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 ------- 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'-". ' ------- 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 ------- 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. ------- -2- 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 ------- |