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: •' - "..., 1 . V ORIGINATING OFFICE: jp FINAL D DRAFT STATUS: REFERENCE (other documents): osw A- Pending OMB approval B- Pending AA-OSWER approval C- For review &/or cement D- In development or circulating headquarters OSWER OSWER OSWER VE DIRECTIVE DIRECTIVE Dl ------- Unn«d SUIM 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 [ ] [ ] DIRECTIVE nc DIRECTIVE ------- 4\ — Q — Washington. DC 2O460 " OtrA OSWER Directive Initiation Request Robin Anderson Lead Office Q 0uST n OERR n OWPE &osw DAA-OSWER WS^te) - Branch T«S82-r I 1^ *^t jx f • * ^^^^^1 #9488. OO-Y"™" — H 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 Typ* of Directive fMinvit. Policy Dtrvctnr*. Announcement. ete.f • j- Pol icy Directive ! Status • DO*, wv*> ii"» wnwvu»« <*UV*I*OTM i i «*wu» wii«i,u«*i»(> | | i*» 1*1 "u uu«» ii 0UM««iii*iil nwwiM UHVCUWISK II. fM l_jl iUWll If "Yes" to Either Question. Whet Directive (number, title) ' •""^^-^•S Review Plan D AA-OSWER Q OUST O OERR D OWPE (E] OSW D Regions D OECM D Other (Specify) • :*§£ D~ -• '•'•'•-t*-* OGC -;-::f^ D OPPE >j^ This Request Meets OSWER Directives System Format ' - J •. ' Signature of Lead Office Directives Officer Owe _.:|*| ------- 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). ------- 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 ------- 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! ------- |