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Hazardous Waste Incineration Permitting Study
Summary ot Oirtc:iv«
Section 3005 of the Hazardous 4 Solid Waste Amendments of 1984 reauires that"
the Administrator issue a final permit or denial by 1989 for all existing (interim
status) incinerator facilities. This document presents results of a study designed
to evaluate incinerator permitting priorities, determine permitting timelines,
identify issues influencing the incinerator permitting, process and alternatives
for problem resolution, and orovide an accurate accounting of hazardous waste
incineration facilities.
Key Word*:
Incineration, Permitting
Typo o< Oiroctr»o tMtnmi. PoKf Onttnm. AttnmtnetmttH. «*c.;
. .'Program Implementation Study
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Officer
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HAZARDOUS WASTE INCINERATION
PERMITTING STUDY
U.S. Environmental Protection Agency
Office of Solid Waste
Permits and State Program Division
401 M Street, S.W.
Washington, D.C. 20460
August 1986
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TA51Z J? ^MT-'TrS
Pace
Summary 1
I. Introduction 4
II. Method of Approach 4
III. Results of Data Verification 6
IV. Study Findings and Recommendations 18
V. Implementation Planning 26
Attachment I:
Attachment II:
Attachment UI:
Attachment IV;
Attachment V:
Attachment VI:
Attachment VII:
Attachment VIII:
Attachment IX:
Attachment X:
Permitting Study Questionnaire
List of Incinerator Facilities
Data Base Format
Permitted New Facilities
Permitted Existing Facilities
Commercial Incinerators
Differences of Commercial Facilities
Between HWDMS and Incinerator Database
Facilities Whose Part B's Not Received
Exempt Facilities
Closed or Closing Facilities
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The authors wish to acknowledge "rhe assistance
of the Regional and State permit writers whose
efforts led to the completion of this document.
Special appreciation is given to Betty Willis
and Region IV staff who provided valuable assist-
ance in evaluating the questionnaires used in
the study.
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The Hazardous and Sciid v-'cst* Amendmer:s -'WSW»; of 1984 re-
quire the Envirorcner.ral rroc-?';.;:-i Agency -._ ar^njote the issuance
;f permits to faciiicies =-:&: pro--.:ds alternatives co land dis-
posal. Section 3005 of HSWA esquires -hat tne Administrator
Issue a final permit or denial t? 1989 for ail incinerator
facilities having interim stacus it the time of HSWA enactment.
Interim status shall terminate for all incinerator facilities in
existence at the time of HSWA -enactment if their Part 3 permit
applications have not been submitted by November 3, 1986.
The Permits Branch in the Office of Solid Waste initiated
this study to assess the current status of the hazardous waste
incineration permitting process. The study was designed to
evaluate incineration permitting priorities, determine the
length of time associated with the permitting process, identify
issues influencing the process and alternatives for problem
resolution, and provide an accurate accounting of hazardous
waste incineration facilities. No attempt was made to determine
incineration capacity.
The information base for this study was obtained during the*
Autumn of 1985 by means of a questionnaire survey of Regional
and some State permit writers and through data verification of
selected information contained in the EPA- Hazardous -Waste Data
Management System (HWDMS). The data show that there are 235
hazardous waste incinerator facilities which will require RCRA
permits. Of these, 223 will be required to conduct trial burns
to demonstrate performance. Only 25 have been permitted to
date. Of the total number of incinerator facilities, 27 are
commercial facilities (i.e., facilities which treat off-site
customer wastes), and 93 are associated with land disposal. The
facilities are unevenly distributed across the country: 28
percent of all incinerator facilities are located in Region VI
and 37 percent of all commercial incinerator facilities are
located in Region IV. The Regions identified 12 facilities
which are seeking the exemption for ignitable, corrosive and
reactive wastes. Another 39 facilities are expected to close or
have closed already.
The study indicates that incinerator permitting is proceed-
ing as rapidly as possible considering the technical complexities
of the process. The average permit processing time for new and
existing (i.e., interim status) facilities is 430 and 729 days,
respectively. These figures are consistent with the process
timeline developed jointly by permit writers for this study.
The time difference between new and existing incinerators is
attributed to the fact that the trial burn occurs after permit
issuance for a new incinerator and before permit issuance for an
existing incinerator.
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<<-
It is recognized that tf^e -study findings and XWDMS are in
lisagreenvsnt. ror example, as of July iS£5, HVGKS indicates
there are 352 incinerator facilities wnile the study indicates
274 (235 requiring permits and 39 closing). Activities are
ongoing to resolve these discrepancies.
Permit processing times of one to two years cannot be
significantly reduced under the present regulations. Current
regulations impose performance-based operating standards which
must be established through a lengthy trial burn procedure.
Regulatory changes specifying standard operating conditions for
given facility types rather than performance-based standards
(thus eliminating the need for a trial burn) would be necessary
to improve upon the minimum timeframes associated with
performance-based standards. Since regulatory changes of this
nature would take a minimum of two years to be approved and
promulgated, it seems highly unlikely that prospective
regulatory changes will assist the Agency in meeting its HSWA
deadline for permit issuance.
The study indicates that the time required for permit
issuance may actually increase' in the future. The reasons given
by Regional permit writers for the expected increase include:
increased workload demand associated with the HSWA deadline of
1989; the type of facilities under review (commercial facility
applications take longer to process due to the complexity of the
trial burn and the likelihood of public concern); requests for
variances (e.g., boiler variance); and the difficulties asso-
ciated with trial burn data review. Furthermore, permitting
timeframes may be extended in those Regions which called Part Bs
before they were ready to process them in order to weed out
facilities which planned to close.
The Regional and State permit writers indicate that high
priority is placed on the processing of commercial facility per-
mits. However, on the average, only one commercial incinerator
permit has been issued per year. Frequently, land disposal
facilities (both commercial and private) have supplanted
incinerator commercial facilities as the top priority. Permit
writers believe that the Agency's highest priority remains on
land disposal. Further, many Regional permit writers feel that
incineration, both commercial and private, is not a high
priority because the 1986 Strategic Planning and Management
System (SPMS) provides no performance targets for permitting
incinerators.
Secondary emphasis on incinerator permitting is one factor
extending the time period required to complete the process.
Other major factors are the relatively high turnover among
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permit writer staff and facility-caused delays associated with
requests for exemptions or lack of cooperation. The change-
over in permitting staff is particularly serious due to the
highly technical nature of the review process. High turnover is
attributed to lack of advancement potential and flight to
Superfund.
Although significant gains in permit processing cannot be
achieved in the current regulatory context, actions can be taken
to ensure that projected increases in permitting time are
minimized and to ensure that the permits issued are of high
quality and reflect national policy. To achieve these
objectives, this study concludes that a series of guidance
documents and models should be developed and disseminated (see
Section V). Established training courses should be offered on a
routine basis to assure that permit writers at all levels are
* given the opportunity to upgrade their skills.
s.
Improvements may also be achieved if Headquarters
establishes a higher priority on permitting incinerators.
Performance targets must be clearly articulated in SPMS in order
to assure the necessary resource allocations.
Finally/ action needs to be taken to maintain EPA's current
expertise in incineration. Such action could include providing
greater advancement potential and achievement recognition for
RCRA permit writers.
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HAZARDOUS WAST5 :fiiC:32BXTras ?gRMZrr?!KS STUDY
The Hazardous and Solid WJST:» Amendments .;HS'-'?A'» ot 1934
require the Environmental Protect,L-.n Arency cc» promote tne
issuance of permits to facilities that provide alternacives to
land disposal, such as commercial incineration facilities. The
P.CRA National Permit Strategy was revised in July 1985 to
reflect this new mandate.
To ensure that the goals of the National Permit Strategy and
HSWA are met, the Permits Branch in che Office of Solid Waste
requested that A. T. Kearney assist them in conducting a study
during Autumn 1985 to evaluate the hazardous waste incineration
permitting process.
The primary objectives of this study were to provide:
o An accurate listing of the universe of hazardous waste
incinerators, including those associated with land
disposal, and their permitting status;
o An evaluation of the priority which the permitting
authorities (Regions and States) are .placing on
commercial incinerators and increased treatment
capacity; and
o An identification of issues influencing the permitting
process and suggestions for resolving those issues.
The following report provides a summary of study methods,
findings, and suggestions for improvement.
II. METHOD OF APPROACH
The Hazardous Waste Incineration Permitting Study was
organized into three parts: development of the questionnaire,
verification of data, and analysis of the information collected.
A. Development of the Questionnaire
The subject matter of this study is both technically and
administratively complex. It was decided to develop a standard-
ized questionnaire which would be used to poll Regional and
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Scate personnel to ensure consistent qMescior.s were being
isked. The draft questionnaire w*3 organized to address both
region-wide and facility-speciric concerns as*cci-:ce'i '/ith tha
incinerator permitting process. Accc:.lir.*ly. ..t *as divided
into two major sections.
Part I was made up of a series of raanagement-uriented
questions in order to determine the Region's overall approach to
incinerator permitting. It included questions concerning the
Region's process for permitting and its policies regarding new
capacity (especially commercial).
Part II was directed at designated facilities and raised
questions relating to the specific situation of the facility
under discussion during each phase of the permit issuance
process. Its purpose was to uncover the technical issues which
arose during permit issuance, the types of technical assistance
sought by the individual permit writer, and specific problems
relating to the trial burn.
The questionnaire was sent to Region IV, where it was field.
tested. The purpose of the field test was to assess the
effectiveness of the questionnaire and to determine if any
changes would be necessary to elicit the type of information
required'to achieve study objectives.
The field team used both parts of the questionnaire. The
first part was discussed with Betty Willis, the Region IV
incineration contact. The second part of the questionnaire was
used to discuss four individual facilities with the responsible
permit writers.
The field team determined that with a few modifications, the
questionnaire was appropriate to use in the study. Attachment I
is a copy of the questionnaire. The questionnaire was then sent
to each of the Regional incineration contacts along with a list
of several facilities proposed for the Part II interviews. The
proposed facilities were selected based on information in the
Hazardous Waste Data Management System.
Attachment II provides the list of facilities which were
selected for the study. Selection criteria were: commercial
facilities, incinerators at facilities with land disposal,
federal facilities, and facilities which have either a draft or
final permit. The review team called each of the incineration
contacts and confirmed or revised the list of facilities to be
reviewed, obtained the names and phone numbers of the permit
writers responsible for the selected facilities, and then
interviewed each permit writer.
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Verification oi Ta-.j on tna Universe of Hazardous
r-r. rev:-*./ t..vair trrepi'sr- » -ia1- » T*enf iraticn for.- cc -e used
to l-'rerni.-e -h-* 3c:t'j.i'. vini '*rs-i .; J l-vmsr acors in rrlie United
Statroc and .? verity the -nt" cm*-/. ?n aoout tnose facilities
whir/. is contained ir. tne Hazardous Xuoca Data Management System
'.HWDKS; . A form was prepared for each incinerator facility and
sent -..: the Regions for verif icacion. Blank forms were also
provided so that the Regions couiri complete them for facilities
not already identified. Attachment III is a copy of a blank
form and the instruction sheet tzf. completing the form. The
data from these forms was loaded onto a micro computer to allow
for easy manipulation and access and the floppy disk containing
the information was provided to SPA.
C. Analysis of Information
The information for the study was not collected, nor is it
presented, on a statistical basis. The interviews were subjec- -
tive recountings of facilities' history from personal memory or
from what had been noted by a previous permit writer. The
interviewees identified examples of major technical and adminis-
trative problems encountered during the application review arid
offered suggestions for improvements. These analyses are based
solely on the information provided by the interviewees. No
independent verification of the data was attempted by A. T.
Kearney or EPA's Office of Solid Waste.
III. RESULTS OF DATA VERIFICATION
The data show that there are 235 facilities with inciner-
ators which will be permitted under RCRA. Of these 12
facilities are seeking the exemption under Section 264.343 for
burning wastes which are solely ignitable, corrosive, or
reactive. In addition, the Regions identified 39 facilities
which have closed or will be closing. Attachments IX and X
provides lists of exempt and closing facilities, respectively.
The distribution of incinerator types is presented in Figure
1. Among facilities for which this information is known, 38
percent are liquid injection and 34 percent are rotary kilns.
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Of the 223 facilities vh^.rn ;a*- iiazarcous waste incinera-
tors subject to the perfor.-nar.c3-r.;r^d permits, 93 incinerator
facilities are associated wiv l-i.-.l i*spcsal and 2" are
commercial facilities. The nu-Sex oi isciiities is less than
the number of incinerators since facilities may have more than
one incinerator; this study did sot determine the number of
incinerators.
The incinerator facilities are unevenly distributed across
the nation (-Figures 2 and 3). ?egicn VI accounts for 23 percent
of all hazardous waste incinerators and Region IV accounts for
37 percent of all commercial incinerator facilities. More than
three-fourths of all incinerators are located in Regions II,
III, IV, V, and VI.
The central and western portions of the U.S. appear to be
under-represented in the distribution of commercial incinerator
facilities. But in the absence of figures comparing regional
demand versus available capacity, it is unclear whether or not
the relatively sparse distribution of facilities in some regions
constitutes a problem.
Listings of permitted new and existing facilities are pro-
vided in Attachments IV and V, respectively. -A list of .all-
commercial inciner'ato'rs (i.e., incinerators which treat clients'
waste) is provided in Attachment VI.
The number of commercial facilities determined to exist in
this study does not correlate with the number identified in
HWDMS. This study identified three commercial facilities not
listed in HWDMS. These facilities include: Olin Corporation in
Kentucky, Trane Thermal in Pennsylvania, and Radian Petroleum in
Missouri. In addition, HWDMS lists 10 facilities as commercial
incinerators when in fact they are not. These facilities are
listed in Attachment VII together with an explanation for the
discrepancies.
At present, 180, or 81 percent, of all incineration
facilities requiring permits have submitted their Part B permit
applications. Of the remaining 43 facilities, 20 have not yet
had their Part Bs called in. Most of these are located in
Region VI (Texas) or in Region III. Both Regions plan to
request remaining Part Bs in the near future. Attachment VIII
provides the list of facilities for which Part Bs have not been
received.
Figures 4 through 7 illustrate the processing time for in-
cinerators which have received a RCRA permit. It is interesting
to note that although the number of incinerator permits issued
each year is increasing, the percentage of these which are new
incinerators is diminishing. This is primarily due to the
progress that is being made on existing incinerators.
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NUMBER OF INCINERATORS BY REGION
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
Incin-
erators
3
35
21
36
31
63
14
10
14
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235
Incinerators
With
Land Disposal
1
11
9
10
6
41'
5
6
6
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95
Incinerators
Without
Land Disposal
2
24
12
26
29
22
9
4
8
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140
Commercial
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0
5
1
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4
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The time necessa-y to issue permits is lengthening. Many of
c-.e permits which ate currently taing issued are those which have
osen difficult to process and ara only no,* i^csiving permits.
This affect will be racra pronounced 1:1 rr.e future because some
regions chose to call in the Part 3s at an earlier date than
others in order to weed out those facilities which planned to
close.
Figures 8 and 9 are estimates developed by Regional and
Headquarters staff for processing "typical" permits under
various scenarios. The average time to issue a permit based on
experience to date is stet days for a new incinerator and 729
days for an existing incinerator. The averages compare well
with the joint Regional/Headquarters staff estimates of 435 days
for a new incinerator and 700 days for an existing incinerator.
Figure 7 shows the breakdown of average permitting time by
Region. Variations in the mix of facilities permitted accounts
for most of the variation among regions. On balance, relatively
few permits exceeded the average processing times.
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Scenario 41
Region Issues
Permit:
2 NODs, and
1 request for
technical
clarification
1. Suimi^: Part fl
2. Agency reviews Par- 2 *nd prepares *OC
3. Applicant response
4. Agency reviews response and prepares NOD
5. Applicant response
6. Agency reviews response and prepares
completeness letter with a request -or
technical clarification or NOD
?. Agency drafts permit and begins public
notice process
3. Public comment period
9. Agency responds to public comments and
issues permit
TOTAL TIME FROM RECEIPT OP PART B
Ku«I:%.- of
2-.7 3*
0
3C-JO**
30
30-60**
30
30-60**
60-90***
45*
60
315-435 days
Scenario It2 7.
Authorized 7a«
State Issues 7b,
Permit 7c.
State prepares draft permit and submits
to EPA for review*
EPA reviews draft permit
EPA and State negotiate conditions
State issues draft permit
TOTAL TIME FROM RECEIPT OF PART B
60-90'***
45
15
5
380-500 days
* Time required for this step is a regulatory requirement.
** Time is based on guidance provided in Section 124.3.
*** Includes allocation of time for technical discussions with applicant
regarding permit conditions.
NOTE: Issuance of a RCSA permit for a new hazardous waste incinerator does not
guarantee that the incinerator will be available for treating hazardous
waste or even that it will be built. Other State and local laws may
delay or prevent the construction and operation of the incinerator.
-------
L.i^
IHCIBZSATCSl *laS.*.
Interin ? .a"-^ '
Scenario II
Region Issues
two HODs Cor
application
and two MOOs
for trial
burn data
1.
2.
3.
4.
5.
6.
7.
3.
9.
10.
11.
12.
13.
14.
Submit ?ar* 3
Agency reviews ?*rt 3 %nd prepares NCD
Applicanc r*roe«»«
Agency reviews response and prepares HOD
Applicant res-aonae
Agency reviews r«spons« and approves
Applicant sets up trial burn
Applicant conduces trial burn
Applicant analyses data and prepares report
Agency reviews report and prepares HOD
Applicant response
Agency reviews response and prepares HOD
Applicant response
Agency reviews response, prepares and
issues draft permit
15. Public comment period
16. Agency responds to public comments and
issues permit
Number of
Day a*
0
60**
30
60**
30
30
30
10
90*
60**
30
30
15
60-12CT***
45
60
Scenario #2
Authorized
State Issues
Permit
Scenario #3
EPA issues
CO for incom-
plete Part B
TOTAL TIME FROM RECEIPT OF PAST B
14. State prepares draft permit and submits
to EPA for review
14a. EPA reviews draft permit
14b. EPA and State negotiate conditions
14c. State issues draft permit
TOTAL TIME FROM RECEIPT OF PART B
4. Agency permit writer reviews & prepares
4a. Enforcement prepares and issues
Compliance Order (CO) with HOD
4b. Applicant responds to CO/settlement
conference
TOTAL TIME FROM RECEIPT OF PART B
HOD
640-700
days
60-120***
45*
15
S
705-765
days
60**
30
30
700-760
days
* Time required for this step is a regulatory requirement.
** Time is based on guidance provided in §124.3.
*** Time line includes allocation of time for technical discussions with
applicant regaring permit conditions.
-------
r:. STUDY PIPINGS ANC ?.r: -p?'-: r.-v.?7.j>:;s
A. Study ?iridings
Incinerator permitting .: r«n«:ail7 -proceeding as rapidly as
pc'.isiole consic«rieq the t*c^'..cal comp.exity inherent in the
rroress. The r.eea for adi'.c.cr.dl ir.toraaricn, reflected ia the
Mctice of Deficiency (NOD), -.33 major factor in the tine
necessary to process an inc..:«5cator application. NODs deal
preponderant!-/ wich the trial burn plan or the trial burn
results because of their critical importance co the quality of
the permit and because much cf the information required is left
to best engineering judgmen-.
The trial burn is often the only test cf incinerator perform-
ance. Accordingly, it must provide a reasonable approximation
of anticipated performance characteristics. Trial burn plans
are negotiated on a case-by-case basis and typically necessitate
a minimum of two NODs. Discrepancies in the type and quality of
the data obtained from the trial burn or problems associated
with the interpretation of resulting data often engender addi-
tional NOD cycles before such problems can be satisfactorily
resolved. The permitting processing time can only be shortened
significantly (i.e., permit issuance less than one year) if the
regulation is changed such that permit conditions .are based on
standard operating conditions instead of'performance standards
(i.e., trial burn).
1. Permitting Timeframe
The results of this study suggest that, although some gains
may be made in the time necessary to process incinerator permits
for target cases, the overall time frame will not be shortened
below 435 days for a new incinerator and 700 days for an exist-
ing incinerator. In fact, the average time that it takes to
process incineration permits may increase due to the types of
facilities being processed (e.g., commercial incinerators, which
are inherently more time consuming), work load increases
necessary to meet the HWDMS deadline (only 25 of the 235 permits
have been issued to date), requests for variances, and review of
trial burn data.
A notable exception to the average time estimate is the time
which was necessary to issue the permit for the EPA mobile
incinerator in Region VII. This permit was issued within 112
days of the date the Part B was received. The case is unusual
in that the unit had been permitted in Region II and applied for
a permit in Region VII using the non-site-specific information
from the Region II application. The Region expedited permit
issuance by intensifying personnel resources allocated to the
application and by encouraging public participation in the
review process. This type of resource commitment cannot occur
for the bulk of the incinerator facilities.
-------
1)
Many of the permit writers interviewed »ncicated they
believe it is possible *:o -^toc-iSi ir£-icati5ns for new
incinerators in 180 d-ayii and exi^-ir..? incinerator* in 365 co 545
days from the date th~t '-.he ?arr a is recei-«>d. Tnis raises
concern that permit wrt-ecs t>ay te providing tco optimistic a
picture of the permitcing process to the applicant.
2. Federal Facilities
The permitting of federal facilicies, particularly those
operated by the Department of Defense (DOD), poses unique
problems which are delaying the permitting process in many
cases. A major cause of delays is the slow response by the
applicant to requests for additional information. Delays may be
partly attributed to the structure of the decision-making
process in DOD and the Regional and State permit writers'
hesitancy in taking action to force the issues. For the
Regional permit writer, alternative actions are limited to
calling in the Part B and denying the permit. The State permit
writer, however, does have the ability to fine the applicant for
non-compliance. The success of such efforts is presently being
challenged in Federal court. In. addition, DOD is known to delay
the permitting process while searching for a decision by EPA
.Headquarters which is supportive of DOD's position (e.g., DOD
has petitioned Headquarters over the past several years
regarding the designation of "popping furnaces" as thermal
treatment other than incineration).
The types of federal hazardous wastes and activities which
are subject to RCRA are often unique (i.e., not encountered by
most commercial facilities except those dealing with the federal
government). For example, the permit writer must be familiar
with munition calibers in order to assess the munitions which
are subject to RCRA. This education process takes time and
often requires the permit writer to apply RCRA regulations to
situations which the authors never had in mind (e.g.,
destruction of off-specification hand grenades, destruction of
nerve agents, etc.).
3. Permitting Priorities
New commercial capacity is said to be a top permitting
priority in all Regions. But the results of the study suggest
that the Regional permit writers have not considered commeicial
incineration capacity as the top priority. Although 3 new
commercial incinerators have been permitted out of the 28
commercial incinerators which are listed on the data base, an
average of only one commercial incinerator has been permitted
each year. Frequently, land disposal facilities (both
commercial ana private) have supplanted other commercial facili-
ties as the top priority. It is interesting to note that, in
-------
T.ost cases/ other priorities were ROC xsnticnfed by the permit
writer as a cause for permit delays, me ermiv: writer" did say
tnat the "crisis of the day" and '-iSWA : s* :«*a often interrupt
out never stop the process. They -c r.^r. 3«=«i7i tc perceive
this as a shift in priorities but as <*n ^-Jiic^on to previously
established priorities.
The relative priority of incinerator applications is almost
always affected by the number and complexity of land disposal
facilities in the region and the effect oc HSWA. HSWA innacts
include the necessity for corrective action and the post-permit
issuance activities necessary to monitor the schedule for
remedial response.
Delays in permitting were frequently attributed to HSWA
implementation. A case in point is the Merck and Company
incinerator in Region III. The draft permit was in the 45-day
comment period when HSWA became effective. The permit was
modified to reflect the necessary changes and the permit
underwent a second public notice. Permit redrafting was delayed
because this was the first permit in the Region to incorporate
HSWA requirements.
Facilities requiring expanded treatment capacity under
interim status were not mentioned by any Region as a priority
for permitting. Considering that expanded capacity for an
incinerator usually means building a new incinerator under
interim status/ some Regions indicated a preference to do this
with a RCRA permit unless conditions were such that capacity did
not exist to treat waste.
4. Permit Processing
The processing of incinerator permits is influenced by many
of the same factors which affect other types of RCRA permits.
These factors include: changeover in permitting staff, facility-
caused delays for existing facilities, and lack of readily
available guidance on technical and policy issues. The lack of
permit writer technical expertise in the field of incineration
is particularly detrimental due to the highly technical nature
of the treatment activity. The specific effect of these factors
on the incineration permitting process is discussed below.
a) Every Region has at least one incinerator expert and
several other experienced permit writers. However, due to a
high turnover in permit writer staff at both the Regional and
State level, there continues to be a cadre of inexperienced
permit writers. These persons frequently lack training and
guidance on incineration and RCRA and learn through the permit
-------
review itself rather :haa throuqn formsi sd-..c*t^on. They tend
to rely heavily on the experts, who are tr'stct.ed in th<*ir
ability to act as both .Tsntor and p^rmi". *T_:»:. TurtherTiore,
the States similarly rely on regional exoe.-s or contractor
support rather than developing in-house expertise.
High turnover among permit wrizars can be attributed
to natural attrition, lack of recognition, and flight to tee
Superfund program by RCBA permit writers. The permit writars
said that a major reason for the attrition 13 due to the lack of
advancement potential (i.e., the pay scale usually tops ouc at a
GS-11 level) and because the "glory" is rsserved for Superfund.
New permit writers who have not worked on a permit
from the beginning may not be fully aware of the history of
individual facility issues. This causes significant delay in
processing permits and may result in permit conditions which do
not fully address the technical problems associated with the
individual facility. It appears that the permit files do not
track technical issues closely/ if at all. There is no
immediate solution to this problem. New permit writers will
invariably identify different issues because much of the
decision process is based on "best engineering judgment."
Guidance manuals may alleviate the problem.
b) Frequently the facility is the major cause of delays
in processing permits. This is particularly the case for exist-
ing facilities. Examples of facility-caused delays are that the
incinerator needed to be rebuilt or that the facility was slow
in responding to NODs. States have often been reluctant to take
enforcement actions in order to expedite the process. Even when
they do, the use of enforcement actions does not necessarily
result in speedier resolution of problems.
Facilities frequently rely on contractors to assist
them in developing permit applications, in building or alter-
ing the incinerator and in conducting trial burns. Yet con-
tractor resources are often not available on a timely basis due
to lack of understanding or poor planning, without timely and
effective contractor support, further delays are inevitable.
Variance requests by the applicant may significantly
extend the permitting process. In most cases, the applicant
continues to request a variance after an unfavorable ruling has
been made'by the Regions and Headquarters. Additional informa-
tion and further supporting arguments are typically presented
directly to Headquarters. Part 124 administrative procedures do
not define the procedures for variance request and appeal. Most
importantly, they neither define the point at which administra-
tive authorities are exhausted nor at which level they conclude
-------
(i.e.. Regional or Headquarters,-. Therefore, tr.e anpeai for a
reevaluacion of the variar.ee r.=
-------
:} t < s .00" v
B. Recommendations
Each Region has unique ...-jc'.*.^* ^r*i solutions which are a
function of the mix cf r-erT.li vriter experience, management
approaches, state interaction ar«^ tj.'pes of facilities and
political pressures encountered vichia. As such, an effective
solution for a problem in or.3 Aaqion nay be ineffective in
resolving the same problem ir. another Region. Nevertheless,
there are common problems and prospective solutions applicable
to all Regions. Effective resolution of many of the major
issues outlined above will require a reasonable degree of
national consistency in approach.
1. Develop Guidance Documents
The study results suggest that insufficient guidance is
available to the Regions and States on several key topics.
This in turn slows the incinerator permitting program. It is
recommended that guidance documents be developed in order to
accelerate the permitting process and to provide more uniformity
of program implementation nationally. It is also recommended
that these documents be prepared and presented in a manner which
facilitates their usefulness. They should be easy to read and
use. This should also serve to alleviate some of the burden
currently experienced by the regional incineration--experts. The
guidance may minimize, but certainly not eliminate, the number
of appeals of decisions made by the permit writers since the
Agency's position will have been stated in advance.
Guidance documents should be developed on the following
topics:
a) Continuous carbon monoxide (CO) monitoring, in-
cluding the types of monitors, sampling location,
pre-evaluation of sampling location, performance
standards, use of computerized monitoring systems,
calibration and zero-check method and frequency,
definition of what constitutes continuous monitoring
as required under Section 264.347.
b) Elements necessary in an incinerator system design,
including the adequacy of air pollution control sys-
tems and the automatic waste feed cut-off system. A
computerized model on incinerator physical design
characteristics is currently under development by
ORD.
c) Waste feed and POHC selection, including waste
analysis and "POHC-soup" for incinerators burning
multiple combinations of waste (i.e., commercial
facilities).
-------
d) Detailed cneov:.i»ta identifying ail necessary
elements of a.-.sline; and analysis programs; quality
assurance/q-a*.: ~7 control olans fjr sach sapling
and analysis Tstv.ra, an.1 T^nicoring procedures. A
checklist identifying far the permit applicant the
types of resources necessary tc construct, test, and
operace a HW incinerator. The Practical Guide -
Trial Burns fer Hazardous Waste Incinerators
(June 25, 1985), which was prepared by MRI for ORD,
provides much of the information for applicants on
the types of resources required.
e) A trial burn data base. This is currently under
development by ORD.
f) Guidance on the use of data in lieu of a trial burn
to expedite permit processing. This should include
guidelines considering the circumstances under which
use of data in lieu of the trial burn is appropriate.
2. Develop Model Documents
In addition -to guidance documents which assist permit
writers in resolving policy and technical issues, the study
findings suggest that "models" should be developed. The models
will serve to expedite the process by providing easy-to-use,
"cook book" examples for those parts of the permitting process
which apply in most, if not all, cases.
The models to be developed or updated are:
a) Model trial burn plans and monitoring procedures,
including a sampling and analysis plan with QA/QC
procedures for each sampling and analysis method.
b) Model incineration permits for classes of
incinerators (e.g., commercial incinerators).
c) Model trial burn results report format.
3. Improve Public Information
The public needs to be educated if incineration is to be an
accepted method of treating hazardous waste. The information
must be unbiased and must be presented in a form readily under-
stood by the public.
-------
0 0 ' >i
Public information brocnures sr.ouid ce prepared to assist
the permit writer in informing the public about the RCRA process
and about incineration. The following information brochures
should be prepared:
a) Explanation of the RCRA permitting process.
b) Explanation of hazardous waste incineration.
c) Explanation of the issues of special concern (e.g./
Dioxin, Products of Incomplete Combustion).
4. Provide Additional Training/Technology Transfer
Permit writers identified the following course needs:
a) A very basic course in hazardous waste incineration
for the novice permit writer. It should include a
discussion of the regulations, various common incin-
eration designs, and basic concepts of incineration.
b) A focused course on translating trial burn results
into permit conditions.
c) Periodic symposia to transmit to the permit writer
on a timely basis information and knowledge in the
dynamic and rapidly changing field -of hazardous
waste incineration.
Section V.B. identifies the training courses which are
available now or in the near future. With the exception of
periodic symposia, these courses appear to meet the training
needs identified above. The one major drawback to many of these
courses is that they are not offered on a continuing basis, and
thus, the training needs of the new permit writers and new
applicants are not met.
5. Provide Administrative Guidance
Many of the problems identified in the study are technical
in nature. However, a few deal directly with the administrative
aspects of the permitting program. The following actions are
recommended as effective means of administrative support:
a) Re-emphasize the need to address incinerator
facilities as a top priority for permit processing.
Heightened priority should be clearly reflected in
-------
both tna Jir- .-rj? i:. e S?M£. An a«'3rage schedule for
issuing ir.cir/w.. it.~.r parnucs s.-to.jll oe distributed to
assist rtiC.'.*~ '". -ra.7s^» .'r. .Jl*»r!n;..*i'3 and in
deterra-.-.».-..; -/.= ::/ .-»** ar:.:..--/ so ;neet the HSWA
deadlines.
b) Insure tr.cr':^:>. iistr^sucio.-. o:" -reliance docu.T^nts.
Frequently p-vrr^z writers ara net provided all per-
cinent juidaaca or do net take ~;-,e time to read che
guidance. I" _s suggested that a compendium of
applicable guidance documents be developed, main-
tained, and presided to all new permit writers.
The Permits and S~ate Program Division of OSW is
preparing a compilation of applicable policy
decisions. This information will be provided to the
Regions. The Permits Branch plans to collect
incinerator-specific information and to provide
copies of this material to all Regional and State
permit writers.
c) Provide guidance on when to reprogram funds for
additional contractor support and available
assistance from ORO. Some regions do not take
advantage of the technical expertise available to
them through contractual support, the Office of
Research and Development, or other regions.
d) Provide greater Headquarters support for permit
writers to expedite the permitting of 000
facilities. This would include coordinating
discussions between permit writers in conference
calls and providing timely guidance on issues. This
activity is planned to facilitate the permitting of
the DOD nerve-agent demilitarization facilities.
e) Take action to stem the exodus of qualified permit
writers from the incineration program. This action
should include providing increased advancement
potential for Regional permit writers and establish-
ing an award or bonus program so that permit writers
receive recognition for their achievements.
V. IMPLEMENTATION PLANNING
The implementation of the activities described above will
require careful planning to ensure availability of resources and
personnel. Planning will also be necessary to ensure that the
following criteria are met:
-------
- 27 -
o The improvements srould become effective on a
schedule which vili enhance the Agency's ability to
meet HSWA deadlines for incinefator permit issuance;
and
o The improvements should be accomplished on a
schedule designed to ensure that the most serious
information gaps are filled first and that informa-
tion is available when needed.
In the event that resources are limited, we believe that improved
guidance should take precedence over training since guidance
documents will have longer-term beneficial effects.
A. Guidance Documents and Models
The following is a list of proposed activities designed to
expedite and enhance the permitting process for hazardous waste
incinerators. The activities have been rank ordered based on
the effect each will have on permit quality, public acceptance,"
and timeliness. All of the activities identified, with the
exception of Tasks 11 and 12, .have been initiated as a result of
this study. Draft reports should.be available for distribution
to the permit writers for comment by December 1986. Regional
permit writer participation will be integral to the-development
of all guidance documents and models.
Tasks 9, 11 and 12 will be completed during FY 1987 if
sufficient personnel and extramural resources are available.
The Model Trial Burn for Commercial Incinerators, Task 11, was
delayed until FY 1987 because the development of the model is
dependent on information developed in other guidance documents
and models (e.g., Guidance on Setting Permit Conditions, Item
6). The Data Base, Task 9, and the Incineration Risk Assessment
model, Task 12, should be very useful to the permitting process
but have been delayed until FY 1987 because of limitations in
resources and because other task have been assigned higher
priority.
-------
9 4 3 '6 . :'
iTJTT.^cr: ?Q.r?MEirrs AND MODELS
Guidance Material
Rational* for Tasks
Continuous Monitoring OSW aaa no guidance in this area, yet the
for CO performance of the incinerator after the trial
burn depends on tne performance of the CO
monitor. Delays are being caused due to lack of
guidance because decisions of questionable
validity are being negotiated (Guidance (a),
page 23.)
Engineering of Hazardous Permit writers must evaluate the potential
Waste Thermal Destruc- performance of all new incinerators. This
tion (Computer Model) tool would improve the accuracy and timeliness
of the evaluation process. (Guidance (b), page
23.)
Public Information
Brochures on:
RCRA Incineration,
PICs, and Dioxin
Problem POHC Reference
Directory
Setting Permit
Conditions
Model Trial Burn
Report Format
Improved public education may mitigate
the NIMBY syndrome. (Improve public
information, page 24.)
The improper selection of POHCs results
in inaccurate trial burns. At present,
information about problem POHCs is known only to
a few people and is disseminated by word of
mouth only. This information must be documented
to ensure that good decisions are made by all
permit writers. (Guidance (c), page 23.)
The setting of permit conditions needs to be
standardized as much as possible to assure
consistency and uniformity. (Model (b), page
24.)
Disorganized and inadequate tria1 burn data
reports cause delays in the permitting process
due to difficulties in reviewing data. (Model
(c), page 24.)
-------
X3D MODELS
Guidance Material
Sationala for Taaka
3. Hazardous Waste QX/QC
Guidance
9.
Thermal Destruction
Data (Computerized)
10.
11.
12.
Guidance on Use of
Data-in-lieu of a
Trial Burn
Model Trial Burns
for Commercial
Incinerators
Incineration Risk
Assessment
QX/QC is very important to ensure data from the
trial 'aura produces 'good data' and to ensure
the continued performance of the unit.
(Guidance (d), page 24, and support for Model
(a), page 24.)
Permit writers should have a trial burn data
base so that decisions can be made based on real
experience. The mechanism for this has been
funded by other groups and the Permits Branch,
for a nominal fee, could have this capability.
(Guidance (e), page 24.)
Guidance on the' applicability of data-in-lieu
of a trial burn would expedite the processing of
some permits. (Guidance (f), page 24.)
The trial burn for commercial incinerators needs
to be standardized to facilitate permitting and
to ensure the trial burn design in fact provides
an adequate profile of the unit. (Model (a),
page 24.)
A user-friendly risk assessment model is needed
for such purposes as determining de-minimus
levels of Appendix VIII compounds and setting
priorities. A pilot model has been developed
and provided to the Regional permit writers.
-------
.GO'S
3 . Training
have describee! -i-saii *t -n-* t-ev ---..I r::-l-in-. (See
?«7«» ^5). S-evsral train.. ~4 csursei ?.t-> -<2K[-__v ivavl.- o le or
tc ili re dev-jicped withir. =i S.IOT-. parioJ or t;ra j.-. .hece.
~c?ics. The present syszea for providing ti-ai-.ir-; relies
heavily on regional prafsrar.css mi covers ell suci-sccs *rith all
levels of staff simuitar.^Tu-siy. Experience has snown caat this
sv^^em is act carticularly successful in TiO'Scin-3 ^egicnal and
Stice training needs because tr.a informacirir: is either not
advanced enough cor the experienced permit vrtter or tsc
advanced for the new permit writer. The course evaluations
suggest that several courses should be conducted at different
levels covering different topics.
1. A plan for training should be developed which will
address the following:
a) Permit writer training needs as a function of educa-
tion and experience. This should be determined by
polling the Regions.
b) Specific courses to be conducted, including course
outlines/ appropriate audience, duration. Recom-
mended topics outlined above (IV.B.4) should be
discussed.
c) A schedule for providing the training, balancing the
immediate needs of the permit writers with available
resources and instructors. This schedule should also
consider other training courses already scheduled.
d) A detailed estimate of the level of effort and
resources required to implement the training plan.
The estimate should recommend whether inside or
outside resources ought to be used to implement the
training- plan.
2. Several courses are already developed or are under
development:
a) Hazardous Waste Incineration Permit Writers Workshop
Developed by: A. T. Kearney
Audience: Regional and State permit writers
Duration: 3-4 days
-------
osvo -vjr,' :.;.:;:;',; ::o.
Schedule: This course will ce provided at the
request cf the Personal permitting authority.
Region IX has scheduled the course for the second
week in June.
b) Technology Transfer Seminar Series or. Permitting
Hazardous waste Incinerators
Developed by: ORD
Audience: Region, State, Industry, General Public
Duration: 2 days
Schedule: Three courses tentatively scheduled in
September and October 1986
c) Sampling and Analysis for Hazardous Waste Combustion
Workshop
Developed by: ORD
Audience: Region, State, Industry
Duration: 2 days
Schedule: Courses tentatively scheduled in FY 1987
The seminar courses under development by ORD [see courses b)
and c)] will be available to industry as well as permit
writers. These offerings should serve to educate the applicant
with regard to RCRA and incineration, potentially diminishing
facility-caused delays.
Together, the three programs outlined above meet the
training needs of both new and experienced permit writers.
However, b) and c) are offered only on a limited basis, and a)
is scheduled only at the request of a given Region. Budgetary
constraints preclude the Regions from scheduling this course
frequently enough to meet the needs of their permit writers.
-------
I SCA Chemical Services
BIG Pen
Pratt & Whitney
II Rollins
USEPA Mobile Inc.
Occidental
General Electric
Kodak
III Gulf Oil
American Cyanamid
Union Carbide
DuPont, Wilmington
Experimental Station
IV GE Wilmington
Kodak
Ciba-Geigy
Mississippi Army Ammunition
V Eli Lilly
3-M Chemolite
SCA Environmental Services
Ross Inc.
U.S. Army Savannah Army
Depot
VI Stauffer
Phillips
ENSCO
Badische Corp.
VII Iowa Army Ammunition
Mobay Chemical
Lake City Ammunition
VIII Rocky Mountain Arsenal
Amoco
Great Plains Coal Gasifi-
cation
Tooele Army Depot
IX Stauffer
Johnston Atoll
NAVMAG DEMIL Furnace
-^rnf> (»*t,» 1 » £. C ~ '^ £
~-7r.' /; i "* i«31
NYDOC03.M432
WVDC04341491
WVD060632291
DED003930807
NCD005040950
TND003376928
ALD001221902
MS0080016123
IND072040348
MND006172969
ILD000672121
OHD048415665
IL3210020803
LAD008161234
OKD000803601
ARD069748192
TXD008081697
IA7213820445
MOD056389828
M04213820489
C05210020769
NDD006175467
NDD000690594
UT3213320894
CAD076941103
TT0570090001
HI8170090015
C
T3
"Major", TB
C, LD
FD
T3
LD
T3
TB
LD
FD, TB
FD
FD
enf. problem
TB
Fed
TB
TB
C.
LD, C
Fed
C/R&D fac
C/TB
new, TB
LD, Fed
TB
Fed, LD
Fed
LD
Energy/
Research
Fed
new C
FD, Fed
Fed
None in X
C --
TB
LD
FD
Commercial facility
= Trial burn conducted
= Land disposal unit(s)
= Final determination
Fed - Federal facility
-------
The following questionnaire r.as been developed to support a
study of the progress of t're Tirsrious waste incineration permit-
ting program. It is separated into two parts. The first covers
general issues which pertain tr t.-.e Region's policies and proce-
dures for processing incineration permit applications. These
questions should be answered by managers responsible for the
overall incinerator permitting program. The second covers issues
specific to the progress of particular incineration facilities.
This part should be answered by the permi't writers (and relevant
specialists) who have worked or are working on specific permic
applications.
-------
*i i -
w "
HAZARDOUS WASTE INCINERATION
PERMITTING ST'JDY QUESTIONNAIRE
PART I
GENERAL QUESTIONS
1. Describe the system the Region uses to process incinerator
Part Bs. Specifically, discuss the following: Does the
Region generally rely on one person to address the entire
Pare B or is a team approach used? Does the Region regular-
ly conduct quality assurance evaluations of on-going permit
reviews? Is there a distinction made between completeness
and technical evaluations? Between NODs and Requests for
Additional Information? What information is normally
provided to the applicant when the Part B is requested? At
'what point is a.site visit conducted?-
2. iiow and wnen does the Region become involved in processing
State-issued incinerator permit applications?
3. What criteria does the Region use to set priorities for
requesting and processing incinerator permits? What, if
anything, has affected these priorities.over the last year?
-------
Hew many, if
pared invo1
-"-- the ~
,f any, f*c*l
,ving inc .:«»;..
ider
set
sow ilia ay , i i. au^, _^w*.... ..;..
pared involving inc-.: ?.jitr -:j
for the renainder b«? -.«jr? .*-e_'
ir. the samp.e set h-s-a r.J?3?
r-.;.-.a.--*rr.--nc clars r.s/* oeen pre-
tr -:-j ;.':: ies "' Vi.»:i ^;il the ?MPs
.o any cr tne facilities
In general, what is the level of experience of your permit
writers? Do you have enough permit writers with adequate
experience and education to meet the permitting goals of
HSWA? If not, what are your suggestions for improving the
situation?
Is the
Region's public participation program geared toward
h-riorit incinerators?
the high-priority incinerators
7.
How will the public participation program affect those high-
priority incinerator facilities?
8. Would it/does it affect
so, wnich ones and how?
the sample set of facilities? If
-------
9. How are requests for treatment capacity expansion being
handled at the State and Reriona: le.-2.7 Are applicants
usually required to ootair. tn-3 full $-54 permit or are
expansions being approved un-ler inter..7, status?
10. dow are inquiries for mobile treatment being handled? Are
applicants required to obtain full 5264 permits or are most
cases being handled under a change in interim status?
11. Are the Region and States doing anything to encourage new
commercial facilities? If so, describe.
12. How are inquiries for RD&D types of treatment being
.handled? What are the problems with this type of permit?
13. What is the Region's policy with regard to use of data in
lieu of a trial burn?
-------
14. * -.at could be done to f * - . 1
.numerators of the sc.tie -se
V«3t5?
-. 1 1 a uniformity of pe?riw.s foe
isr. *r.c burning the sane type
15. What problems specific to pre-HSWA implementation have been
encountered which are delaying permitting of incinerators?
16. What problems do you foresee with the HSWA regulations as
they affect incinerator facilities?
17. Are there cases in your Region where you have expedited the
review process? Identify the facilities. What instigated
the fast-track response/ how was it accomplished and what
was the time frame?
18. What could be done to speed up the permitting process for
incinerators? If this action was accomplished, conceivably
what is the shortest reasonable time in which a permit
could be issued?
19. What, if any, problems has the Region encountered in
addressing incinerators at federal facilities?
-------
9 -i 5 > . 00* 6
Regior.,- Sr
HAZARDOUS WA3T2 INCINERATION
PERMITTING STUCY QuSSTIONNAIRS
Part II
Requesting the Part B
1. What triggered the request for this facility's Part B?
2. What info'rmatioh was sent to the owner/operator along with
the -Part B request? ' '
3. Was there interaction between the permit writer and owner/
operator prior to submission of the Part B (e.g., meetings,
correspondence, telephone calls, site visits)? If so,
describe. Comment on whether this activity assisted in the
permit process.
4. Was the Part B submitted on the date it was originally due?
If not, why not?
-------
- 6
5. HOW could this part of the process be inp:t:v«d oc exoecliced?
-------
9438 .
oo'.ication Review
1. How was the review crgani-raa (;.e. did cne person review
the entire application; did specialises review individual
sections)? What was the bacfcground/crai.iing/experience of
the reviewers? Who had the responsibility to see the
permit through the review process? Did thai person change
during the course of the permit review? was the State
involved in this review? If so, how?
2. Was the incinerator component reviewed at the same time as
the remainder of the facility?
3. Did other facility components hold up processing the incin-
erator portion of the facility? If so, what were those
components? Especially identify if corrective action at
SWMUs or other regulated units was responsible.
4. Did other priorities delay processing the 'incinerator
facility permit application? If so, describe.
-------
When were the NODS anc'cr :*? ..-.sis cc: o,.
tion issued?
6. Were there any issues which continued to o* raised in NCDs
or additional information requests to whicn tne facility
did not respond? If so/ what were chey? Were tney
resolved? How?
7. What, if any, non-process-related issues were difficult to
resolve (i.e., Contingency Plan, security, preparedness,
etc.)? How were they resolved? Who was involved in
resolving those issues?
8. What additional communication was there with the owner/oper-
ator during the review of the application (letters, tele-
phone calls, enforcement actions, etc.)? What was the pur-
pose of the communication?
9. Was there a site visit? What was the purpose? Who partici-
pated? What were the results of the visit?
-------
10. Which components of tre Pare 5 had :ne rrosc .-?iJnifxcaat
technical deficiencies cr, th-r ii.'st suir\--j-<
, Waste analysis plan
Engineering description
Sampling & analysis procedures
Trial burn protocol
QA/QC
11. Briefly describe these deficiencies and discuss how they
were addressed by EPA and the facility. Was technical
assistance provided by the PAT? How was the assistance
requested (e.g., through the monthly conference call)? Was
it helpful and timely?
12. Were any data collected previously at this source submitted
with the Part B in lieu of a-trial burn plan? Were the
data adequate to assess comparability of units and perform-
ance of the facility?
13. Which of the above-mentioned components of the Part B were
most difficult to review and why?
14. What were the difficult technical issues and how wore they
resolved? Was technical expertise available to assist in
resolving those issues? If so/ who?
Examples: Continuous monitors/waste feed cut-off
Relationship of trial burn protocol and
desired permit conditions.
-------
- 10 -
15 Were there inadequacies in the facility's physical desiun
whicn affected the permit issuance process?
Examples: Continuous tncnitors (co/combustion gas v^ioci
Waste feed cut-off syscem.
16. What suggestions do you have which might expedite this part
of the review?
-------
3 . 00-6
Trial Burn and Draft Permit
1. Was the trial burn protvco. lo^qiately desigrsi to enable
development of permit Z3n/*.;.-;^".s for ^r.is particular
incinerator? (e.g.f >«re ins proper POHCs selected? Was
ash evaluated?).
2. What difficulties, if any, were there in scheduling the
trial burn?
Example: Establishing testing contractor
Obtaining sufficient waste
3. Did the facility meet all of the performance requirements?
If not,'explain what happened and discuss the time involved
in the resolution of the problem. Has a second trial burn
been required?
Was the trial burn report adequate to write permit condi-
tions (e.g., did the report adequately characterize the
results of the trial burn, could you find the data in the
report)? If not, what were the inadequacies? When was an
adequate report submitted?
-------
O
3 *
Describe the process use-;
.e.g., what other office
2nforcement)?
6. What/ if any/ technical issues arose in interpreting tue
trial burn data to develop draft permit conditions? How.
were they resolved? How long did it take to develop the
draft permit conditions?
7.
What additional communication took place between
writer and owner/operator during the development
draft permit?
the permit
of the
8.
What suggestions do you have to expedite this portion of
the process?
-------
9 4 : h . 0 0 "
f^slic Comment Period ar.^ fi^a..
I. Did the cwner/ooericrr under1:*^ an/ upfront pub!-:
relations worfc to ov»r;:3iae nsgacive puoiic inzaresc in the
incinerator?
Did the Region do anything to expedite the public comment
period, such as scheduling a public hearing without waiting
for a request from the public?
3. Was a puolic hearing held?
4. What issues were raised during the public hearing and
comment period?
5. Did unanticipated issues arise during the public comment
period? What were they and how were they resolved?
-------
Was the draft permit ,nciiti?c as a result of tr.e p-:c-.-.c
comments? If so, how:
Was the public cotiunenc period reopened to address
modifications of the permit?
8. What, if anything/ delayed the issuance (or denial) of the
permit?
9. If the permit was de'nied, why?
10. Did the owner/operator appeal the final determination?
-------
V
- 15 -
Summary Observations
1. Do you have any specific reccinmenddwicr.s ccr expediting the
permit process?
2. Do you use any or all of the following Guidance Manuals:
o . Guidance Manual for Hazardous Waste Incinerator
Permits/ SW-966, July 1983.
o Model Permit Application for Existing Incinerators,
Draft, 1985
o Engineering Handbook for Hazardous Waste Incineration,
SW-899, September 1981 (revision expected December
1985) .
-------
00-6
New Facility Questions
New incinerator facilities present a special rase in processing
permit applications. DescriJs* an* issues not previously
discussed* (administrative/ technical or public interest) which
affected the issuance of this permit. Clarify if tney were
concentrated in any of the four phases of a new incinerator
permit.
Break-in period (e.g./ difficulties in establishing
waste feed conditions for break-in period)
Trial burn period
Shakedown period
Final permit period
Do you address the four phases of a new facility permit uniquely?
Describe . . .
-------
Faci-it-si
$$.00"6
I SCA Chemical Services
BIG Pen
Pratt & Whitney
II Rollins
(JSEPA Mobile Inc.
Occidental
General Electric
Kodak
III Gulf Oil
American Cyanamid
Union Carbide
DuPont, Wilmington
Experimental Station
IV GE Wilmington
Kodak
Cioa-Geigy
Mississippi Army Ammunition
V Eli Lilly
3-M Chemolite
SCA environmental Services
Ross Inc.
U.S. Army savannan Army
Depot
VI stauffer
Phillips
EwSCO
Badische Corp.
VII Iowa Army Ammunition
Mobay Chemical
Lake City Ammunition
VIII Rocky Mountain Arsenal
Amoco
Great Plains Coal Gasifi-
cation
Tooele Army Depot
IX Stauffer
Johnston Atoll
NAVrtAG DEhIL Furnace
'..-.
O =3431 f. I
u
TB
/ TB
NJD960526S93
NYD000824432
SYD066832a23
NYD980592497
PAD049791098
WVD004341491
WVD060682291
DED003930807
NCD005040950
TND003376928
ALD001221902
MS0080016123
IND072040348
MND006172969
ILD000672121
OHD048415665
IL3210020803
LAD008161234
OKD000803601
ARD069748192
TXD008081697
IA7213820445
MOD056389828
M04213820489
C05210020769
NDD006175467
NDD000690594
UT3213820894
CAD076941103
TT0570090001
HI8170090015
C, LD
FD
T3
LD
TB
TB
LO
FD, TB
FD
FD
enf. problem
TB
Fed
TB
TB
C
LD, C
Fed
C/R&D fac
C/TB
new, TB
LD, Fed
TB
Fed, LD
Fed
LD
Energy/
Research
Fed
new C
FD, Fed
Fed
None in X
-------
WWWI Wll bWIIVI. XV
- s c : o
.00-ti
"' ; ; r- c * c t c £ : : ~ s .'. ; 2 : C o fo s r ; . » t
ccszts ;:--i-*.5: -' 'iwt'Dsr 5- 'i
c * :r »:. -e-a-;-: ! s s : r ; 3 1 i c * :
'CZesSri :
. **»
i -'. e I -5 .
r ? : : : 5 : ; 3 r
IT ".«;. 4S*. -; HI: :-. ;ir,s: :r.-ir ,-«-i c
r-. il sc-^ ^ar, 3u:t ;:: /'
" : i 1 S u r n P c o r - i u z ,:a : * 5 i :
r.c
n«
ir.6l !'&. 6 TIB: r, it: :: - ? I . ?J. Ml)
i n ; 1 I- = : 5 r r, : n a : : 3 r. D -. \ 5 : / /
;J:R M;CI"IC«TICN
*sr«:
.:rrece:vsc: /
es* for Additional indorsation:
;uciic Nct;ce o4 Draft: / / Public Hearings /
"inal "-stgriBinA-iGn: \PI, PO, MM)
ri-i£l Detsria nat: or. Dite: / /
.-**** MAJOR MODIFICATION TWO
5 - 1 B p. s c s : / e a : / / '
." ;Fsr-. est fcr Aciit'.or.il In-f
r:*til cats'- ffiinati or. : \"l, PD, M!"..'
Fir.fe'i I'Stsrein at i on Dats: / /
dftCCP. MODIFICATION THREE ***********************
r i r : c r 5 c s i . s : :
'Jll'/r.ssuss t ror isiiticn*.! Inforastior:
~ 1 1 : c K : t : c s of S * x *. :
r:.-il :-5-.5r1T.:r,i-.i:r.:
.- " c . L- e t 5 r r ; *i i. " i c- r. k- i l
-------
-
.o-«
0* DATA 2*-Z'.*E>" 13
last Update:
Thi» is tft« date the iaiacMtion was entered into th«
computer.
Region:
Self-explanatory.
State:
Self-explanatory.
EPA ID:
Self-explanatory.
Street, City, Zip:
Self-explanatory.
SIC:
Provide Standard Industrial Codes representing the
three most prevalent processes at the facility for
which the incinerator is used.
Original
Regional Contact:
Provide the name of the permit writer for this
facility.
Incinerator Existence:
Write "N" if the incinerator is a new incinerator.
Write "E* if the incinerator is existing.
[HOTS: This is not intended to describe interim
status of the facility.]
Commercial Facility:
Write *T* if the facility is a commercial facility.
Write '? if the facility is not a commercial facility.
Accepts Off-Site:
Write "T* if the facility accepts waste from off-site.
Write '?' if the facility does not accept waste from
off-site.
[NOTE: A facility which accepts waste from other
facilities owned by the same company should
write !.]
-------
^f Waste Streams:
Descris* £.-
incinerator.
A - i
3 - :
C - i
r-sar* .-.andi
-------
4* '? .><} 6
Tr.al aurn Report
Sremitted:
Provlc* cw.« d.*:.* --a-; ;** T;iai Burn Report was submit-
ted, if «?pliCAC.«. -?-i-:e *s provided foe tvo dates.
Public Notice
of Draft:
Provide th« dat* the Piclic Notice of cne Draft Permit
was issued. Space is provided for two dates.
Puolic Bearing:
Provide the dats the Puolic Hearing was held, if
applicable. Space is provided for two dates.
Final Determination:
Describe the type of Final Determination made.
PI Permit Issued;
PD Permit Denied;
MM Major Modification.
Write:
Final
Determination Date:
Provide the date of the final determination.
For new facilities, space is available to provide relevant dates concern-
ing the initial break-in permit plus the three possible major modifications,
including the trial burn, the shakedown, and the final permit.
-------
' ^^ f ' '* \ \ ^ / *
*-.?. ., IJ O > 'NUMfatR OF -. -.-w:-:-:. >=.:...= :- -!;- B :?-=. iCAT ION
,_'". *:-<-.. V'r^r :*-.;-'' i ~n
jr»&'Jr- wf-" DAYS
;V CORPORATION OF LI .-- , «_>:."> .~I!"*3a5 528
JOHNSTON ATuLL CHEM -..'.c-.' M a.~ Tv .'_".-'( .«.>«' 01 487
LWD, INC. CLAY " N '.(. ^o 17857A S4O
MCDONNELL DOUGLAS E'._£uT*r;Ci CO MODC 7S8'-58437 380
NCR-AM CHEMICL CO/ErT T.H£.^ INC .11 L« e075o3!51
FENNWALT CORP. rvDOuo.r~Oi 39
PHILLIPS RESEARCH LEi.'ER OK. j0i.-0a03o01 410
PPG INDUSTRIES, INC. QHCOC43O46a9 347
U.S. ARMY '.MSAAP) rlSOeO'.;016123 239
U.S. ENVIRGNMNTL PROTECTN AQCY NJD9a0326693 332
U.S. EPA MOBILE INCINERATOR M06680O90O10 112
Ur)TON CARBIDE SO CHARLESTON PL WVDO05O03483 557
USEPA COMBUST I Oti RESRCH FACLTY AR614OOVO006 354
WASTE TECHNOLOGIES INDUSTRIES OHD980613341
-------
9 4 .V > . o 0 - 6 ii
NUMBER *-! ^1 843
"uRWOUD, INC. W; vO..'*s'. 4uv^7 S97
DUPONT EXPERiMENTri. STATION DEDOO:-«7« bt'^ 920
EASTMAN KODAK NVD9eC^«24^7 717
HERCULES, INC. RESEARCH CENTER £/EL-VO:3:5G'»? 563
MERCK !< CO INC-MERCi- CHEM 31.'. PADO030433I3 938
MERCK S-: CO. , INC. PAD00^33.'=;s 577
UNION CARBIDE CRF7ICHNICL CTR WVDO
-------
"j* » v - 'J0-6 i
--".-..'.: AERATORS
FACILITY
#,BCO INDUSTRIE?, I'.C. «
c-C OF CTY CM3NRS MS": _C ' -. ',v; >.'» r '". .ISO
C-LDWELL SYSTEMS, I*-1:. < ." '>...-7'. 232
CHEMICAL WASTE MANAGi^E"*". I'*-.: A
SUPONT E I DE NEMCx>c r. i.<: . N
EASTMAN KODAK CO.
ENSCO. INC. ,H
INDUSTRIAL LIQUIDS -'EC''CLI N.j I T
IT CORPORATION OF LOUISIANA
IT CORPORATION VINE HILL F^CIL 3
uWD, INC. CALVERT CITY .^.'0068436817
_WD, INC. CLAY HVD08S438S74
MITCHELL SYSTEMS, INC. NCD991277724
NORLITkl CORPORATION NYD08046993S
01. IN C'ORP/CHEMICAL QRP M VD006396246
RADIUM PETROLEUM COMPANY MODO73027iO9
K'OLLINS ENVIRNMNTL SRVCES (LA) LADO 10395127
ROLLINS ENVIRONMNTL SRVCES,INC NJD053288239
COLLINS ENVRNMNTL 3RVCS TX INC TXD055141378
ft033 INCINERATION SERVICES INC OHD04S415665
SCA CHEMICL SRVCES INC ILL DIV ILDOOO672121
STABLE< SOUTH CAROLINA, INC. SCD044442333
TRADE WASTE INCINERATION, INC. ILD098642424
TRANE THERMAL COMPANY PA.D069O06419
WASTE RESRCH ?* RECLAMATION INC WID990829475
WASTE TECHNOLOGIES INDUSTRIES OHD9.8O613541
WASTE-TECH SERVICES, INC. IDDO72961295
-------
00-6
'.rTACHMENT VII
ERRONEOUS
Facility
MO.
Comments
CIBA-3EIGY Cocp,
Soucheastern Waste
Treacaent, Inc.
Clean Harbor of
Braincree iSCA)
General Electric Co.
Pittsfieid, Mass.
TromDetta, Inc.
A-l Disposal Corp.
Coating system's, inc. "
Battery Disposal
Tech.
Delaware Container Co.
Hydrite Chemical Co.
ALD001221902
GA3000222383
MAD053452637
MA0002084093
MAD019474691
MID0596954452
NHD056331077
. *
NYD000632372
PAD064375470
WID006435887
No; a commercial incinerator.
Incinerator is not in operation.
Incinerator has not formally
closed.
Suspended incineration operation
on 1/31/86.
Not a commercial incinerator.
No incinerator.
Incinerator closed.
No incinerator.
RCRA exempt.
No incinerator.
RCRA exempt.
*HwDi4S - Hazardous Waste Data Management System
-------
: * -TEN -E
_i i -. C._'
,JU1 I"'
> b. r-'-v> t -SiM
C5& WITH NU
I':C.-ATE THE PART b K
'f ' fr'IiCM CM.L.ED-IN)
..,u.> JED CHtrilCAL CORP. -AI-f-IELD
^.LIED FIBERS ?/ PLASTICS CO.
AMOCO WHITING REFINRY-LAl-EPRNT
rtFh -"-iNSAS EASTMAN COMPANY
BRISTOL LABORATORIES CQRPCRATN
CELANESE CHEMICAL COftPANV , INC
DOW CHEM CO USA OYSTER CREEK
C I DUPONT HE NEMOURS ?- COMFNY
EL PASO PROCTS CO ODESSA CMPLX
ELI i. ILLY t: CO., INC. MAVAGUEZ
ENERGY COOPERATIVE, INC.
ENGLEHAPD INDUSTRIES DIVISION
ENVIRONMENTAL MANAGEMNT SRVCE3
FMC CORPORATION
GENERAL DYNAMICS FT WORTH DIV.
K'U&BEi- CO.
hUBBER CO.
ER3TV-VET MEDCN
LT1- , EF GOODRICH
'
VA'J'.'653S52 Oi"1. . i i Of !
r--Gi-ARQlD C'j! .'. URA1 ION
f-'C'i- YREZ CO. , 1 NC.
PPG [NDHSTRIES, INC.
FEICHHOLL' CHLrli LT.LS , INC.
ROTH BPCTHtHi aflELTING CORF.
SCA CHEMICAL. SERVICES INC. TN
SK-V.F LAD CO. , CHEMICAL DIV.
bTAUFFE!-: CHEMICAL CO.
TROFE, 1NL.
TRW, INC.
U S [NDiJ-a TRIAL CHEMICALS CO.
UNITED STATES STEEL-POLYESTER
UP JOHN CU. POLYMER CHEM DIV.
us AIR FuKcii - V.ELLY API?
VOLUNTEER ARMY AMMO PLANT
5HT CORPORri riON
'\ F.-- I ECH SfeRV I CES , I NC .
eRDOOOoe25S8
TXOUo94S0279
TXDOOOS03270
TXDO08079212
TX0980626014
PRDO9 102 4786
INDO82547803
NJD04121 1392
PRDO00743187
TXDO83570051
TXD008O 16958
TXDO57422685
TXDO080 77561
FLD004104105
NO ID * YET
TXD070 133319
NM0890010515
LAD059 122077
ALDOO4O10757
NJDU02 144202
TXD00809001 1
TXDO741800] 9
MAD00140232O
NJD002330322
OHD004347308
TXDO08063398
NYDO06977086
TND000772186
PRDO9O613357
ALDO95688875
NJDO9527526C'
OHDOO4 179453
TXD058276130
NJDOO 1724988
TXDOOOO 17756
TX 257 172 4333
TN6 2 10020933
TXD04 1089467
IDD07296129S
08/28/84
06/0
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