DSHW-2024-005263

DEPARTMENT OF DEFENSE
REGIONAL ENV]RONMENTAL COORDINATOR. REGION 8
March 14, 2024
Douglas J. Hansen, Director
Division of Waste Management and Radiation ControI
Utah Department of Enviromental Quality
P.0. Box 144880
Salt Lake City, UT 841 14-4880
Su切ect: RE: DoD Regional Environmental Coordinator letter, Public Comment on uTTR
RCRA Part B Permit Renewal (UTO570090001) February 12, 2024
On February 1 2工submitted comments on behalf of the Department of Defense ('・DoD”),
Hill Air Force Base (AFB), and the Department ofthe Air Force (“DAF”) regarding the subject
Permit and would like to clarify the DOD position expressed in my origina=etter.
I would like to assure you that the DoD and the DAF are committed to improvlng
inventory control management to reduce reliance on open buming/open detonation (・・OB/OD”)
and to performing altemative technoIogy evaluations and adopting safe and viable altemative
technoIogies. To clarify from my previous letter, the DoD’s and the DAF’s primary concem is
that adding conditions to this UTTR permit imposing altemative technoIogy implementation
requlrementS is premature in Iight ofthe frot that an updated altemate technoIogy evaluation is
underway. Until that evaluation is completed, and an altemative technoIogy is iden揃ed and
implemented, OB/OD remains the only safe and viable treatment for expIosives and munitions
WaSte StreamS at UTTR, and there is a paramount need to maintain protection from acute safety
hazards associated with handling expIosive waste. Our comments in the encIosure to the
February 12, 2024 letter remain unchanged・
I appreciate the collaboration with your department to date on our shared goals of
PrOteCtion of human health and the environment and meeting the national security needs ofthe
nation. We look forward to continuing DOD’s productive relationship with the Department of
Envirormental Quality.
Sincerely,
国璽匿憂国
MARK A. MAHONEY
DoD Regional Environmental Coordinator
US EPA Region 8
CF:
Ms. Kim Shelley, Executive Director, Utah Department of Environmental Quality
Mr. Gary Harter, Executive Director, Utah Department of Veteran and Military Affairs