Alternatives for the Demilitarization of Conventional Munitions (2019) / Chapter Skim
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6 Regulatory Requirements Applicable to Open Burning, Open Detonation, and Alternative Technologies
6 Regulatory Requirements Applicable to Open Burning, Open Detonation, and Alternative Technologies
Pages 71-77
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From page 71... ...
program.2 Under OB/OD and alternative technology units may be subject RCRA, hazardous waste treatment, storage, and disposal to permitting under CAA, which governs air emissions from facilities (TSDFs) used to demilitarize waste munitions certain types of facilities.
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From page 72... ...
Therefore, each state's permit writers must folenvironment."10 The 1980 permitting regulation allows the low state law and regulations and typically review and assess OB and OD of waste explosives, within specified distance scientific information, policies, and legal requirements each and weight limitations, during the interim status permitting time a Subpart X permit is being developed for an alternative period.11 In 1987, the EPA concluded that facilities conduct technology, resulting in duplication of effort by the Army and ing OB/OD of waste explosives would receive permits under the state and possible conflicting outcomes for similar facilithe RCRA Subpart X provisions as miscellaneous units.12 ties. The lack of specific detail in the regulations concerning RCRA regulations establish specific conditions for certain technical permitting requirements for Subpart X facilities TSDF technologies, including incinerators; thermal treat places the burden on state regulators to devise technologyment; chemical, physical, and biological treatment; land and site-specific requirements for OB/OD and for the wide treatment; landfills; and surface impoundments.
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From page 73... ...
NOTE: ANMC, Anniston Munitions Center; BGAD; Blue Grass Army Depot; CAAA, Crane Army Ammunitions Activity; HWAD, Hawthorne Army Depot; LEMC, Letterkenny Munitions Center; MCAAP, McAlester Army Ammunition Plant; TEAD, Tooele Army Depot. unit permits for the Army stockpile depots have relied on the Some state permits impose environmental and operational best available OB/OD emission factor database, a compila- limits for Army Subpart X units based on dispersion modtion of numerous OB/OD emission tests within an enclosed eling.
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From page 74... ...
26 ANAD Hazardous Waste Facility Permit, AL3 210 020 027, issued 29 EPA, Resource Conservation and Recovery Act Public Participation November 14, 2007. Manual, January 11, 2017, 530-R-16-013.
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From page 75... ...
The premise of clean closure is that all hazardous wastes TREATMENT UNITS EXEMPT FROM RCRA have been removed and any releases at or from the unit have PERMITTING REQUIREMENTS been remediated so that further regulatory control under As discussed by several presenters, including the EPA,34 RCRA is not determined to be necessary to protect human some alternative technology units may not need an RCRA health and the environment. Clean closure may leave in TSDF permit.
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From page 76... ...
Also, see letter certifications filed with 43 EPA Draft Alternative Technologies to the Open Burn and Open the Utah Department of Environmental Quality dated January 14, 2014, Detonation of Energetic Hazardous Wastes, dated October 19, 2017; Draft January 7, 2016, and January 10, 2017, respectively. Alternative Technologies to the Open Burn and Open Detonation of Ener- 46 TEAD RCRA Part B Permit Application, Attachment 21, OB/OD getic Hazardous Wastes Workbook/Matrix, received October 19, 2017; EPA Treatment Effectiveness, Alternative Technologies and Waste MinimizaDraft Alternative Tech Not Going Forward, received November 17, 2017.
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From page 77... ...
for alternative technology units that would be they become a problem that could significantly delay permitpermitted as Subpart X units. ting alternative technologies.
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