The Improvement Plan for Military Munitions Rule Implementation was prepared by the Army Munitions Workgroup and distributed in November 1999. The objective of the Plan is to ensure that all applicable elements of the Army are provided with the necessary tools to enable them to efficiently and effectively implement the MR. The Plan is organized to address three fundamental components to cover the full scope of MR Implementation.

• Policy, regulatory initiatives and guidance
• Training and information sharing initiatives
• Compliance monitoring and continuous improvement

The improvement plan assumes the Army's primary interface and mechanisms for coordinating initiatives and addressing MR Implementation issues with other DoD Components via its representation to the Operational Environmental Executive Steering Committee for Munitions (OEESCM).

The MR Improvement Plan is a living document and will undergo revisions and updates as required. The current version is available on DENIX (user account and password required).

Under RCRA, EPA may authorize a State or Territory, instead of the Federal government, to administer and enforce the Munitions Rule. While the regulations adopted by a State or Territory have to be at least as stringent as the Federal regulations, RCRA allows States and Territories to impose standards that are more stringent than those in the Federal program. Therefore, compliance requirements may differ from State to State or Territory. The AEC Regional Environmental Offices have a responsibility to establish an open dialogue with the States and promote adoption of the Munitions Rule. The map provides the current status of Munitions Rule adoption by States and Territories.

The Director of Aviation, Munitions and War Reserves asked the U.S. Army Logistics Integration Agency (LIA) to review the Department of Defense (DoD) Policy to Implement the Military Munitions Rule (MR). The objectives of the review were: to determine the availability and effectiveness of the policy; to determine how well installations are implementing the policy; and to gather issues and identify areas requiring clarification for the field. Sixty-nine installations participated in the review via completion and return of a questionnaire prepared by LIA. LIA conducted on-site visits at eight installations to verify input from questionnaires, and to collect issues and concerns.

The object of this Policy was to conduct a policy effectiveness review of the DoD policy that implements the EPA MR. The objectives of the review were: to determine the availability and effectiveness of the policy; to determine how well installations are implementing the policy; and to gather issues and identify areas requiring clarification for the Army field activities. The LIA Effectiveness Review can be viewed via the LIA Web site (LIA user account and password required).

From October 2000 through May 2001, an integrated government team led by AEC conducted a series of Staff Assistance Visits (SAVs) to installations representing five of the Army's Major Commands (MACOMs). The SAVs were structured to promote open discussion, address installation concerns, and identify issues that must be further addressed by command and support activities. The Site Assistance Visits Lessons Learned document resulted from these visits. This document describes the observations and findings of the SAV team members, highlighting systemic areas of noncompliance and issues of concern and providing specific instructions for improvement as they relate to:

• The Military Munitions Rule (MR),
• The Department of Defense (DoD)'s MR Implementation Policy (MRIP), and
• Other ancillary federal, DoD, and Department of the Army (DA) regulations and requirements

The primary goal of this document is to improve regulatory compliance and consistent implementation of DoD and DA policy. Potential benefits include reduced risk to human health and the environment, reduced compliance costs due to penalties and fines, and improved efficiencies in managing munitions related wastes.

The recent promulgation of the Military Munitions Rule, the ongoing development of the DoD Range Rule, in combination with specific incidences of unsafe handling of range residues, have spurned the DoD and Department of the Army (DA) to look closely at the generation, collection, and disposal of range residues. USAEC is leading efforts to identify and characterize solid waste generated by military personnel during the intended use of munitions items on training ranges.

The result of these efforts will provide Army MACOMs and installations with the prerequisite information necessary to make informed decisions about solid waste management practices. Additionally, this work will support the DoD Munitions Residue Disposal Process Team, Hazardous Waste Management Subcommittee on Range Scrap, and other DoD working groups currently examining range residue management issues.

To this end, a three-phased Range Scrap (Firing Point) Study Project has been implemented. The primary objective of this project is to perform a comprehensive inventory of the items utilized in support of Army training and mission activities on ranges at the firing point, characterize those items in accordance with RCRA, and develop environmental best management practices (BMPs) from handling to final disposition. The overall goal is to promote a consistent approach to the management of the residue items and do so in accordance with environmental regulations.

Phase I, Data Review and Inventory Report Phase I of the project was completed in June of 1999 and presents the regulatory framework for managing range scrap and the inventory of solid waste and residual material generated during training exercises. The activities completed in support of the report incorporated:

• Data search and review of regulatory guidance, inventory data, and characterization data
• Development of regulatory framework
• Development of an inventory database for training-related munitions and range scrap.

Phase II, Characterization Strategy Report Phase II of the project utilized the regulatory framework and inventory developed in Phase I to present:

• The characterization scheme for residual material
• Analytical recommendations and requirements for each scrap item
• Data quality objectives (DQOs) for characterizing range scrap
• Rationale for the characterization and characterization profiles for the inventory
• Data quality, reporting requirements and an approach for interpreting the results to satisfy the project DQOs.

Phase III, Waste Profiles And Best Management Practices Phase III of the project will utilize the data developed from Phase II to further emphasize the development of BMPs for the inventory and provide data to buyers, recycle companies, scrap dealers and disposal and treatment facilities. Phase III will result in the development of profile sheets for each range scrap item; identifying data, hazardous waste determination, characterization data, waste management options, applicable BMPs, and analytical results. Waste Profile Notices for 41 munitions items are available in the June 2005 Range Scrap (Firing Point) Study Waste Profile Notices.