&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9527.01(82)
TITLE:
RCRA. Permits, for.Mobile Treatment; Units and Mul-
'tiple;'Sites,.Using., the Same" Type, of: Equipment
11-2-82
11-2-82
Office of Solid Waste
APPROVAL DATE
EFFECTIVE DATE
ORIGINATING OFFICE:
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE Di
-------
PART 270 SUBPART F - SPECIAL FORMS OF PERMITS DOC: 9527.01(82)
Key Words: Incineration
Regulations: 40 CFR Part 270
Subject: RCRA Permits for Mobile Treatment Units and Multiple Sites
Using the Same Type of Equipment
Addressee: . Regional .Administrators..and .Regional Waste Management
Directors, Regions I-X
Originator: Rita M. Lavelle, Assistant Administrator, Office of
Solid Waste and Emergency Response (WH-562A)
Source Doc: #9527.01(82)
Date: 11-2-82
Summary:
If a mobile unit- is used at more than one site to handle a similar or
identical waste, a RCRA permit is required at each location.
After non site-specific permit conditions have been developed for the
first RCRA permit, these same permit conditions should be used for all subse-
quent permits. This should assure national consistency for permits issued to
facilities using t.he- same.-or similar equipment and should expedite the issuance
of permits. ' . ....
An applicant must apply for and be issued a RCRA permit at the first site.
The application for the permit at the next site should consist of the non
site—specific information :from the first application, a copy of the first
permit, and the site-specific information for the new location (including any
variations).^ -The permit writer- should: use.,the non site-specific permit condi-
tions from the first permit as conditions in the second permit. The permit
writer should only draft new permit conditions' for the site-specific items.
Previous responses to comments for the earlier permits can also be used to
respond to comments on subsequent permits so long as they are similar and
concern non-site-specific issues.. If a new issue is raised, however, the
Regional Administrator must respond to the comment before the permit may be
issued.
-------
.<..' i'".
-*" ^"'-
UNITED STATES-ENVIRONMENTAL
WASHINGTON, O.C.
NOV
2 IS82
SUBJECTS
FRO*
TOr
RCSA Fferntlts: for- Mobile Treat:
Using the, Same Type of Equipment
Rita- »„ Lave II e•'//• (^T
Assistant- Administrator
Office of Solid Waste; and Emergency Response (WH-562A)
Regional Administrators and Regional Waste
Management Directors, Regions 1-X.
you know,, a RCRA permit is required for each site at
which, hazardous waste- treatment, storage or disposal facilities
(TSDPs) operate, rf the TSDF is- mobile or if the- same type of
equipment C'g.g;. / a tank of identical design) is used at more
'than one .site to. handle a. similar or identical waste, a RCRA
permit is still required at each Location. The purpose of this
memorandum " LS "to establish the policy the Agency will use to
permit mobile- treatment units (MTU's) and ta permit fixed facilities
where s person: uses, the sane type of equipment to handle similar1
or- -identical wastes* •atMTOltiple? locations. •
•••;••' -A-- person-: 'applying -to' use- the- same/ type of equipment at
multiple locations «ill find that much 'of the information in the
permit application for the first location will not change for
the other locations because' the information is not" site-specific.
sennit writers should' note that after the non-site-specific
pernit conditions have been developed for the first RCRA permit,
these permit conditions should be used foe all subsequent permits.
while not. changing any procedures for obtaining a RCRA pernitr
this policy will assure national consistency for permits issued
to facilities: using the same or., similar equipment and should
expedite the issuance of .RC3S perrits, without compromising environ—
"rental con-trals-.
The procedures arr applicant and permit writer should use to-
deal with MTU" permits or same-type-equipment permits are as follows:
An applicant must apply for and be issued a RCRA permit at the
first site. It is the responsibility of the applicant to notify
the permit writer of the first RCRA permit. The application for
the permit at the next site should consist of the non-site-specific
information from- the first application, a copy of the first
-------
-2-
permitr and the site-specific in format-ion, for- the new Location.
This aits— specific information must, include any variation in the
equipment or wastes fronr those permitted at the first site. The • -
. permit:.. writer. should use- the non-site— specific permit conditions
fronr 'this 'first permit Cta the extent 'that variations in equipment
and: wastes do act require, otherwise] as conditions; in the; second.
permit and draft new. permit concf f tionst for the site- specific
items, only.
The Agency can. also rely ore. previous responses to, comments
for comments dealing- with non-site— specific permit conditions
received" ia a second (or subsequent)- proceeding if the same or
similar comments were raised on. an. earlier* permit. Response ta
public comment concerning aaa— site— specific issues should, be as
follows: If a comment is similar to. a comment raised in, an
earlier permit issuance proceeding, any response should be the
same as: that given in the first proceeding. If, however, a'
significant, comment addresses- an issue differently than it was
addressed, in the first proceeding, or a significant comment raises _
air issue oat: addressed: irr. the .first proceeding, ther Regional
Administrator anist, of course r respond ta that comment before
the. permit may be issued.. .
The, reuse of; part of. the tnir:i^.I. permit application- and the-
permit conditions wi_LL allow EPA- to streamline the
for multiple faO|tlitie
that use the- same type of equipment 'to handle similar or identical
wastes-'-/ This-' policy- ia". likely -to" be.' first applied to. SPA's
mobile incinerator which is currently being permitted in Region II
discussed: this approach with; Or". John A.' Tbdhunter,
Assistant Administrator, for Pesticides and Toric Substances, and he
has indicated that it is. consistant with, and similar to- the approach
his office will use to 'permit mobile facilities disposing of PCB's.
Zoarnore information cr guidance on the policy outlined in
this memorandum,, contact. Jeff EJetlefsen, of my staff, at EPA.
Headquarters^ 202—382-4300.
•s Dr. Jona A. Todhunter
------- |