EP 1110-1-18
24 Apr 00
agent for environmental restoration activities on FUDS, including OE response actions, and must
ensure these activities are executed in accordance with DERP.
(b) IRP. The IRP addresses contamination resulting from past operations at active
installations. The IRP is a comprehensive program to identify, investigate, and clean up such
contamination. The IRP does not address maintenance, repair, remediation, or clearing of active
ranges or disposal sites at active installations.
d. BRAC. The Base Realignment and Closure Act of 1988 (Public Law 100-526, 102
Stat. 2623) and the Defense Base Realignment and Closure Act of 1990 (Public Law 101-510,
104 Stat. 1808) provide for a recurring, systematic review and evaluation of all installations
operated by the U.S. Armed Forces. The purpose of the process is to create operational,
economic, and strategic efficiency by recommending closure and/or realignment of installations
to best serve the defense needs of the United States.
e. Resource Conservation and Recovery Act (RCRA).
(1) For OE response actions, RCRA will apply mainly as an Applicable or Relevant and
Appropriate Requirement (see paragraph 1-3g). OE recovered from an OE response action on a
FUDS, if transported off-site, may be a solid waste. This is determined on a site-specific basis
and could require application of other requirements.
(2) On-site treatment of discarded munitions on FUDS are not subject to RCRA permitting
and manifesting requirements. When OE is moved off-site, however, it must be managed in
accordance with all applicable RCRA and Department of Transportation (DOT) requirements.
f. Environmental Protection Agency (EPA) Military Munitions Rule. The EPA Military
Munitions Rule amends 40 CFR 260-266, and 270. This Rule was implemented to clarify the
application of RCRA requirements to military munitions. Six major issues are addressed:
(1) Conditions specifying when military munitions become subject to regulation as a solid
waste or hazardous waste under RCRA.
(2) The application of RCRA hazardous waste standards to the use of military munitions in
weapons testing and military training exercises.
(3) The standards applicable to emergency responses to incidents involving military
munitions and explosives.
(4) The applicability of RCRA requirements to unexploded ordnance (UXO) and
environmental contamination at closed or transferred military firing ranges.
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