOSED VARIANCE ADEM Admin. Code r (5) incorporates by reference 40 CFR , which describes the requirements for a variance from a treatment standard. Based on 40 CFR , the Department may approve a site-specific variance from an applicable treatment standard if it is inappropriate to require the waste to be treated to the level specified in the treatment standard or by the method specified in the treatment standard, even though such treatment is technically possible. Based on information submitted by Redstone Arsenal (generator) and CWM, the Department has confirmed that the subject waste stream (concrete filled rocket missile casings) are inert motors that

2 were used for training purposes only. They have been characterized with the Resource Conservation and Recovery Act (RCRA) waste codes for cadmium (D006) and chromium (D007). These concrete filled rocket missile casings come in three stages (14 Total Casings): 1) Five stage one casings. a. HQ weighs 37,780 pounds and is 187 inches in length by 74 inches in b. HQ weighs 37,900 pounds and is 187 inches in length by 74 inches in c. HQ weighs 37,700 pounds and is 187 inches in length by 74 inches in d. HQ weighs 38,180 pounds and is 187 inches in length by 74 inches in e. HQ weighs 21,520 pounds and is 187 inches in length by 74 inches in 2) Four stage two casings. a. HQ weighs 37,780 pounds and is 97 inches in length by 74 inches in b. HQ weighs 37,900 pounds and is 97 inches in length by 74 inches in c. HQ weighs 37,700 pounds and is 97 inches in length by 74 inches in d. HQ weighs 38,180 pounds and is 97 inches in length by 74 inches in 3) Five stage three casings. a. HQ weighs 19,300 pounds and is inches in length by 31.8 inches in b. HQ weighs 10,120 pounds and is inches in length by 31.8 inches in c. HQ weighs 10,120 pounds and is inches in length by 31.8 inches in d. HQ weighs 3,860 pounds and is inches in length by 31.8 inches in e. HQ weighs 3,860 pounds and is inches in length by 31.8 inches in Based on a demonstration provided by Chemical Waste Management, Inc. in the variance petition, the Department has determined that the applicable treatment standard is technically possible but is inappropriate to require based on conditions present in the waste. The motors have never contained any propellant and were manufactured with concrete cores and are surrounded by a Kevlar / non-friable asbestos resin exterior coating. VI. TECHNICAL CONTACT Mr. Lanny Sasser Compliance and Enforcement Section Industrial Hazardous Waste Branch, Land Division Alabama Department of Environmental Management 1400 Coliseum Blvd (zip ) P.O. Box (zip ) Montgomery, Alabama (334)

3 VARIANCE FROM A HAZARDOUS WASTE TREATMENT STANDARD FACILITY NAME: CHEMICAL WASTE MANAGEMENT, INC. ADDRESS: ALABAMA HIGHWAY 17 EMELLE, ALABAMA EPA IDENTIFICATION NUMBER: TYPE OF VARIANCE: MATERIALS APPROVED: ALD TREATMENT STANDARD FOR DISPOSAL OF HAZARDOUS DEBRIS 14 CONCRETE FILLED ROCKET MISSILE CASINGS GENERATED AT REDSTONE ARSENAL In accordance with and subject to the provisions of the Hazardous Wastes Management Act of 1978, as amended, Code of Alabama 1975, to , the Alabama Environmental Management Act, as amended, Code of Alabama 1975, 22-22A-1 to 22-22A-15, and the rules and regulations adopted thereunder, and subject further to the conditions set forth in this variance, the above named facility is hereby granted a variance from the treatment standards for the above listed materials. ISSUANCE DATE: EFFECTIVE DATE: EXPIRATION DATE: MONTH DAY, YEAR MONTH DAY, YEAR MONTH DAY, YEAR Alabama Department of Environmental Management

4 Chemical Waste Management, Inc. ALD Variance from a Hazardous Waste Treatment Standard Page 2 of 3 PART I MATERIALS COVERED BY VARIANCE A. Fourteen (14) concrete filled rocket missile casings generated at Redstone Arsenal (Huntsville, Madison County, Alabama, EPA ID Number AL ) that have been characterized with the AHWMMA waste codes for cadmium (D006) and chromium (D007) and have been approved for a variance from a land disposal treatment standard of a hazardous debris pursuant to ADEM Admin. Code r (5) incorporating by reference 40 CFR , which describes the requirements for a variance from a treatment standard. PART II MATERIALS TRANSPORTATION MANAGEMENT REQUIREMENTS A. The facility, its agents and employees shall be familiar with the manifest and reporting requirements of ADEM Admin. Code r B. The facility, its agents and employees shall be familiar with the manifest and reporting requirements of ADEM Admin. Code R In addition to the reports required by such rule, a written report of any spill during loading or unloading shall be filed with the Land Division of the Department not later than 15 days after such spill. C. The facility shall allow, at all reasonable times, representatives of the Department, upon presentation of credentials, to enter the permittee's premises, including, but not limited to, vehicles, loading and unloading facilities or any place where records required by the ADEM Admin. Code are kept, for the purpose of inspection to determine compliance with the ADEM Admin. Code and this permit. At all reasonable times, representatives of the Department shall be allowed access to and the right to copy all records required by the ADEM Admin. Code and the conditions of this permit. All inspection reports and other data collected shall be available for public inspection unless the permittee makes a showing in compliance with Code of Alabama that such information is entitled to confidentiality. PART III EFFECT OF VARIANCE A. Issuance of this variance does not convey any property rights of any sort or any exclusive privilege. B. The issuance of this variance does not authorize injury to persons or property or invasion of other private rights, or any infringement of federal, State of Alabama or local laws or regulations or preclude the institution of any legal action for violation of such laws or regulations. PART IV REVOCATION, SUSPENSION AND MODIFICATION OF VARIANCES A. The Department may, at any time, revoke or terminate this variance if the facility fails to comply with all applicable provisions of the Hazardous Wastes Management Act of 1978, as amended, Code of Alabama 1975, to , the Alabama Environmental Management Act, as amended, Code of Alabama 1975, 22-22A-1 to 22-22A-15, and the rules and regulations adopted thereunder, and subject further to the conditions set forth in this variance. B. The Department may, at any time, suspend this variance for any of the causes for termination listed above.

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