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
   C- For review &/or cement
   D- In development or circulating
           headquarters
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           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

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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
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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
Typ* of Directive fMinvit. Policy Dtrvctnr*. Announcement. ete.f
                          •

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Review Plan
D AA-OSWER Q OUST
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This Request Meets OSWER Directives System Format ' - J •. '
Signature of Lead Office Directives Officer
Owe _.:|*|

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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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