Evaluation of Alternative Technologies for Disposal of Liquid Wastes from the Explosive Destruction System (2001) / Chapter Skim
Currently Skimming:
4 Regulatory and Public Involvement Issues
4 Regulatory and Public Involvement Issues
Pages 32-38
The Chapter Skim interface presents what we've algorithmically identified as the most significant single chunk of text within every page in the chapter.
Select key terms on the right to highlight them within pages of the chapter.
From page 32... ...
The first stage involves the following: · obtaining the regulatory approvals necessary to operate the mobile treatment system · transporting the system to the site · actual neutralization of the nonstockpile chemical materials The second stage involves the subsequent treatment and disposal of the EDS waste streams, whether at the site where they are generated or at an off-site facility. Although the RAP mechanism used for operation of the EDS device itself will affect the choice of a RAP mechanism for treatment of the EDS liquid waste streams, the two ID.
|
From page 33... ...
Operating and closure standards must also be developed. However, because the establishment of treatment goals is an objective that applies to all technologies for treating the entire spectrum of nonstockpile CWM and waste streams, not just EDS liquid wastes, a more detailed discussion of this issue is beyond the scope of the current report and will be addressed in a subsequent NRC report dealing with all of the treatment technologies available to destroy nonstockpile materiel.
|
From page 34... ...
As with the neutralents, EDS rinsates and spent cleaning solutions may be classified as listed hazardous wastes in some states. In states where the EDS rinsates are not listed as hazardous waste, given their dilute nature it is unlikely that they would meet any of the RCRA characteristics and would therefore not be designated as hazardous waste.
|
From page 35... ...
For example, at this writing the neutralents generated in the recent destruction of the six sarin bomblets at RMA, after having been temporarily stored on-site, were sent out of state to a permitted hazardous waste incinerator. Based on the Army's reported quantities of residual chemical agents in EDS neutralents, transportation of neutralent wastes from the EDS should not be subject to any restrictions beyond the applicable federal RCRA, DOT, and state regulatory requirements.~° Nevertheless, the incineration of CWM has been a controversial issue, and the Army is concerned that at least at some sites the opposition of some states and public interest groups to incineration of stockpile chemical agents could one day be extended to incineration of nonstockpile neutralents from mobile treatment systems.
|
From page 36... ...
Recommendation: The Army's RAP strategy should ensure that sufficient information is obtained about the chemical constituents of greatest concern in the RAP process for the EDS liquid wastes: chlorinated organics, degradation products of agent and energetic compounds, metals, suspended solids, and MEA. Finding: RAP options associated with treatment of EDS neutralents, rinsates, and cleaning solutions depend on whether the waste is regulated as hazardous within the state where it is generated and, if it is, whether it is a "listed" hazardous waste, a "characteristic" hazardous waste, or bosh.
|
From page 37... ...
permit, if that permit is written sufficiently broadly to allow acceptance of EDS liquid wastes. Other options include obtaining a hazardous waste permit for treatment, modifying an existing hazardous waste treatment permit, using emergency exemptions available under most state hazardous waste regulations, obtaining an emergency permit under the state hazardous waste regulations, using a RCRA compliance order (RCRA §§ 3008(a)
|
From page 38... ...
concerning public acceptability for RRS and MMD neutralent treatment processes also apply to treatment of EDS neutralents and rinsates. The committee's discussion with citizen groups indicated a need for and the value of public involvement in the Army's decisions on the selection and deployment of technologies for disposing of neutralents and, indeed, all nonstockpile chemical materiel.
|
Key Terms
This material may be derived from roughly machine-read images, and so is provided only to facilitate research.
More
information on Chapter Skim is available.