Kansas Army Ammunition Plant (KSAAP) – Pesticides

“It is the EPA’s decision that the pesticides are no longer protected under “intended use” when the structures are demolished or are to be demolished. Because of this, the chemical’s “intended use” is no longer applicable, and the pesticides become ”solid waste” and subject to RCRA Section 1004(27).”
Mathy Stanislaus, US EPA, Assistant Administrator for the Office of Solid Waste and Emergency Response (OSWER)

Department of Defense Inspector General (DOD IG) 

Disagreements on Whether Applied Pesticides Require Cleanup Resulted in Potential Cost Increases and Delays

“Army program managers and the BRAC environmental coordinator at KSAAP incurred potential cost increases and delays because of disagreements among EPA Region 7, Kansas Department of Health and Environment officials, and themselves regarding the remediation of applied pesticides. Army and EPA officials discussed the cleanup of applied pesticides at KSAAP in letters spanning January 2011 to April 2012. It became apparent that their interpretations differed on the cleanup of applied pesticides. According to EPA officials, applied pesticides in the soil around buildings are considered “solid waste” under the Resource Conservation and Recovery Act (RCRA) if the buildings are demolished, and are thus potentially subject
to the corrective action terms of a RCRA permit. Army and DoD officials considered the applied pesticides to be products used as intended, not solid waste as discarded material, and therefore outside the scope of RCRA.9 According to the Army officials, it is an unexpected and extraordinary expansion of the obligations of RCRA to apply solid-waste-management requirements to soil where pesticides have been applied but “no longer serve their intended purpose.” Army officials discussed efforts to remediate the property with Kansas Department of Health and Environment officials, reaching the conclusion that the Army’s actions are in compliance with the environmental legal standards. According to Kansas Department of Health and Environment officials, Army and EPA officials were unable to reach an agreement. Army, EPA, and state environmental agency officials’ inability to reach an agreement sooner caused at least a 16-month delay in transferring the property and increased costs. According to the April 30, 2012, letter from the EPA, Army and EPA officials agreed to establish a joint work group to discuss and resolve site-specific issues to provide more consistency in addressing pesticides. As of June 2013, however, the Army reports that Army and EPA officials remain unable to reach an agreement.

EPA officials have RCRA permit authority and would not allow the closure of the RCRA permit from the phase 2 Economic Development Conveyance parcel of property (6,116 acres), because the Army and the EPA disagreed in their interpretation of the cleanup requirements for these materials. The Kansas Department of Health and Environment and the LRA resolved the RCRA permit disagreement through the Environmental Consent Order, which instituted an Environmental Use Control Program.10 The U.S. Army Corps of Engineers prepared and signed the deed for the LRA’s portion of the property in August 2012 and officially transferred 6,116 acres to the LRA.”  See: DODIG-2013-114 (Project No. D2012-D000CG-0206.000) – August 6, 2013

Pesticides at George AFB

“EPA has named aldrin and dieldrin as hazardous solid waste materials. If quantities greater than 1 pound enter the environment, the National Response Center of the federal government must be told immediately.” http://www.atsdr.cdc.gov/phs/phs.asp?id=315&tid=56#bookmark09

  • Considering the reported levels of aldrin and dieldrin at the George AFB’s “Family Housing” and that these pesticides were used liberally base-wide for years, hasn’t more than 1 pound been released into the environment at George AFB?
  • Was the National Response Center notified by the AF of the release of aldrin and dieldrin?
  • How did the AF dispose of the aldrin and dieldrin when the AF stopped using it?
  • How much aldrin and dieldrin, and how, did the AF dispose of at George AFB?

When the AF stopped using DDT at George AFB they buried it.

TitleAuthorDocument DateAR #
Phase I, Records Search Report, Vol I of IICH2M Hill01/01/19823

Page  29

“The use of DDT was discontinued in 1962.”

Page 29

“a large quantity of DDT was reportedly buried east of the present sewage percolation ponds.”

Page 48

“Site No. 8—8 — located east of alert hangar and southeast of Site No. 5. An unverified report of DDT, copper sulfate, and leaded paint disposal in – this site was made.”

Source: Air Force Administrative Record

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