Systems and Technologies for the Treatment of Non-Stockpile Chemical Warfare Materiel (2002) / Chapter Skim
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4: Regulatory Approval and Permitting Issues
4: Regulatory Approval and Permitting Issues
Pages 56-63
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From page 56... ...
THE ARMY'S RAP EXPERIENCE Prior experience can be summarized by examining permitting for various deployments of non-stockpile treatment technologies, including the MMD-1 (munitions management device) system, the RRS (rapid response system)
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From page 57... ...
The Army used the existing structure under the RMA' s CERCLA remedial program to destroy the sarin bomblets using the EDS; it met the requirements of the state's RCRA order as a CERCLA emergency removal action.3 Doing so enabled the Army to avoid the long RAP delays experienced in Utah with RCRA permitting of the RRS and MMD- 1. The Army hopes that the CERCLA removal approach can be a model for the RAP process at future sites to which the EDS might be deployed.4 However, the CERCLA emergency removal action RAP mechanism, as deployed at RMA, pertained only to the use of the EDS itself; management of secondary waste was deferred to the RMA waste management plan (U.S.
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From page 58... ...
Furthermore, the committee believes that classification of CAIS as RCWM is unwarranted because the surety risks that this materiel poses in no way compare to the risks posed by other RCWM, such as recovered mortars or bombs (NRC, l999a) .6 Diverse Army Organizations with Responsibility for RAP NSCMP is responsible for developing and proving technologies that are capable of destroying non-stockpile materiel and for treating secondary wastes and related waste in 6As discussed in NRC 1999a, this conclusion is based on the fact that CAIS sets contain no explosives and relatively small quantities of agent, and that the hazards of the chemical agents in CAIS (mustard and lewisite)
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From page 59... ...
As a result, a large share of state resources must be devoted to developing regulations that affect a very low volume of waste, compared with commercial hazardous waste regulations. This has resulted in considerable delays in the RAP process at the state levels, often resulting in different treatment requirements being applied for the same type of chemical agent or secondary waste in different states.
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From page 60... ...
in There is no question that the primary chemical agents found in non-stockpile items are acutely hazardous and warrant stringent controls. Secondary treatment residuals, however, are often placed in the same acutely hazardous category as the parent agent (as, for example, in the Utah and Colorado regulatory programs)
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From page 61... ...
In this manner, neutralents would no longer be associated with the parent agent waste, and acceptance by off-site commercial TSDFs would be facilitated. Third, some secondary wastes may not warrant regulation as a hazardous waste at all.
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From page 62... ...
Several Army entities are involved in developing and demonstrating technologies for destroying NSCWM and treating secondary wastes and for achieving RAP for these activities. In addition, the Army has established separate RAP responsibilities for chemical warfare materiel (CWM)
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From page 63... ...
In states where secondary waste streams are regulated as acutely hazardous, the Army should work with state regulators to remove the designation "acutely hazardous." For neutralents, the Army should work with state regulators to establish de minimis concentrations for the agents in waste streams, to be incorporated into the listing regulations, whereby the waste would longer be considered as being associated with the parent agent waste. Further, the Army and the states should consider whether rinsates and cleaning solutions and residuals from the treatment of neutralent should be classified as hazardous waste at all.
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