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               DIRECTIVE NUMBER: 9501.01(82)

               TITLE: Guidance for Permitting of Hazardous Waste
                   Incinerators
               APPROVAL DATE: 7-9-S2

               EFFECTIVE DATE: 7'9-82

               ORIGINATING OFFICE: o«ice of solid waste

               m FINAL

               D DRAFT

                STATUS:
               REFERENCE (other documents):
(  ]  A- Pending OMB approval
[  ]  B- Pending AA-OSWER approval
[  ]  C- For review &/or comment
[  ]  D- In development or circulating

              headquarters
      WPP      ns WPP      n c
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PERMITTING PRIORITIES
                                                DOC:   9501.01(82)
Key Words:    Incineration

Regulations:  40 CFR 270.62

Subject:      Guidance for Permitting of Hazardous Waste Incinerators

Addressee:    Regional Hazardous Waste Division Directors

Originator:   John Skinner, Director, State Programs and Resource
              Recovery Division
Source Doc:

Date:

Summary:
#9501.01(82)

7-9-82
     This memorandum provides guidance and sets priorities which should be
followed in formulating Regional plans for permitting incinerators.  The fol-
lowing factors should be considered in ranking existing incinerators for calling
Part B applications:

     - Age of the facility;

     - Size;

     - Proximity to Population Centers;

     - Complexity of the waste mixtures incinerated; and

     - Prior history of poor operation or air pollution violations.

     Incinerator facilities  which also have storage capacity at the site should
include both activities in Part B applications.

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                                                                  950L.OL (3:
  Guidance for Permitting of Hazardous Waste Incinerators


  John Skinner, Director
  State Programs and Resource Recovery Division

  Regional Hazardous Waste Division Directors


     As you are aware* the amendment for hazardous waste inciner-
ators was published' in the Federal Register on June 24, and was
accompanied by a notice announcing that the suspension on calling
Part B's for incinerators has been lifted.  The "information burden"
clearance from OMB was also received recently (clearance 32050-0002),
The Agency is thus in a position to begin the permitting process for
these facilities.  This memorandum is intended to provide guidance
as to the priorities which should be followed in formulating
regional plans for permitting incinerators.

     In Rita Lavello's memorandum of June 18 'to the Regional Admin-
istrators various targets were set for the numbers of incinerator
permits to be issued in FY 33 and the numbers to be called in FY 83
for issuance in FY 84.  These targets were set for each region on  •
the basis of the permitting resources projected to be available.
Asauraing roughly a year's time free the time a permit is called to
when it is issued* adherence to the targets win necessitate calling
a substantial number of incinerator Part B's during the remainder
of this fiscal year, and during the first quarter of FY 33.  Inciner-
ators must be considered to be the first priority of the RCRA
permitting program in the cooing months.

     In establishing priorities for permitting of hazardous waste
incinerators we expect to use the same general approach we have
been using for storage facilities.  That is, new facilities win
be assigned the highest priority for permit issuance, and existing
facilities should be prioritized according to their potential for
causing environmental harm.  The following are factors which
should be considered in ranking existincr incinerators for calling
Part B applications:

            o Age of the facility
            o Siz^
            o Proximity to population centers
            o Complexity of the waste mixtures incinerated
            o Toxicity of the wastes incinerated
            o Prior history of poor operation or air pollution
              violations

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     It should be expected that most incinerator facilities win
also have some type of storage capability at the site.  In such
cases the Part B should be called for both the incinerator and the
storage facilities.  These storage facilities can be counted against
the permitting targets in Attachment 1 of Rita Lavelie'a June 13 .
nenbrandun, according to the specified substitution ratios.

   :  If there are any questions regarding the incinerator permitting
progran,  please contact Randy Chrisnon of my staff at 332-4535.

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