In 1990, the U.S. Environmental Protection Agency (EPA) designated the facility within the Apache Powder Superfund Site based on a Preliminary Investigation under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In 1994, EPA issued a Record of Decision (ROD) and Unilateral Administrative Order (UAO) outlining remedial actions required for certain historic waste disposal areas at the site. ROD-designated “media components” included a waste storage and drum disposal area; dinitrotoluene (DNT) drum landfill; and various other DNT disposal areas across the site. In 1999, EPA issued a CERCLA Removal Action Memorandum (RAM) directing the removal of residuals from an improperly closed trinitrotoluene (TNT) recovery operation that pre-dated ANP’s operation.
Remedial implementation was performed from December 1999 through June 2000. The scope included on-site pre-treatment of potentially-explosive TNT wastes; removal of drummed and non-drummed liquids and debris; excavation of potentially-impacted soil; confirmatory sampling; waste profiling; and off-site disposal at approved hazardous and non-hazardous facilities. In total, these actions involved approximately 2,200 tons of waste materials, including approximately 1,200 tons of hazardous waste.