oEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9489.01(82)

TITLE: Status of ODD Munitions Deactivatlon Facilities



APPROVAL DATE:  11-23-82

EFFECTIVE DATE:  11-23-82
               ORIGINATING OFFICE:

               C FINAL

               D DRAFT

                 STATUS:
               Office of Solid Waste
[  ]
                           [ 1
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PARTS 264 AND 265  SUBPART P - THERMAL TREATMENT
                                                DOC:  9489.01(82)
Key Words:

Regulations:

Subject:

Addressee:


Originator:



Source Doc:

Date:

Summary:
Federal Facilities

40 CFR 265.382, 270.72

Status of DOD Munitions Deactivation Facilities'

Thomas W. Devine, Air and Waste Management Division,
Region IV

John P. Lehman, Director, Hazardous Industrial Waste Division;
and Bruce R. Weddle, Acting Director, State Programs and Resource
Recovery Division

#9487.01(82)

11-23-82
     Existing munitions deactivation furnaces will be considered thermal treat-
ment units, regulated under §265.382.  EPA cannot permit these units as there
are no comparable Part 264 standards.  These facilities may be able to expand
during interim status.  New munitions deactivation furnaces, however, will be
regulated and permitted as incinerators.

     DOD facilities which have interim status for open burning can expand to
build munitions deactivation furnaces under interim status subject to the
expansion cost limitations for interim status.

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MEMORANDUM

SUtsJtCT:  States of DUD Munitions  Oeagtivation facilities.
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     This is in response  to your memorandum  of  June 21,  1982,  in
which you discuss the regulatory status  of the  Department of
Defense (DOD) munitions deactivation  facilities.   You, request
headquarter 's support of  your approach to these facilities.

     The conclusion you reach is two-pronyed.   Existing  nunitions
deactivation furnaces will be considered thermal  treatment units,
regulated under §265.382.  Although we cannot permit these units,
as there are no comparable Part 264 standards,  these facilities
may oe able to expand during inter in  status.  New munitions
aeactivation furnaces, however, will  be  regulated and permitted
as incinerators.
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     tfour conclision to allow D
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     We also support your decision to require any new facilities
thac uoD ouilds co modify cheir designs to meet the Part 2$4
incinerator standards.

     I apologize for the aelay in responding to your .first
memorandum.  Apparently, an earlier response to your questions
was lost.  It you need any further information, please call
Deborah Wolpe of my staff at FTS
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