Review Criteria for Successful Treatment of Hydrolysate at the Pueblo Chemical Agent Destruction Pilot Plant (2015) / Chapter Skim
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4 Regulatory Requirements for Offsite Hydrolysate Shipment and Treatment
4 Regulatory Requirements for Offsite Hydrolysate Shipment and Treatment
Pages 21-28
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From page 21... ...
Should it schemes more stringent or broader in scope than the federal become necessary for PCAPP to send hydrolysate offsite in program. Colorado, like many of the states with past or presorder to continue destruction of the chemical stockpile, all ent chemical demilitarization facilities, has chosen to make regulatory requirements must be identified and prebriefed its program broader in scope than the federal RCRA program with the Colorado Department of Public Health and Envi- by listing specific chemical agent wastes as hazardous.
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From page 22... ...
For PCAPP, this means that the hydrolysate However, if the hydrolysate is shipped to an out-of-state and all downstream secondary wastes retain the K903 list- TSDF, the waste hydrolysate would have to be treated to meet ing designation, including the filter cake resulting from the the LDRs for characteristic wastes as adopted by the state in biotreatment process. RCRA provides a delisting process which the TSDF is located -- for example, it no longer exhibthat is available for waste that the waste-generating entity its a RCRA characteristic (e.g., corrosivity)
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From page 23... ...
The Program Manager for Assem months, whereas the typical time for a Class 3 modification bled Chemical Weapons Alternatives should continue to would be 6 months to a year or more. pursue the acceptance of the planned offsite shipment and The time required to implement a Class 2 modification to disposal of secondary waste through permit modifications a RCRA permit may vary depending on regulator and public and stakeholder involvement.
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From page 24... ...
. allow limited activities to prepare for offsite shipments until the final permit modification is approved (e.g., planning or At this time, even if the permit modification is approved preconstruction of truck loading facilities)
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From page 25... ...
in October of that year. 18 Presentation by Paul Usinowicz, Bechtel technical advisor, and Yakup In 2003, the Army issued a transportation analysis that Nurdogan, senior wastewater treatment specialist, July 29-30, 2014, and analyzed the environmental impacts for two routes from presentation by Don Guzetti, start-up field supervisor, PCAPP, and Dave Newport, Indiana, to Deepwater, New Jersey, to reach the deLesdernier, Battelle, July 29-30, 2014.
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From page 26... ...
If it is determined that the BTA cannot treat option. In April 2007, the Army issued another REC for the the hydrolysate onsite and it becomes necessary to consider proposed action to ship caustic wastewater derived from the shipping hydrolysate offsite, a corresponding NEPA action destruction of VX at NECDF to a permitted commercial may be necessary, potentially delaying shipment of hydroTSDF and found that the proposed action qualified for a lysate and, once storage capacity is reached, the destruction categorical exclusion for routine management of hazardous operations at PCAPP would need to halt.
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From page 27... ...
The primary purpose of the biotreatment system at PCAPP, to which mustard hydrolysate is fed, is to miner- 25 PCAPP RCRA RD&D Stage III, Class 3, Permit Modification Request, alize the organic compounds present in the hydrolysate, Revision 0, November 2006, Appendix D, Waste Analysis Plan, C-2a(3) including TDG.
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From page 28... ...
2008. Review of Secondary Waste will result in waste streams similar to those that will be Disposal Planning for the Blue Grass and Pueblo Chemical Agent produced during the actual mustard treatment campaigns at Destruction Plants.
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