Research development and demonstration permits

Finding 4-7. The applications for modifications of the research, development, and demonstration permits for both BGCAPP and PCAPP proposed that a number of specific secondary wastes be shipped offsite for treatment or ultimate disposal. 

BPBGT. 2006b. Blue Grass Chemical Agent-Destruction Pilot Plant Resource Conservation and Recovery Act Research, Development and Demonstration Permit Application, Volume II, Revision 3, September. Available online at http //www.pmacwa.army.mil/ky/activities.htm. Last accessed January 30, 2008. 

See NRC (2002) for background information on RCRA research, development, and demonstration permits. 

U.S. EPA Office of Solid Waste, Guidance Manual for Research, Development, and Demonstration Permits Under 40 CRD S ection 270.65, EPA/530-SW-86-008,"July 1986, NTIS Number PB86-229f92. 

Recommendation The Army shonld work with state regnlators to tailor RAP mechanisms to the magnitnde of the NSCWM recovery and treatment operations. Eor facilities, initial operations should be conducted under expedited RAP mechanisms (e.g., a Research, Development, and Demonstration permit) traditional Resource Conservation and Recovery Act (RCRA) permits, if necessary, should be employed after operations become routine. When mobile treatment systems or technologies are employed, and par-ticnlarly for small or even moderate qnantities of newly discovered NSCWM, expedited (non-RCRA permit) regulatory approval mechanisms nnder RCRA or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) shonld be nsed, as appropriate (Recommendation 4-1). 

RD D stands for research, development, and demonstration. This is a special type of RCRA permit that allows testing of treatment units for development and demonstration purposes. These types of operations require a permit even though it is much less stringent and demanding than a full RCRA operating permit. 

Recent amendments to the 1984 Hazardous and Solid Waste Act have discouraged the disposal of dioxin-containing wastes on land and encouraged the development of unique treatment technologies. The 1984 Amendments make provisions for the waiver of research development and demonstration (RD D) permit requirements by Environmental Protection Agency regional administrators to facilitate and expedite critically needed research (pilot-scale and prototype testing). 

Memorandum from Marcia E. Williams, Director, Office of Solid Waste, to Hazardous Waste Division Directors, Hazardous Waste Branch Chiefs, Hazardous Waste Section Chiefs, Regions I-X, Oct 3, 1985, Subject Research, Development, and Demonstration (RD D) Permits. 

The TC-60 TDC has been permitted and operated in the United States but only forthe destruction of phosgene and chloropicrin. For this reason, although eventually a full RCRA operating permit would be required, operations could be initiated under a research, development, and demonstration (RD D) permit. To allow continued operation of the TC-60 TDC, BGCAPP s Title V CAA permit would need to be modified. When obtaining the permits for operation of the TC-60 TDC in Hawaii, there was no public opposition. As previously discussed and as indicated in Appendix A, permits have been obtained for similar systems built for destruction of conventional weapons in the United States. The TC-60 TDC uses a catalytic oxidizer but no open flame in the pollution abatement system. The catalytic oxidizer does not appear to be a liability for the public or the regulatory authorities. Noise levels are not extreme. The system is transportable, a positive factor. 

MAPS will operate initially under a Resource Conservation and Recovery Act (RCRA) Research, Development, and Demonstration (RD D) permit and will transition to a standard RCRA Part B permit when operations become routine. The Army has worked closely with Maryland regulators, and the MAPS permitting process has gone relatively smoothly. 

RCRA Research, Development, and Demonstration (RD D) Permits RCRA also established a mechanism to allow for demonstration of small-scale, state-of-the art technologies and processes and for modifications of existing technologies or processes. This mechanism is the RCRA RD D permit. It allows for RD D of technologies that are not yet commercially available, units that require refined or improved performance, or innovative commercial units that require demonstration of performance and cost-effectiveness. 

In some cases, the wastes conld be managed under a waste management plan established nnder a CERCLA record of decision. RCRA research, development, and demonstration (RD D) permits and treatability studies may also be appropriate in certain cases. 

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