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Waste Streams from Transportable Treatment Systems
Pages 12-19

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From page 12...
... These liquid waste streams are referred to in this study as "neutralents."i Because neutralent waste streams from the RRS and MMD are expected to be classified as hazardous wastes under RCRA,2 the Army had planned to ship them to a permitted hazardous waste incinerator for final disposal. However, because the incineration of chemical agents has aroused considerable opposition among public interest groups, and because this opposition may be extended to the incineration of neutralents, the Army is also investigating alternative (nonincineration)
From page 13...
... Neutralent Waste Streams and Volumes The chemical reactions of the RRS processes are complex, and a large number of products are present in the neutralent waste streams. However, all four processes effectively destroy the chemical agents and produce waste streams that could be shipped to hazardous waste incinerators.
From page 14...
... aRCRA charactenzation of the neutralent waste stream will be completed using analytical data obta~ned from bench-scale demonstrations conducted at the Edgewood Chem~cal ar~d Biological Center, Aberdeen Proving Ground, Maryland. bMay be either isomer, 1, 1,1,2-tetrachloroethane, or 1,1,2,2-tetrachloroethane.
From page 15...
... If the neutralent waste stream contains phosgene, it will either be classified as a listed hazardous waste, or, if it is corrosive (pH >10) , as 5HD reacts with DCDMH to form sulfoxides, which are relatively nontoxic.
From page 16...
... CSource: Dugway Proving Ground, 1998. ~RCRA toxicity-characteristic component concentration less than TCLP regulatory limit eNot a TCLP constitutent.
From page 17...
... The reader should note that Tables 2-4 to 2-7 describing the composition on neutralent wastes derived from bench tests of the RRS and MMD neutralents do not list any Schedule 2 precursor compounds. Yet the Army suggests that a major argument against storage is that neutralents may contain Schedule 2 compounds and therefore must be destroyed per the CWC schedule.
From page 18...
... . In 1995, Congress placed restrictions on moving nonstockpile CWM out of any state except to the closest permitted CWM storage facility, and then only under very strict conditions.
From page 19...
... However, the public perception of "residual chemical agents" from the MMD waste streams may arouse concerns. Although these residues will be in extremely small amounts, the public could consider the overall neutralent waste mixture as "tainted" with chemical agent and, therefore, of special concern.


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