oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
# 9488.00-1A
TLE: Dioxin Trial Burns for Purposes of Certification
or a FCFA Permit
APPROVAL DATE: 5/21/86
EFFECTIVE DATE: 5/21/86
ORIGINATING OFFICE: osw
Q FINAL
D DRAFT
STATUS:
I 1
( 1
t ]
I 1
REFERENCE (other document*):
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or content
D- In development or circulating
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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Unmd SHIM
Environment*) Protection
Agency
Office ol
Sond Waste and
Emergency Response
DIRECTIVE NUMBER:
# 9488.00-1A
TITLE: Dioxin Trial Burns for Purposes of Certification
or a RCRA Permit v
APPROVAL DATE: 5/21/86
EFFECTIVE DATE: 5/21/86
ORIGINATING OFFICE: osw
E3 FINAL
D DRAFT
STATUS:
[ ] A- Pending OMB approval
[ ] B- Pending AA-OSWER approval
[ ] C- For review i/or coment
[ ] D- In development or circulating
REFERENCE (other documents): headquart.rs
ffi DIRECTIVE DIRECTIVE
^^— " <.£j"S'-". '
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v> EPA
. . . ..„ .
Wasmngton. DC 20460
OSWER Directive Initiation Request
in;-;r:rr.
4*9488.00 -
Originator Information
Name of Contact Person
Mail Code -
WH-563
Branch
Te lep none"N u mber
382-4498
Lead Office
D OERH
US OSW
D OUST
LJ OWPE
D AA-OSWER
Approved for Review
Signature of Office Director
Date
Title
Dioxin Trial Burns for Purposes of Certification or a RCRA Permit
Summary of Directive
The dioxin listing regulations (50 FR 1978-2006, January 14, 1985) require
facilities to either be certified under interim status or to have a RCRA permit to
treat dioxin waste before such material may be treated. The purpose of this memo-
randum is to confirm that certification is not required prior to a trial burn
involving dioxin listed waste;-
Key Words:
Dioxin,.Trial Burn, Incineration
Type of Directive (Mtnuil. Policy Directive. Announcement, etc.I
.
Regulatory Interpretation
' Status
I
O Drrt
03 Final
I a
Revision
3o*s this Directive Supersede Previous Oirective(s;> [ j Yes
f "Yes" to Either Question, What Directive (number, title/
No Does It Supplement Previous Directive)*)' |] Yes (_J No
Review Plan
D AA-OSWER C OUST
D OERR D OWPE
• LJ Regions
OSW
D OECM
13 OGC
D OPPE
D
Other /Specify)
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
I Date
Signature of OSWER Directives Officer
I Date
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OSWER Directive #9488. 00-1 A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
MAY -
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Dioxin Trial Burns for Purposes of Certification or
a RCRA Permit
FROM: JZ*-: Bruce*WedBle7 Director
Permits and State Program Division
TO: Hazardous Waste Branch Chiefs, Regions I-X
The dioxin listing regulations (50 FR 1978-2006,
January 14, 1985) require facilities to either be certified
under interim status or to have a RCRA permit to treat dioxin
waste before such waste may be treated. The facility must
provide evidence (e.g., trial burn data) that the treatment
unit is capable of meeting performance standards under
Subpart 0 of Part 264 to support the certification or the
permit. We have received questions regarding the need for
certification prior to a trial burn involving dioxin waste*
The purpose of this memorandum is to confirm in writing that
certification is not required in order for an applicant to
conduct a trial burn.
We recognize that this issue has been confusing because
the regulations are silent on the need for certification
prior to a trial burn involving dioxin listed waste. The
intent of the regulations, however, is to allow this activity
without prior certification because the trial burn process
itself provides adequate safeguards to public health and the
environment. The regulations for both new and interim
status incinerators require the applicant to submit infor-
mation on the design of the unit and the trial burn plan in
accordance with SS270.19 and 270.62 and the Director must be
satisfied that the unit is likely to meet the $264 Subpart 0
performance standards before the trial burn may occur.
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The„preamb le to the regulations indicates a preference
for the use of actual dioxin listed waste for the trial
burn. Specifically, the preamble states that the trial
burn may involve "...spiking the [dioxin] waste with a
compound that is more difficult to incinerate ...it is
possible to use a trial burn to predict compliance with
the 6-9's [destruction and removal efficiency] ORE..."
(see 50 FR 1991). The advantage of using actual dioxin
waste for the trial burn is that it provides the most
accurate test of the treatment unit performance. This is
particularly true in those situations where the waste
material has a very complex matrix which is difficult to
duplicate.
Although certification is not required prior to the
dioxin trial burn, there may be cases where it is advisable
to perform a pre-trial burn using a synthetic material to
demonstrate the potential performance of the treatment unit.
A case in point is when the public has a high concern regarding
a trial burn involving dioxin waste and information resulting
from a trial burn using a synthetic waste material would
ease the public's concern. Another case is where the per-
formance of the treatment device is in doubt and supporting
evidence using a waste material for which the 6-9's ORE is
not a regulatory reguirement would provide the necessary
assurance. In no case, however, is certification required
in order for the trial burn involving the dioxin waste to
occur.
Questions on this policy may be addressed to Robin Anderson
of my staff at 382-4498 or Jim Cummings of the Dioxin Management
Task Force at 382-4686.
cc: Peter Guerrero
Art Glazer
Jim Cummings
Robin Anderson
Steve Silverman
Incinerator Permit Writer's Workgroup
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