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SOUTHERN REGIONAL ENVIRONMENTAL OFFICE (SREO). OVERVIEW OF MEMPHIS DEFENSE DEPOT MAIN INSTALLATION LAND USE CONTROLS. David M. Buxbaum SREO Regional Counsel 30 June 2005. Memphis Depot Aerial View. Memphis Depot Background.

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southern regional environmental office sreo
SOUTHERN REGIONAL ENVIRONMENTAL OFFICE (SREO)

OVERVIEW OF

MEMPHIS DEFENSE DEPOT

MAIN INSTALLATION

LAND USE CONTROLS

David M. Buxbaum

SREO Regional Counsel

30 June 2005

slide3

Memphis Depot Background

  • Formerly known as the Defense Distribution Depot (Memphis), Tennessee or DDMT.
  • Located in SE Memphis near airport; Size: 642 acres.
  • Mission: Materiel storage and stock control facility for US Army and other Services [1942 –1995].
  • Main Installation (MI) [~ 578 acres] has warehouses, open storage areas and military family housing.
  • Dunn Field [~ 64 acres] used for bauxite storage piles, equip. de-contamination and waste disposal areas.
  • Identified for closure under BRAC July 1995.
  • 2004 Facility of the Year Award by NAID/ADC for Memphis Depot Business Park.
memphis depot property transfers

PBC DOI Parks (DF –15 Acres) Sep 2004

PBC DOT 2 (DF – 34 Acres) Feb 2010

PBC DOT 1 (DF – 20 Acres) Sep 2004

Dunn

Field

EDC 2 (MI - 275 acres) Sep 2003

EDC 1 (MI - 13.4 acres) May 2002

Main Installation

PBC DOI (MI - 4.7 acres) Feb 2002

PBC HUD (MI - 6.5 acres) Sep 2001

PBC DOI (MI - 50 acres) Sep 2005

EDC 3 (224 acres) Jun 2008

Memphis Depot Property Transfers
slide8

Memphis Depot Regulatory Dates

  • RCRA Facility Investigation by EPA in January 1990.
  • Issued RCRA Part B permit by TDEC DSWM in September 1990 for container storage unit.
  • Issued HSWA permit by EPA in September 1990 for corrective action of SWMUs and AOCs.
  • Added to Federal NPL on October 14, 1992 with HRS score of 58.06 [57 Fed.Reg. 47180].
  • FFA between Defense Logistics Agency (DLA), EPA and TDEC March 6, 1995.
  • RCRA Part B permit terminated October 1998.
  • TDEC & EPA agree to terminate HSWA permit in January 2005 due to deferral to CERCLA cleanup.
cercla cleanup actions for mi
CERCLA Cleanup Actions for MI
  • Remedial Project Managers: DLA – Mike Dobbs; EPA – Turpin Ballard; TDEC – Jim Morrison.
  • 1995 thru 2000 conducted RI/FS and several interim actions to remove contaminated surface soil.
  • ROD for MI (February 2001); selected remedy includes bioremediation of VOC [PCE & TCE] contaminated groundwater and land use controls (LUCs).
  • LUCs to prevent residential use/daycare facilities and production/consumptive use groundwater wells.
  • Final Remedial Design (July 2004) included Land Use Control Implementation Plan (LUCIP).
mi land use restrictions
MI Land Use Restrictions
  • Land Use Control Objectives:
    • Prevent direct contact/ingestion of surface soils contaminated with dieldrin, arsenic and lead;
    • Prevent ingestion of groundwater contaminated with VOCs.
  • Land Use Restrictions:
    • No residential use or other child-occupied facilities, including daycare;
    • No production/consumptive use of groundwater or drilling wells.
summary of mi lucs
Summary of MI LUCs
  • Deed and Lease Restrictions:
    • Property transfer documentation includes land use restrictions;
    • Lessee (DRC) subject to “environmental protection provisions” in lease which restrict use.
  • Notice of Land Use Restrictions:
    • Recorded at Shelby Co. Register of Deeds pursuant to TCA 68-212-225;
    • Identifies location of residual contamination and specific use restrictions.
summary of mi lucs con t
Summary of MI LUCs con’t
  • Zoning Restrictions:
    • Depot located in Light Industrial (I-L) zoning district;
    • Memphis Land Use Control Board administers and enforces zoning ordinance.
  • Groundwater Well Restrictions:
    • Shelby County Well Construction Code prohibits installation of drinking water wells within half-mile of designated boundaries of Superfund site.
  • Golf Course Fence:
    • Preclude casual access by public passerby and prevent unauthorized uses.
slide15

Notice of Land Use Restrictions

  • Includes legal description of the site.
  • Identifies:
    • the location and dimensions of the areas of potential environmental concern with respect to surveyed benchmarks;
    • the type, location, and quantity of regulated hazardous substances known to exist at the site;
    • the specific restrictions on the current or future use of the site.
  • Once filed, restrictions enforceable by any owner and local government agency with jurisdiction.
  • Copies provided to EPA, TDEC, City of Memphis, Shelby County Dept of Health, DRC, USACE, BRACO.
luc monitoring and site inspection
LUC Monitoring and Site Inspection
  • Monitoring frequency and responsible entity provided in Table 1 of LUCIP.
  • Part of CERCLA 5 Yr. Review process; report certifying effectiveness of the remedy including LUCs.
  • Army may arrange to have TDEC or 3rd party conduct required monitoring but retains responsibility.
  • Annual site inspection to ensure land use restrictions are being followed; checklist and certification.
  • If deficiency/violation, then Army will inform EPA & TDEC within 72 hours and undertake corrective action.
luc modification and termination
LUC Modification and Termination
  • Determination to modify or discontinue LUC will be made by Army with approval by EPA and TDEC.
  • Decision to modify/end LUC will be documented and placed in Administrative Record file.
  • Transferee must submit request in writing to Army/EPA/TDEC if changes to LUC or use restriction.
  • Under TCA 68-212-225(e) Notice may be made less stringent/canceled with approval of TDEC Commissioner.
  • LUCIP may be terminated by Army/EPA/TDEC if remedial goals met and LUCs no longer required.
why is this lucip important
Why is this LUCIP important?
  • First document approved by EPA and Army HQ after DoD/EPA CERCLA Post-ROD Authority LUC dispute.
  • Consistent with Navy/EPA Land Use Control Principles and EPA Federal Facility LUC Checklist.
  • Coordinated review with DLA, Army (HQ, ELD, AMC), BRACO, TDEC, EPA Region 4 and EPA HQ.
  • Army Guidance incorporates many aspects of the LUCIP including specific language in sample RD document.
  • Provides model for other federal agencies at similarly situated sites.
summary statements
Summary Statements
  • All land use controls are local, so determine whether existing mechanisms, (e.g. zoning or excavation permit) can be utilized.
  • LUCs should be “layered”, meaning use multiple LUCs that help ensure remedy effectiveness.
  • Start dialogue with document reviewers (especially regulators) to facilitate approval.
  • Understand relevant EPA and DoD/Army Guidance and State laws/regulations.
  • Enlist the assistance of knowledgeable attorney to help draft required documents such as deeds, Notices etc.