Assessment of the Army Plan for the Pine Bluff Non-Stockpile Facility (2004) / Chapter Skim
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Pages 44-53
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From page 44... ...
44 5 Regulatory Approval and Permitting and Public Involvement Before PBNSF can be constructed and operated, it must undergo a permitting process established within the federal and state regulatory and legal frameworks to protect human health and the environment. The regulatory approval and permitting (RAP)
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REGULATORY APPROVAL AND PERMITTING AND PUBLIC INVOLVEMENT 45 containers defined as "empty" under RCRA (40 CFR 261.7) , is exempt from RCRA permitting requirements.
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46 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY Permitting Approach for the Pine Bluff Non-Stockpile Facility The PBNSF includes storage containers, tanks, vaults and miscellaneous units,4 with each category having its own permit requirements, which the permit application must address. Whereas the regulatory standards for containers, tanks and vaults are fairly prescriptive, requirements for miscellaneous units are performance-based.
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REGULATORY APPROVAL AND PERMITTING AND PUBLIC INVOLVEMENT 47 ence in the stockpile program shows that permit issuance for demilitarization operations involving chemical agent typically takes far longer than the 13 months allocated for PBNSF. Agent operations at PBNSF are scheduled to begin in June 2006 and end in April 2007, the CWC schedule deadline.
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48 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY Background to the National Environmental Policy Act NEPA (42 U.S.C.
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REGULATORY APPROVAL AND PERMITTING AND PUBLIC INVOLVEMENT 49 its offsite secondary waste treatment contract. If this effort is well conceived and implemented, local citizens are more likely to understand the treatment process(es)
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50 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY (Bradbury et al., 1994)
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REGULATORY APPROVAL AND PERMITTING AND PUBLIC INVOLVEMENT 51 and black communities, as having roots in the economic and political history of the region" (Bradbury et al., 1994)
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52 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY affairs program in Pine Bluff that goes well beyond legal requirements by holding informal meetings to ensure genuine public involvement could provide significant benefits: It would not only prepare the PMNSCM to deal with potential incidents, but might also enable the program to develop an on-site alternative for neutralent disposal, with community buy-in, should its plans for off-site disposal encounter opposition in destination communities and communities along the transportation routes. However, when the committee asked PMNSCM management about potential changes in the program's public affairs strategy, PMNSCM officials said their authority to institute change at the installation level was constrained by Army policy, although they promised to discuss possible improvements with their counterparts at PBA.
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REGULATORY APPROVAL AND PERMITTING AND PUBLIC INVOLVEMENT 53 the partnership has had time to talk with appropriate community representatives and received input to finalize locations" (DEA, 2003)
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