What are the two key provisions of the 1992 Federal Facilities Compliance Act?
It directed the EPA to develop the Military Munitions Rule and created a waiver of sovereign immunity with regards to federal facilities
How does EPA define hazardous waste?
Those that are specifically listed as such, and those that possess hazardous characteristics
T or F? A munition that is the subject of an Urgent NAR is a WMM.
TRUE
T or F? The DDA is the only authority, in most cases, that is authorized to declare unused munitions items as a waste.
TRUE
Why is it important to define what constitutes a range for the purposes of the MR?
RCRA does not apply to most ordnance operations on an operational range
Who can assist in obtaining emergency permits, if needed, during a Level 2 emergency response?
The installation environmental office
T or F? Scrap metal can be excluded and exempted from RCRA
TRUE
The Explosives Safety Inspection (ESI) program:
All of the above
T or F? All states have to adopt the MR as it is a national standards, i.e they must adopt it “as is” with no amendments
TRUE
T or F? Range clearance activities should be scheduled and documented to identify which ranges were swept, when, by whom, and what items were destroyed
TRUE
T or F? The use of Condition Code “H” material for and EOD training operation, must comply with all the requirements of RCRA disposal.
TRUE
T or F? The three components of the course’s take home message are: 1.) Know when munitions are not a waste, 2.) Know when unused munitions are a waste, and 3.) Know when used munitions are a waste
TRUE
T or F? CE transportation is exempt from all documentation requirements
FALSE
Waste generators may employ which of the following measures to identify hazardous waste:
All of the above
T or F? When a munitions lands off-range and it is not promptly responded to then it is considered a waste munitions item and RCRA applies.
TRUE
A solid waste can be a:
All of the above
When is an unused military munition a waste military munition?
When declared so by a Designated Disposition Authority
T or F? Temporary storage during reasonable delays of Level 1 emergency responses requires an emergency permit
False
The MRIP was designed to:
All of the above
Flashing, crushing, or shredding of military munitions (including UXO and munitions fragments) on operational ranges is considered and are _.
Intended use; not waste management
NARS can be used to reclassify an unused munitions item into condition code V. This denotes what?
That it has gone through the DDA process and has been declared a waste military munition
What items are NOT regulated by the MR?
IED, wholly inert items and nuclear weapons
During test operation, a warhead malfunctions and is removed from the range/test site. The warhead is a __ munition.
Used
T or F? The MRIP applies to all DoD components within the U.S. and U.S. territories.
TRUE
Before we can determine if the MR applies we must first determine if the item is:
All of the above
T or F? If a misfire or dud is transferred off-range for the purpose of an investigation, it is not immediately considered a waste.
TRUE
Records of all EOD incidents must be maintained for __.
3 years
T or F? When EOD units consistently use a single safe disposal area for emergency response operations, they must eventually obtain a Sub-part X permit for this facility.
FALSE
T or F? During range clearance activities, burial is a best management practice for managing range scrap and UXOs.
FALSE
A munitions item does not become a waste until the intent for it is disposal.
TRUE
What range activity is subject to the MR?
Removal of military munitions for treatment or disposal
What is a valid way to determine whether an item is a hazardous waste?
All of the above
T or F? A characteristic hazardous waste is a solid waste that exhibits any of the following: ignitability, corrosively, reactivity, or toxicity.
TRUE
T or F? The Munitions Rule allows for discarding or burying of excess munitions when necessary.
FALSE
The DoD Munitions Rule Implementation Policy was developed to aid in _.
Implementing/Interpreting EPA’s Munitions Rule
T or F? You cannot train with old, obsolete munitions items
FALSE
T or F? An ordnance test plan should clearly identify the generation point of any waste.
TRUE
Why is it important to know if a munitions item is hazardous waste or not?
All of the above
T or F? The DoD has sovereign immunity over their own facilities.
FALSE
Which of the following are NOT waste military munitions
Unserviceable mortars stored in a magazine
T or F? The MR covers contractors if they are managing military munitions in contract with the DoD
TRUE
Which of the following items are military munitions?
Artillery projectiles in storage at a U.S. Army installation
In RDT&E, the test plan should document how used munitions will be managed and at which point __.
They become waste
EOD can declare situations that , but they still pose an “imminent and substantial endangerment to human health or the environment” as _ emergency response.
Do not pose an immediate threat; level 2
T or F? The officer in charge of a Level 1 emergency is exempt from generator paperwork requirements, does not need a manifest to transport, and does not need a permit to respond (including emergency permits).
TRUE
The Munitions Rule Implementation Policy was developed by and for (the) _.
All the Services
T or F? Taking a misfired munition off a military range always constitutes an overt intent to dispose.
FALSE
The DDA:
Ensures all efforts are made to use a munitions item before declaring it waste military munitions
Which of the following are NOT examples of military munitions as defined under MRIP?
IED
An additional requirement for storing waste military munitions under conditional exemption is:
You must have a DDESB approved site plan
When transporting a WMM under CE, the shipping activity must ensure:
All of the above
T or F? The actual laws that regulate waste military munitions may vary from state to state. This could cause confusion as the practices you were taught in one state could be illegal in another state.
TRUE
WMM can be transported under a Conditional Exemption if the following conditions are met:
Both A and C
T or F? Scrap metal collected from the range is eligible for a scrap metal exclusion from RCRA if the materials are formally documented and deemed safe.
TRUE
T or F? When munitions land off-range and are not promptly responded to, it is not considered a waste munitions item and RCRA does not apply.
FALSE
T or F? RCRA only regulates the final disposal of waste
FALSE
NARS are issued to:
All of the above
When does the MMR cover munitions that are being managed by a DoD contractor?
When they are managing military munitions
When can installations apply for treatment CE?
Never. Treatment CE is not an available option
T or F? Civilian munitions recovered from ASP Amnesty Boxes are eligible for MR exemptions.
FALSE
A munition that becomes the subject of an urgent NAR and must be disposed is considered waste __.
As soon as the Urgent NAR is issued
What conditional exemptions for transport or storage are revoked, _.
All of the above
Foreign military munitions are subject to MRIP when they have been:
All of the above
Which of the following is NOT a characteristic of hazardous waste as defined by RCRA?
Ferrous
Treatment, Storage, and Disposal Facilities require operating permits issued by _.
Either the EPA or the State
T or F? Munitions stockpiled for operations or training are waste, despite what their condition code may state.
FALSE
T or F? The Federal Facilities Compliance Act (FFCA) waived federal sovereign immunity from RCRA violations.
TRUE
Waste military munitions are typically hazardous waste due to their characteristic of __.
Reactivity
Why is the use of explosives during EOD proficiency training not a RCRA waste management activity?
Training requirements constitute intended use
If the state has adopted Conditional Exemption for transportation and storage, what two environmental shipping options would the installation be able to use?
Full RCRA and Conditional Exemption for transportation
Which of the following are NOT among the three options Authorized States have in implementing the Munitions Rule?
States can regulate military munitions under “traditional” (pre-MR) CERCLA
Which of the following is NOT a condition for defining a military munition?
- The items is the object of an emergency response
Military munitions that land off an operational range as a result of use become WMM if:
The are not promptly rendered safe or retrieved
Which of the following activities indicate an intent to dispose on a range?
Burial