The Rocky Flats Agreement is now being renegotiated. These agreements are in place at the Hanford Reservation, the Savannah River Site, the Oak Ridge Reservation (Oak Ridge National Laboratory, K-25, Y-12), and the Paducah Gaseous Diffusion Plant. Several types of agreements that address mixed waste land disposal restriction (LDR) compliance have already been signed by more » both DOE and the regulators. DOE will need to rethink its strategy in the area of future compliance agreements to ensure commitments and deliverables are made consistent throughout the different DOE facilities. DOE`s implementation of the FFCA will have significant effects on current and future DOE waste management operations. The Federal Facilities Compliance Act (FFCA, the Act) was signed into law on October 6, 1992, primarily as a means of waiving sovereign immunity for federal facilities with respect to requirements under the Resource Conservation and Recovery Act. The purpose of this paper is to review several important munitions Rule issues, and to discuss potential impacts of these issues. It is important for DOD, the Services, and individual installations, to be aware of potential impacts of the FFCA on munitions management operations. Demilitarization, range management, training activities, and emergency response actions may be affected. It is clear that the Munitions Rule could have a significant effect on the way in which DOD manages munitions. These are the only provisions of the FFCA that require a new rulemaking. The FFCA requires EPA to promulgate the final ``Munitions Rule`` by October 6, 1994. Section 107 requires the Environmental Protection Agency (EPA) to develop, after consultation with the Department of Defense (DOD) and appropriate State officials, regulations identifying when military munitions (including conventional and chemical munitions) become hazardous waste, and to provide for the safe transportation and storage of such waste. The Munitions Provisions, contained in Section 107 of the FFCA, modifies Section 3004 of RCRA by adding a new subsection (y) on Munitions. The focus of this paper is the FFCA Munitions Provisions, which have the potential to more » change some aspects of the structure of munitions management within the military. While the waiver has broad implications for all Federal facilities, other provisions of the FFCA impact specific sectors of the Federal complex. This waiver subjects Federal facilities to the same ``incentives`` as the private sector for compliance. This Act amends the Resource Conservation and Recovery Act (RCRA), the primary law governing hazardous waste management in the US The most significant provision of the FFCA was the waiver of sovereign immunity. The Federal Facility Compliance Act (FFCA) was signed by President Bush on October 6, 1992.
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