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3 Regulations Governing Carbon Disposal
Pages 25-32

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From page 25...
... pose a subWastes derived from the management and destruction stantial present or potential hazard to human health of chemical agents and munitions must be assessed or the environment when improperly treated, stored, under this authority and, if determined to be hazardous, transported, or disposed of, or otherwise managed." managed under it. This includes waste activated carbon The statutory definition is implemented for a specific from all air- and gas-filtering units at each chemical waste through a series of regulations that require a agent disposal facility.
From page 26...
... Hazardous wastes stance is defined to include any substance specifically containing mercury are covered by the land disposal designated by EPA, hazardous wastes as defined under restriction regulations, which establish two categories: RCRA, toxic pollutants listed under the federal Clean low mercury (<260 mg/kg total mercury) and high Air Act, and imminently hazardous substances under mercury (≥260 mg/kg total mercury)
From page 27...
... ADEM Agent Disposal Facility (PBCDF) , and TOCDF all set recently approved a permit modification under which WCLs as 20 ppb for nerve agents GB and VX and 200 certain solid wastes not exposed to chemical agent ppb for distilled mustard agent HD, while the UMCDF liquids or to vapors at concentrations greater than the permit sets PCCs, which serve a similar purpose, of 13 ppb for VX, 16 ppb for GB, and 152 ppb for HD. 40 C.F.R.
From page 28...
... for regulations.10 According to the ADEM requirements, agent.12 only combustible nonporous solid wastes or objects that do not possess internal cavities can be evaluated for According to the PBCDF WAP, each batch of waste off-site disposal using chemical agent vapor monitor- from areas where chemical agent may be present will ing; thus, activated carbon is excluded (ADEM, 2006)
From page 29...
... . as represented by the Umatilla Chemical Depot and In addition to the EPA list of acute hazardous wastes, the Washington Demilitarization Company, LLC, the UDEQ regulations add the following state-specific to operate a hazardous waste treatment and storage listed wastes: nerve, military, and chemical agents (i.e., chemical demilitarization facility located in Umatilla CX, GA, GB, GD, H, HD, HL, HN-1, HN-2, HN-3, HT, County, Oregon.
From page 30...
... be a hazardous waste. 14Timothy Garrett, Site Project Manager, ANCDF, "ANCDF Finding 3-5.  Upon a determination that carbon from secondary waste initiative," Presentation to a fact-finding team of a chemical agent disposal facility is not a hazardous the Committee on Review of Chemical Agent Secondary Waste waste, it may be sent to a solid waste disposal facility Disposal and Regulatory Requirements, October 16, 2006.
From page 31...
... under the Hazardous Waste Material Transpor- Transporting Carbon Off-site tation Act.17 The administration establishes uniform The existing requirements to transport activated standards for the shipment of all hazardous materials, carbon off-site for disposal are stated in each facility's including hazardous wastes, and generally preempts RCRA permit. Any changes desired by the facility state and local requirements unless such requirements require applying for a modification to the permit -- a (1)
From page 32...
... Washto confirm that the agent concentration is below the ington, D.C.: U.S. Environmental Protection Agency.


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