Category Archives: Hazardous waste
A newish CRS report titles Human-Induced Earthquakes from Deep-Well Injection briefly discusses the Army Chemical Corps decision to dispose of its wastes through deep-well injection. The CRS report describes the process, that lead to
an M 4.8 earthquake that struck northeast Denver, on August 9, 1967 was generally accepted as the largest recorded human-induced earthquake in the United States. The M 4.8 earthquake was part of a series of earthquakes that began within several months of the 1961 start of deep-well injection of hazardous chemicals produced at the Rocky Mountain Arsenal defense plant. The earthquakes continued after injection ceased in February 1966.21 The disposal well was drilled through the flat-lying sedimentary rocks into the underlying older crystalline rocks more than 12,000 feet deep, and injection rates varied from 2 million gallons per month to as much as 5.5 million gallons per month.
Confusing letters between the RMA Subcommittee and the EPA on 10 x -6 risk and Superfund.
Readers are advised to scan over 40 CFR 300 before reading our letters; our assumption was that cleanup standards/cancer risk for RMA would follow 10 x -6 as outlined in the National Contingency Plan, not 10 x -4 as applied to the Arsenal and in many CERCLA cleanups.
History, lots of history…
- The Blue Book (Parts 1 and 3 not included).
- CDPHE  Citizen Health Summary.
- CDPHE press release on the 10th Circuit decision.
- Chemical Agent Program History [no author – a contractor doc?].
- City and County of Denver comments on the Onpost proposed plan.
- Colorado Dept. of Health , Chemicals & Spills.
- Colorado Dept. of Health , Concerns, Offpost Proposed Plan.
- Conceptual_Agreement, Sierra Club comments, .
- Corrective Action Management Unit, Sierra Club comments to CDPHE, : The Arsenal was one of the first federal facilities to reinvent cleanup via the CAMU. It is my understanding the original intent of the CAMU was to provide a framework for the development and use of alternative and innovative technologies by allowing flexibility in the Resource Conservation and Recovery Act (RCRA) Land Disposal Rule (LDRs). But at one time, the use of CAMU subverted the LDRs rule by allowing untreated dioxin laden waste landfilled without treatment. This capricious misapplication of the rule is contrary to the law, and was not the intent of Congress, the EPA and the Colorado Hazardous Waste Commission which promulgated LDRs. EPA changed requirements in 2002 [see 3.3 of this EPA doc].
- Department of the Army , Review and Analysis.
- Draft EIS, USFWS wildlife refuge, Sierra Club comments to USFWS .
- Daigle v. Shell Oil.
- EPA Factsheet on RMA,  | EPA Q&A on the SQI [Submerged Quench Incinerator].
- EPA , Operation of the Basin F Liquid Incinerator.
- Hazardous Spills and Leaks .
- History of Basin F.
- History of Building 1727.
- History of the Complex Trenches.
- History of the Hydrazine Blending and Storage Facility [owned by the Air Force but operated by RMA from 1962-82].
- History of the M1 Settling Basins.
- History of the Motor Pool area.
- History of the NW Boundary System.
- History of Rocky Mountain Arsenal .
- Installation Action Plan [March, 1997; no author].
- Kuznear, Casimir and Trautmann, William L. History of Pollution Sources and Hazards at Rocky Mountain Arsenal [September 1980].
- Labaton, Stephen. [1987, Nov. 16]. Business and the Law; Big Courtroom For Toxic Web. The New York Times.
- Larry Land testimony [100th Congress, 1st session, H.R. 816 allowing rancher Larry Land, to bring suit against the Army for DIMP (diisopropylmethyl phosphonate, a byproduct of Sarin) contamination and related health problems].
- Rep. Pat Schroeder  requesting waste history from the Army.
- RMA waste to Fountain Landfill [n.d.].
- Program Manager for Demil of Chemical Materiel, Project Eagle, Phase II, Disposal of Bulk GB, M34 Cluster .
- Program Manager RMA Contamination Cleanup, Rocky Mountain Arsenal: An Organizational Historical Perspective .
- Program Manager for Rocky Mountain Arsenal, Authorized Access to and Allowable Activities at Rocky Mountain Arsenal .
- South Plants Remediation Survey.
- State of Colorado comments on the endangerment assessment.
- State of Colorado’s Conceptual Cleanup Agreement press release from Lt. Gov. Gail Schoettler .
- Toxic Tours at Rocky Mountain Arsenal [Sierra Club, 1998] | Sierra Club Rocky Mountain Arsenal Subcommittee letter regarding school tours to view wildlife during Superfund cleanup activities.
- Use and Storage of 2,4-D Spraying History.
- Waste Disposal, A National Problem [author unknown; info on deep well injection, the basins, and pollution].
- Why We Need Good Info to Cleanup Bad Places.
Perhaps the most controversial party to RMA cleanup, on April 30, 1952, Shell Oil purchased Julius Hyman & Company, which manufactured “high-potency insecticides.” Hyman officially became integrated into Shell on January 1, 1955 [see Kendall Beaton’s Enterprise in Oil: A History of Shell in the United States, Appleton-Century-Crofts, 1957].
A few scanned files:
- Ben Nighthorse Campbell  calls for Shell to cleanup RMA | Shell responds
- The (infamous) Blue Book (Parts 1 and 3 not included).
- Colorado Department of Health to Shell: Cease and Desist, 
- Colorado Department of Health to Shell regarding “unauthorized discharge of pollutants” 
- Congresswoman Pat Schroeder asking the Secretary of the Army for records on Shell releases 
- Cooperative Agreement between the Colorado Wildlife Federation, the National Fish and Wildlife Federation, Shell Oil Company, the U.S. Army Program Manager’s Office at the Rocky Mountain Arsenal, and the U.S. Fish and Wildlife Service
- Diana Hembree and William Kistner’s Shell Game article on No Pest [Vapona] strips that were once manufactured at RMA [E Magazine, December 1992] | Denver Post article written by Mark Obmascik Vapona & testing on infants [missing the second page, so head to your local library]
- Maret, Why We Need Good Info to Cleanup Bad Places
- Shell, Declaration of Covenants 
- Shell Oil Co. v. Winterthur Swiss Ins. Co
- Shell responds to reporter Mark Obmascik’s Denver Post articles on cleanup costs | Holmes, Roberts & Owen’s letter to the editor defending Shell’s involvement as a Principle Responsible Party (PRP)
- Shell’s Concepts in Remediation 
- Shell’s “Statement of Settlement Issues [September, 1994]