&EPA
            United States
            Environmental Protection
            Agency
          Office of
          Solid Waste and
          Emergency Response
DIRECTIVE NUMBER: 9527.02(82)
TITLE: EPA's Mobile Incinerator

APPROVAL DATE: u~2'82
EFFECTIVE DATE: 11-2-82
ORIGINATING OFFICE:
0 FINAL
D DRAFT
 STATUS:

REFERENCE (other documents):
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 PART 270   SUBPART F - SPECIAL FORMS OF PERMITS
                                                 DOC:   9527.02(82)
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 Summary:
Incineration

40 CFR 270.62

EPA's Mobile Incinerator

Regional Administrator and Regional Waste Management Directors,
Regions I-X\  •          • , •     •••••'

Rita M. Lavelle, Assistant Administrator, Office of Solid Waste
and Emergency Response

#9527.02(82)

11-2-82
      EPA  has  developed  policy to expedite the issuance of RCRA permits to
mobile  treatment  units.   (See recent  memo titled "RCRA Permits for Mobile
Treatment. Units-and  Multiple Sites  Using the Same Type of Equipment").  The
first application of this- policy, is likely to be in relation to EPA's mobile
incinerator.   A model RCRA application and model permit for the mobile incin-
erator  has  been prepared.   These models address the non site-specific permit
conditions, these will  not change from site to site.

   —The-criteria to be  used for selecting future operating sites for the
mobile  incinerator include:   1.  incinerability of the material; 2. degree of
hazard  based  on nearness to  population, toxicity, amount, etc.;  3. cost;  4.
...time;- -.5... policy. . EPA.':S. mobile  incinerator, must obtain all permits required
by Federal, State  and local  governments at each site.

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'•JF.MORANDUM
SUBJECT:  .-SPA1 s- Mobile Incinerator

P^OM:     Rita M. Lavelle, Assistant Administrator
          Office of Solid Waste and Emergency Response

TOs       Regional Administrator and Regional >/aste
          Management Directors,. Regions  I-X


     This aerno is" to inform you of our plans for  the  use of
IP A'a-, mobile incinerator.

     We have developed a .policy that will expedite the
issuance, of. RCRA permits to mobile treatment units.   This
policy is discussed in a recent memo from ny office entitled,
"RCSA Perrtits for Mobile Treatment fJnits and Multiple Sites
Using the Sarae Type of Equipment«"

  ''• The : first application of this policy is likely to be  in
relation to SPA's mobile incinerator.  The unit haa recently
begun"a"TSCA PCDiest burn."  The data collected during the
TSCA test burn will be used for the incinerator's first RCRA
permit at the Kin-Sue Superfund sits.

     John STcinner, Acting Director, Office of Solid Waste, is
preparing a model RCRA application and model permit for the
mobile incinerator for use at additional sites.   The  model will
specifically address the non site-specific permit conditions
that Will not change frosi :site to site.

     In addition to the model RCRA permit, Kenneth 3iglana,
Director,  Hazardous Response Support Division/ ia developing
a protocol to select f iture operating sites for the mobile
incinerator.  The criteria to be used for selecting subsequent
sites are as follows« 1. incinerability of the material; 2.
degree of hazard based on nearness to population, toxicity,
amount, etc.; 3. cost; 4. tiner 5. policy.  No single factor
except the first would, of itself, preclude the use of the
mobile incinerator at a particular site.  The purpose of the
protocol is to identify those sites having wastes amenable

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to incineration where the degree of hazard is significant.,
incineration is coat effective, and time and policy constraints
argue against waiting for the implementation of other tech-
nologies » .   .  ....  .-.•,......

     Finally, keep in mind that SPA's mobile incinerator must
be in possession of all permits required by the Federal, State,
and local governments at each site.  Each region must be careful
to coordinate these permits so that all the many details are
worked out in advance of the mobile incinerator's arrival.  You
must also coordinate the unit's use to ensura that operations
are conducted in a safe and legal manner.

     I have discussed this approach with Dr. John A. Todhunter,
Assistant Administrator for Pesticides and Toxic Substances,
ainca the model permit and selection protocol are also applicable
to the use of the nobile incinerator for PCS's.

     If you have any questions about the RCRA permit for the
mobile incinerator call Randy ChrisTnon at FTS 332-4535.
Questions about the site selection protocol should be directed
to Steve Droller- at FTS 340-674O.

cct  John A. Todhunter

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