Kay Ivey
June 2, 2022
ELECTRONICALLY TRANSMITTED
Jason Braxton, P.E.
Environmental Division Chief
Environmental Management Division
US Army Garrison-Redstone Arsenal
4488 Martin Rd.
Redstone Arsenal, AL. 35898
RE: Emergency Permit
Redstone Arsenal (RSA)
Redstone Arsenal, Madison County, Alabama
U.S. EPA ID No. AL7 210 020 742
Dear Mr. Braxton:
The Alabama Department of Environmental Management (ADEM) has made a final determination to
issue an Alabama Hazardous Wastes Management and Minimization Act Emergency Permit to the U.S.
Department of the Army, Redstone Arsenal. The permit is approved as of this date and a public comment
period will be held from June 10, 2022 to July 25, 2022.
Enclosed is the issued emergency permit. If questions and comments arise concerning this matter, please
contact Ms. Heather Guerrero of the Remediation Engineering Section at (334) 271-7738 or via e-mail at
heather.guerrero@adem.alabama.gov
.
Sincerely,
Stephen A. Cobb, Chief
Land Division
Enclosures
cc/via email: Austin York, Redstone Arsenal Kelley Hartley, ADEM
Clint Howard, Redstone Arsenal Daniel Arthur, ADEM
Austin York, Redstone Arsenal Kevin Greaney, US EPA Region IV
Yolanda Negroni, CTR Robert Pope, US EPA Region IV
Brian Roberson, NASA MSFC Robert Morris, US EPA Region IV
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HAZARDOUS WASTE EMERGENCY PERMIT
STATEMENT OF BASIS
US EPA Identification Number: AL7 210 020 742
Facility Name: U.S. Army, Garrison Redstone
U.S. Army Aviation and Missile Research
Development and Engineering Center
(AMRDEC)
Location: Huntsville, Madison County
Type of Hazardous
Waste Management:
Treatment
Permit Duration:
June 02, 2022 through June 17, 2022
The conditions in this permit are based on standards promulgated under Chapters 335-14-2, 335-14-
3, 335-14-5, 335-14-7, and 335-14-8 of the ADEM Administrative Code.
The wastes covered by this permit consist of components and/or completed missiles of the SA-6, a
two stage, solid fuel, low altitude surface-to-air guided missile system, and a classified surface-to-air
guided missile system. The following items are currently stored at the U. S. Department of the
Army, Redstone Arsenal (RSA):
• Two (2) complete SA-6 surface-to-air guided missile systems, each one comprised of a
guidance system, a solid rocket motor, and a warhead (619.37 lbs net explosive weight
(NEW) per item)
• Two (2) incomplete SA-6 surface-to-air guided missile systems, each one comprised of a
solid rocket motor and warhead (619.37 lbs NEW per item)
• Six (6) SA-6 surface-to-air guided missile system solid rocket motors (564.38lbs NEW per
item)
• One (1) classified surface-to-air guided missile system motor (768.30 lbs NEW)
Each SA-6 rocket motor contains potassium nitrate and magnesium. Each SA-6 warhead contains
hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) and 2,4,6-trinitrotoluene (TNT). The classified system
rocket motor contains ammonium perchlorate.
These items (some of which have been launched in theater) have been in storage for nearly two
decades at RSA; however, due to flooding, they are deemed unstable/unsafe and too damaged for off-
post travel. The demilitarization treatment described in this permit was determined to be the safest
and most effective technology available.
This permit allows for implementation of on-site treatment of the listed items using thermal
treatment, by open detonation or open burning. RSA is currently authorized to conduct Open
Burning and Open Detonation (OB/OD) operations at two units regulated by the Resource
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Conservation and Recovery Act (RCRA) and in accordance with the ADEM Administrative Code
Rules 335-14-6-.16(13) and 335-14-6-.16(14). However, the listed items have been deemed too large
for processing at RSA’s OB/OD areas; therefore, the systems will be processed at Test Area 1 (TA-
1).
The issuance of this permit will result in environmental and safety benefits as compared to the
current storage of this hazardous waste. The conditions of this permit are designed to protect public
health and the environment. The treatment will be performed at TA-1 at RSA to minimize risk to the
public, and will continue until the treatment is complete or expiration of this permit.
Issuance of an emergency permit under ADEM Administrative Code R. 335-14-8-.06(1) is warranted
because there is an imminent and substantial endangerment to human health and the environment due
to the potential instability of the waste and the lack of available treatment alternatives.
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HAZARDOUS WASTE
FACILITY PERMIT
ISSUED TO: United States Department of the Army, Redstone Arsenal
EPA ID/PERMIT NUMBER: AL7 210 020 742
LOCATION: Huntsville, Madison County, Alabama,
Latitude 34° 36' 39.82" and Longitude - 86° 40' 37.15"
UNITS PERMITTED: Emergency Treatment at Test Area (TA) 1
EFFECTIVE DATE: June 02, 2022
EXPIRATION DATE: June 17, 2022
This Permit is issued pursuant with the Code of Alabama 1975, §§ 22-30-1-et. seq., as amended,
and regulations adopted thereunder and the Hazardous Waste Management and Minimization
Act and in accordance with the plans and specifications and applications filed with the
Department subject to the conditions appended hereto, all of which are considered a part of this
Permit. This Permit shall be subject to all applicable laws of the State of Alabama, rules and
regulations and orders of the Department of Environmental Management and shall be effective
from the date of issuance.
__________________________________________
Alabama Department of Environmental Management
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HAZARDOUS WASTE EMERGENCY PERMIT
US EPA Identification No./Permit No. AL7 210 020 742
Name of Permittee/Operator:
U.S. Department of the Army,
Redstone Arsenal
Operator:
U.S. Department of the Army,
Redstone Arsenal
Facility Location:
Madison County, Alabama
35898
Effective Date:
June 02, 2022
Expiration Date:
June 17, 2022
In compliance with the provisions of the Alabama Hazardous Wastes Management and
Minimization Act, as amended, the Permittee is authorized to conduct hazardous waste
management activities including:
_____Storage
__*__Treatment
_____Disposal
at the facility location in accordance with the provisions and conditions attached to this permit.
___________________________________________ __________
Alabama Department of Environmental Management Date
6/2/2022
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A. WASTE LIST
The following hazardous wastes may be treated at this facility:
Waste Number
Common Name/Description
Total Quantity
D003, D006,
D008
Reactive/Energetic, Cadmium,
Lead
• Two (2) complete SA-6 surface-to-air
guided missile systems, each one
comprised of a guidance system, a solid
rocket motor, and a warhead (619.37 lbs
NEW per item)
• Two (2) incomplete SA-6 surface-to-air
guided missile systems, each one
comprised of a of a solid rocket motor
and warhead only (619.37 lbs NEW per
item)
• Six (6) SA-6 surface-to-air guided
missile system solid rocket motors
(564.38lbs NEW per item)
• One (1) classified surface-to-air guided
missile system motor (768.30 lbs NEW)
B.
HAZARDOUS WASTE TREATMENT, STORAGE, DISPOSAL UNITS LIST
The following hazardous waste management units are covered by the permit: Emergency
Treatment at Test Area 1 (TA-1).
1.
Process Description
Design Capacity
treatment, by open detonation or open
burning. This action will be performed at TA-
1 at Redstone Arsenal.
under clear weather conditions. The systems
are not to be treated if there is more than 80
percent cloud cover.
Restrictions
(a)
No more than two (2) items shall be processed per event
(b)
Only like items shall be processed per event (i.e., complete SA-6 systems shall be
treated together, incomplete SA-6 systems shall be treated together, etc.)
(c)
Management of the waste shall be in accordance with the approved plan and Section
B.5 of this permit.
(d)
Explosives Ordnance Disposal (EOD) will be in charge of the treatment.
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(e)
Redstone Test Center and Aviation and Missile Command (AMCOM) safety
representatives will be onsite to provide observation and coordination during the
transportation and demilitarization treatment operations.
(f)
The TA-1 Range Safety Officer will be onsite during the demilitarization activities for
observation and coordination.
(g)
The treatment of chemical agents, nuclear or radioactive materials, biological agents,
depleted uranium, or items containing or contaminated with these materials is expressly
prohibited.
3.
Transportation Conditions
(a)
The treatment area shall be secured. All nonessential personnel shall be evacuated
from the immediate area during removal of the unstable compounds from storage,
transportation to the treatment area, and placement in the treatment area. Road
barricades will be placed to prevent unauthorized entry to the storage and treatment
areas.
(b)
The items shall be properly containerized for transportation to ensure stability
during movement to the treatment area.
(c)
Items shall be transported from the storage area to the TA-1 treatment area only on
the day they are to be processed.
(d)
The predetermined route of travel shall be directly from the systems’ storage
location on East Line Road to the TA-1 treatment area on Centerline Road. Two
routes between the systems’ storage location and TA-1 have been selected: the
primary route along East Line Road, West Line Road, Buxton Road, Dodd Road
through the alternate TA-1 gate until final location on Centerline Road. The
alternate route along East Line Road, West Line Road, Redstone Road, Patton Road,
and Flight Road through the main TA-1 gate until final location on Centerline Road.
The truck driver shall have a commercial driver's license and local ammunition
hauler certification.
(e)
The route of travel between the storage area and the treatment area shall be secured
by emergency personnel prior to transport, and shall be cleared of non-essential
traffic during the transport procedures.
(f)
AMCOM safety and EOD personnel will escort the transport truck from the storage
area to the treatment area.
4.
Storage Conditions
Cradles will be placed on the transport truck and the unstable missile
systems/components and containers will be placed in the cradles and strapped down. The
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missile containers shall remain at their current location until the appropriate time for
removal for treatment.
5.
Treatment Conditions
The unstable missile systems/components and containers will be treated at Redstone
Arsenal’s TA -1, and treatment will be performed by the EOD team personnel trained in
munitions /propellant handling and OB/OD operations. Treatment will be accomplished
using open detonation or open burning during daylight hours; commencing no sooner than
one hour after sunrise and ending no later than one hour before sunset. The EOD Team will
decide the treatment method in accordance with ADEM Admin. Code r. 335-14-7-.13(5),
based on atmospheric and other conditions on the day of treatment. The EOD Team will
requisition donor material as required to complete the treatment. After treatment, any
residues will be properly disposed.
C.
GENERAL CONDITIONS
1. Duration of Permit (Rules 335-14-8-.05 and 335-14-8-.06(1))
(a)
This permit is issued from June 02, 2022 through June 17, 2022.
(b)
This permit may be terminated by the Department at any time without process if it
is determined that termination is appropriate to protect human health and the
environment.
(c)
In the event that treatment of the munitions cannot
be completed prior to the
expiration date of this permit due to safety, weather, logistical or other reasons,
Redstone Arsenal may/shall apply for a one-time renewal of the permit.
2. Duty to Comply (Rule 335-14-8-.03(l)(a))
The Permittee shall comply with all conditions of this permit. All words used in this permit
shall have the meaning and definitions set forth in Chapter 335-14-8 of the ADEM
Administrative Code. The operation of the facility shall be in accordance with the
conditions agreed to with ADEM. The conditions have been incorporated as part of the
permit. The filing of a request by the Permittee for a permit modification, revocation, re-
issuance, termination, planned changes or anticipated noncompliance does not stay any
condition of this permit. Any permit noncompliance constitutes a violation of the ADEM
Administrative Code and is grounds for enforcement action including permit termination,
revocation and re-issuance, or modification or for denial of a permit renewal application.
In addition, criminal or civil actions may be brought in appropriate instances.
3. Imminent Hazard Action (Rule 335-14-5-.01(4)
Notwithstanding any other provision of these Rules, enforcement actions may be
brought pursuant to Section 7003 of RCRA and AHWMMA.
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4. Duty to Mitigate (Rule 335-14-8-.03(1)(d))
The Permittee shall take all reasonable steps to minimize or correct any adverse impact
on the environment resulting from noncompliance with this permit.
5.
Personnel Training (Rule 335-14-5-.02(7))
Contact with the wastes will be limited to personnel adequately trained in the handling
of
reactive and flammable wastes.
6.
Emergency Coordinator (Rule 335-14-5-.04(6))
The Permittee will ensure that at all times there is at least one employee either on the
premises or on call (i.e., available to respond to an emergency by reaching the facility
within a short period of time) with the responsibility for coordinating all emergency
response measures.
The emergency coordinator must, in addition to carrying out the responsibilities
specified in Rule 335-14-5-.04(7) of the ADEM Administrative Code, be thoroughly
familiar with all operations and activities at the facility, and the location layout. In
addition, this person must have the authority to commit the resources needed to carry out
all emergency response measures.
7.
Proper Operation and Maintenance (Rule 335-14-5-.03(2))
The Permittee must maintain and operate the facility in a manner to minimize the
possibility of any unplanned fire, explosion, or sudden or non-sudden release of
hazardous waste or hazardous waste constituents to air, soil, and surface water, which
could threaten human health or the environment.
8. Security (Rule 335-14-5-.02(5))
The Permittee must prevent the unknowing entry and minimize the possibility for the
unauthorized entry of persons or livestock onto the active portions of the facility by
means of:
(a)
A surveillance system that continuously monitors and controls entry onto the
active portion of the facility.
(b)
An artificial or natural barrier that completely surrounds the active portion of the
facility and a means to control entry, at all times, through gates or other entrances
to the active portion of the facility.
(c)
In addition, the facility must post a sign with the legend "DANGER -
UNAUTHORIZED PERSONNEL KEEP OUT", at each entrance to the active
portion of the facility, and at other locations, in sufficient numbers to be seen from
any approach to this active portion. This legend must be written in English and any
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other language predominant in the area surrounding the facility and must be legible
from a distance of at least 25 feet. Existing signs with a legend other than
"DANGER - UNAUTHORIZED PERSONNEL KEEP OUT" may be used if the
wording on the sign indicates that only authorized personnel are allowed to enter the
active portion and that entry onto the active portion can be dangerous.
9.
Access to Communications or Alarm System (Rule 335-14-5-.03(5))
Whenever hazardous waste is being loaded, unloaded, or otherwise handled, the Permittee
must ensure that all personnel involved in the operation will have immediate access to an
internal alarm or emergency communication device, either directly or
through visual or
voice contact with another employee.
10.
General Inspection Requirements (Rule 335-14-5-.02(6))
The Permittee must inspect the site prior to the unloading or managing any waste to ensure
that only authorized personnel are present.
11.
General Requirements for Ignitable, Reactive or Incompatible Waste (Rule 335-14-5-.02(8))
The Permittee must take precautions to prevent accidental ignition or reaction of
ignitable
or reactive waste.
12.
Arrangements with Local Authorities (Rule 335-14-5-.03(8))
The Permittee must assure that the following arrangements have been made with the
local
authorities (unless otherwise specified):
(a) Arrangements made to familiarize police, fire departments, and emergency
response teams with the layout of the facility, properties of hazardous waste handled
at the facility and associated hazards, places where facility personnel will normally
be
working, entrances to and roads inside the facility, and possible evacuation
routes;
(b) Agreements designating primary emergency authority to a specific police and a
specific fire department, and agreements with any other to provide support to the
primary emergency authority;
(c) Agreements with State emergency response teams, emergency response
contractors, and equipment suppliers; and
(d) Arrangements to familiarize local hospitals with the properties of hazardous waste
handled at the facility and the types of injuries or illnesses that cou ld result from
fire, explosions, or releases at the facility.
(e) RTC Safety and AMCOM Safety will coordinate with U.S. Army Garrison (USAG)
Redstone Arsenal Fire and Emergency Services for on-site support to assist in
the
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event of fire or personal injury emergences.
(f) EOD personnel will be responsible for the treatment of the waste material.
13.
Identification Number (Rule 335-14-5-.02(2))
An EPA Identification Number has been assigned to the facility: AL7 210 020 742
14.
Closure (Rule 335-14-5-.07(2))
(a) All fragments, debris, and treatment residuals shall be collected and properly
disposed.
(b) A visual inspection of the treatment site shall be performed to ensure all fragments,
debris, and treatment residuals have been removed.
(c) Any shrapnel with what appears to be explosive residue shall be placed in an OD pit at
TA-1 and processed. Any remaining scrap shall be placed in a bin and transported to
the facility’s permitted OB unit and flashed, which involves placing the debris in a burn
pan with donor material and additional burning to ensure that any explosive residue is
consumed (flashed).
(d) At the completion of processing the systems, surface and subsurface soil samples shall
be collected and submitted to an analytical laboratory for testing. The testing shall
include explosives, metals and perchlorate. The testing shall be completed using US
EPA Method SW-846, number 8330, 6020 and 6850, respectively.
15. Reporting (Rule 335-14-5-.05(8))
The Permittee shall submit to the Alabama Department of Environmental Management the
following information:
(a) The EPA identification number.
(b) The actual dates and times of treatment.
(c) A description of and the quantity of each container of waste that is stored and/or
treated.
(d) Name of emergency coordinator.
(e) Copy of all analytical reports and a description of the sampling and analytical
methods used.
(f) A certification that the emergency has been alleviated.