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APPENDIX H Insights from State Regulators This appendix provides comments and information provided by state regulators on issues crucial to obtain- ing environmental permits for any of the technology packages. The committee conducted informal tele- phone discussions with state regulators in Colorado, Kentucky, and Utah with the understanding that regu- lators were stating their personal opinions and could not render formal judgments. The following obser- vations emerged from these discussions. First, the state of Kentucky has a law on the books prohibiting the Kentucky Department of Environmen- tal Protection from examining a permit for a chemical- agent treatment process until the process has been sat- isfactorily demonstrated (Kentucky 1988 Ky. Acts ch. 86, sec.l). Second, regulatory bodies are concerned about the volume of activated carbon generated by the air-pollu- tion control equipment and how to dispose of it. Ac- cording to a regulator in Utah, the Tooele facility has replaced large quantities of activated carbon and is now storing the spent material. Facilities that do not have incinerators to treat at least some of the building venti- lation air will produce even more carbon. Spent, acti- vated carbon is very dusty and hard to burn, tends to become hot in storage (about 150°F), and may, with time, release adsorbed agent. If the carbon is ultimately disposed of off site, the person opening the drum for inspection (disposal facilities are required to inspect waste prior to accepting it) may be exposed to agent. Third, there are no hazardous waste landfills in 240 Kentucky, and the disposal of hazardous wastes from any process must take this into account. The "derived- from" rule may also pose a problem. Because Kentucky classifies agent as a hazardous waste, all of the wastes from any of these processes will be hazardous wastes, by definition. Fourth, regulators from Kentucky and Utah noted that processes proposing to burn a gas produced by the treatment process will have to address several issues. A utility that agree to accept it as a fuel, for example, must provide firm contracts and commitments to do so. If the gas is burned on site, it will be examined by the regulatory authorities for contaminants. If the gas meets fuel specification comparable to EPA's Maximum Available Control Technology Rule (EPA, 1998a), it will pose few problems. If the gas does not meet these specifications, the boiler will have to be permitted like a boiler/industrial furnace or an incinerator for burning hazardous waste. Fifth, the following comment was included in Utah' s evaluation of the ACWA demonstration permit appli- cations and appears to be applicable to all of the full- scale processes. "No process that treats agent should be vented without control into the work space if people are present to operate equipment or to sample. No pro- cess that treats agent should be vented without carbon control into the environment." Coupled with the earlier concern about activated carbon, this statement implies that processes that produce large quantities of activated carbon waste may encounter permitting delays.
