in accordance with regulatory requirements. The regulatory requirements pertain primarily to the Resource Conservation and Recovery Act (RCRA) and its implementing regulations. RCRA is summarized in Appendix D, along with other regulatory programs.

The secondary wastes produced by the various types of EDTs are similar; they consist of metal casings and fragments, explosive fragmentation protective materials, carbon filter material, baghouse dusts, miscellaneous wastes (used O-rings, fittings, etc.), and liquid waste streams coming from off-gas treatment, from periodic cleaning and decontamination of the device, or from closure between deployments. The EDS will generate not only the above materials but also a substantial volume of liquid wastes (hydrolysates and various dilute rinsates). CAIS containing dilute or neat agent are treated and disposed of in a SCANS unit, as discussed above.

Secondary waste from EDS operations was stored at both the Spring Valley and Camp Sibert sites and then shipped off-site.30,31 At both sites, the project managers followed the Army’s general practice of treating the waste only to the point at which it can be safely shipped off-site to commercial treatment, storage, and disposal facilities (TSDFs) (NRC, 2004). At both places, the waste was stored in a less-than-90-day hazardous waste storage area. The waste was placed in an enclosed trailer (Spring Valley) or in a vapor containment structure (Camp Sibert). The enclosures were within fences, with security guards present. Liquid waste was placed in 55-gal steel drums.

For the past several years, NSCMP has maintained a waste management contract with Shaw Environmental, Inc. As explained in NRC, 2004, the waste management contractor is responsible for teaming with one or more commercial hazardous waste TSDFs to transport and dispose of hazardous secondary and neutralent wastes from the various NSCMP projects. Shaw Environmental fulfilled this responsibility for EDS operations at both Spring Valley and Camp Sibert. The project manager at Spring Valley reported that he received some questions and expressions of concern from the regulators and the community about the nature and amounts of reagents and waste entering and leaving the facility, but that this was “nothing really significant.”

Otherwise, there were no problems with waste storage or disposal at either Spring Valley or Camp Sibert. As a consequence, the committee could not identify any need for targeted research and development in this area.

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30Karl E. Blankinship, FUDS Project Manager, Mobile District U.S. Army Corps of Engineers, personal communication to Nancy Schulte, NRC study director, April 4, 2012.

31Dan G. Noble, Project Manager, Spring Valley, Baltimore District, U.S. Army Corps of Engineers, personal communication to Nancy Schulte, NRC study director, March 30, 2012.



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