oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: #9488.0o-2
TITLE:
Permitting Incineratprs
APPROVAL DATE:
EFFECTIVE DATE:
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ORIGINATING OFFICE:
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STATUS:
REFERENCE (other documents):
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A- Pending OMB approval
B- Pending AA-OSWER approval
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D- In development or circulating
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Environmental Protection
Agency
Off >c« of
Solid WMI« and
Emergency Recponte
&EPA
DIRECTIVE NUMBER: #9488.0o-2
TITLE:
Permitting Incinerators
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE: OSW
jp FINAL
D DRAFT
STATUS:
I ]
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review i/or coanent
D- In development or circulating
REFERENCE (other documents): headquarters
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DIRECTIVE
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DIRECTIVE
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4\ — Q — Washington. DC 2O460 "
OtrA OSWER Directive Initiation Request
Robin Anderson
Lead Office Q 0uST
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#9488. OO-Y"™"
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Approved for Review |
Signature of Office Director
Daie ' I
Permitting of Incinerators
Summary of Directive
This memorandum provides guidance on whether a RCRA permit for a hazardous waste
incinerator under interim status could be issued prior to the performance of the
trial burn. Although the regulations are silent on this issue, the intent of
the regulation is to require performance of the trial burn and receipt of the
data prior to permit issuance so that permit conditions may be set based on
actual operating data, rather than on theoretical conditions.
Key Words:
Incinerator, Permit, Trial Burn
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Signature of Lead Office Directives Officer
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460 Q^JJ pQjjQy D|RECT|VE NO.
9488 .00-2
111 Iftmt OFFICE OF
JUI I U MOD SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Permitting of Incinerators
FROM: Bruce Weddle, Director
Permits and State Programs Division (WH-563)
TO: Sam Becker, Chief
Hazardous Waste Compliance Branch, Region VI (6H-C)
I am writing in response to your memorandum of May 7, 1986,
in which you requested guidance on whether a RCRA permit for a
hazardous waste incinerator under interim status could be issued
prior to the performance of the trial burn. Although the regula-
tions are silent on this issue, the intent of the regulation is
to require performance of the the trial burn and receipt of
trial burn data prior to permit issuance for existing incinerators.
This issue was discussed with Henry Onsgard of your staff on
May 22, 1986, and this memorandum confirms in writing that Agency
policy is to require performance of the trial burn prior to
permit issuance.
As you know, the regulations require the Director to set
permit conditions such that the incinerator will comply with the
performance standards of Part 264 bubpart 0 (§270.62). Results
of the trial burn (or data in lieu of the trial burn) are the
critical piece of information in setting these conditions. Estab-
lishing permit conditions this way provides for maximum protection
of human health and the environment since the permit conditions
will be based on actual performance information, rather than
theoretical conditions. Except in rare cases, we do not foresee
why existing incinerator facilities would not be able to provide
this information since these facilities have had ample time to
obtain performance data and have known that such information
will be necessary to obtain a permit.
One case when it may be appropriate to permit an interim
status incinerator prior to performance of the trial burn
is where the unit requires major modifications. In this
case, the permit should be issued as though the unit were a
new incinerator. The permit must specify the allowed operating
conditions in accordance with the appropriate portions of
S$ 270.62 and 264.344 (c).
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OSWER POLICy DIRECTIVE NO.
9488.00-2 ~?
-2-
Please contact Robin Anderson (FTS 382-4498) of my staff if
you have further questions on this issue.
cc: Art Glazer
Robin Anderson
Hazardous Waste Branch Chiefs, Regions I-V, VII-X
Incinerator Permit Writer's Workgroup
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
INTER FIRST TWO BUILDING. 1201 ELM STREET
DALLAS. TEXAS 75270
USWEB ?'jJW UIKECFIVt NO.
May 7, 1986
9488.00^2
MEMORANDUM
SUBJECT: Permitting of Incinerators
FROM: Sam Beckervchef
Hazardous Waste Compliance Branch (6H-C)
TO: Bruce R. Weddle, Director
Permits and State Programs Division (WH-563)
During our recent Regional Implementation File Review, our staffs
discussed the matter of issuing a RCRA permit to an existing incinerator
prior to conducting a trial burn. I would appreciate receiving the formal
Headquarters position concerning this matter.
Thank you for your cooperation. Please contact Henry Onsgard at
(FTS) 729-9719 for more information.
IGi'.. ...X •>-!-•
^r,% y.rirn 2404 Pl.'L
?' Street, S.Vv.
ilHK*>T. DO R04B!
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