An overview of regulatory issues that affect the development of new waste treatment technologies Page: 22 of 64
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requirements include issues such as obtaining R&D permits, complying with
various reporting requirements, conducting appropriate reviews and submitting
appropriate documentation under NEPA, and adhering to appropriate worker
health and safety requirements and guidelines. In addition, other regulatory
"overhead," such as the time and effort to maintain ongoing "informal" inter-
action with regulatory agencies, needs to be identified and understood.
The regulatory issues related to implementing the technology closely
parallel those related to developing it. The principal concern here is to
identify and comply with regulations pertaining to the implementation of the
new technologies. These regulations will usually be very specific and, very
likely, site-specific and will frequently depend upon individual state
requirements and their interpretation by state agencies.
The analysis of regulatory issues associated with DOE's decision making
in selecting technologies to pursue involves the highest degree of uncer-
tainty. It involves the consideration of a number of factors, such as how
regulatory requirements would impose a variety of barriers to the implemen-
tation of a proposed new technology. For example, a technology that generates
a secondary hazardous waste stream may be less promising, from a regulatory
point of view, than a technology that generates material that can be recycled.
In addition, broader regulatory issues need to be addressed. These include
issues such as whether it is advisable to make substantial investments in
incineration technologies considering the current regulatory climate or
whether bioremediation is wise to pursue considering possible constraints
imposed by the land disposal requirements (LDR) of RCRA (bioremediation, in
some circumstances, may not be the technology specified by the applicable
LDRs).
Another issue is whether delays associated with regulatory requirements
related to implementing an otherwise promising proposed technology would
nonetheless make that technology unacceptable. For example, when evaluating
two otherwise comparable but competing technology proposals, it will be very
relevant to the RDDT&E decision makers that one of the technologies may face
fewer regulatory hurdles before being implemented in the field. Factoring
1.8
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Kuusinen, T L; Siegel, M R; Williams, T A & Powell, J A. An overview of regulatory issues that affect the development of new waste treatment technologies, report, July 1, 1991; Richland, Washington. (https://digital.library.unt.edu/ark:/67531/metadc1093979/m1/22/: accessed July 18, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.