Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (2008) / Chapter Skim
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3 Regulatory Requirements Applicable to BGCAPP and PCAPP Secondary Waste Management
3 Regulatory Requirements Applicable to BGCAPP and PCAPP Secondary Waste Management
Pages 23-26
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From page 23... ...
currently operating chemical agent disposal facilities, have One of the important differences between characteristic obtained EPA authorization to implement and enforce state hazardous wastes and listed hazardous wastes is that, under requirements for the management of hazardous waste. RCRA regulations, any wastes derived from the treatment, Each of these states has adopted the basic EPA hazardous waste management program, including regulations for A hazardous waste code, consisting of a letter followed by three num identification and listing of hazardous wastes; requirements bers, is assigned by the EPA or the state regulatory agency to each listed applicable to generators and transporters of hazardous waste; waste.
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From page 24... ...
to construct, test, and operate a facility teristic, they are no longer hazardous wastes and may be designed to destroy chemical munitions containing the nerve managed under the less stringent rules for nonhazardous agent GB and related waste using neutralization technology. solid wastes.
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From page 25... ...
While the Bechtel Parsons Blue community to respond to releases from such a facility, the Grass Team and the Program Manager for Assembled Chemplan must provide for sufficient training, coordination, and ical Weapons Alternatives are not in violation of regulatory equipment for state and local emergency response personnel, requirements and have ample time to meet the requirement including health, police, fire, and other responders. It must to submit a waste analysis plan for BGCAPP 18 months prior demonstrate a capability for evacuating prior to exposure to receipt of munitions at the facility, it would be prudent to all individuals who might be exposed to releases from the develop and submit the plan as early as possible in order to facility during a credible worst-case release or otherwise determine the requirements that may be placed on the operamitigating their exposure. tions by the Kentucky Department of Environmental Protec tion and avoid unnecessary delays to the operation.
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From page 26... ...
The Board has determined that the phasing (Hazardous Waste Code K901) , and of the project and CODs is appropriate and has directed the • Any soil, water, debris, or containers contaminated phasing to be in the form of multiple applications and cer through contact with waste chemical weapons listed tificates generally paralleling the three stages of the RD&D as K901 or hazardous wastes listed as P909, P910, permits and the three stages of construction, as outlined in or P911 (Hazardous Waste Code K902)
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