oEPA United States Environmental Protection Agency Office of Solid Waste and Emergency Response DIRECTIVE NUMBER: 0SWER #9503.50-1A(85) TITLE: RSI Memorandum for #b&D Permits .• V APPROVAL DATE: December 23, 1985 EFFECTIVE DATE: December 23, 1985 ORIGINATING OFFICE: Office of Solid Waste , Permits and State Programs Div. H FINAL Permits Branch D DRAFT STATUS: REFERENCE (other documents): OSWER OSWER OSWER VE DIRECTIVE DIRECTIVE D ------- I Untea S,dtr•s nviroi naI Pot ctt r genc 1 l erirn Dirtc:, Washington DC 20460 I r*’EPA OSWER Directive Initiation Request 503 .50-1 85), Originator Information ame of Contact Person Mail Code I Telephone Number Art Glazer 382—4692 Lead Office 0 OUST Approved for Review Date 0 OERR 0 OWPE Sig of Office Director ‘U - J 0 OS 0 &A•OSWER for Marcia iii __ 12T24-85 Title RSI Memorandum for RD+D Permits Summary of Directive Addresses four (4) policy questions on RD+D Permits: 1. disposition of treated waste 2. type of reporting information 3. permits for more than one RD+D unit 4. mobile RD+D units Type of Directive (Manual Policy Directive. Announcement. etci Status 0 Draft 0 New Final 0 Revision Policy memo Does this Directive Supersede Previous Directive(s Yes No Does It Supplement Previous DirectiveIs) Yes No If Yes to Either Question What Directive (number title) N/A Review Plan 0 AA OSWER 0 OUST 0 OECM 0 Other (Specify) O OERR 0 OWPE 0 OGC 0 osw 0 Regions 0 OPPE Request Meets OSWER Directives System Format 1 Lcad Office Directives Officer Date n Warren 12—24—85 Signatur’ ol OSWER Directives Officer Date EPA Form 1315-17(10 85( ------- f UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 PRO OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE DEC 2 3 SWER Directive //9503.50—1A(85) MEMORANDUM SUBJECT: RSI Memorandum for RD&D Permits FROM: Marcia Williams, Director Office of Solid Waste (WH—562) TO: Allyn M. Davis, Director Hazardous Waste Management Division (6H) I am responding to your memorandum of November 13, 1985, which requested policy guidance on the following issues pertaining to RD&D permits. 1. May an RD&D permittee who collects hazardous waste from a generator who does not have a TSD RCRA permit, return the unused or reduced part of the waste to that generator after experimentation ? Although the Agency may modify or waive permit application and permit issuance requirements to expedite the permitting of RD&D activities, there is no authority to modify or waive the requirements pertaining to shipping hazardous waste from an RD&D facility. Waste shipped from an RD&D facility must be manifested and go to a facility with a RCRA TSD permit. The RD&D facility could arrange for the generator’s transporter to pick up the unused and reduced portions of waste and take it to such a facility —— either the facility normally used by the generator or another facility. 2. How much reporting information should be required from permittees, and who should accept this information and in what form ? The reporting requirements are determined by what information is necessary for the Agency to ensure protection of human health and the environment. Because each RD&D permit is unique, the time—frame for reports and the level of detail required must be determined on a case-by-case basis. Applicants who intend to ultimately apply for a full RCRA permit must assure that their ------- —2— procedures meet routinely acceptable research practices, otherwise, the Agency may not be able to consider their results in issuing the permit. When Regions receive information on the results of experiments, this information should be submitted to Art Glazer, Program Manager, Permits Branch. This information will then be shared with other EPA Headquarters staff and ORD to assist the Agency in developing permit standards and analytical methods for new techniques and processes, and to assist the Agency’s research efforts. There is no set form for submittal of information, except that the information must be legible and the results clear. 3. If the permittee wants to test more than one machine, whether or not they are similar or modified, is a permit required for one set—up or is it for an entire experimental process? When a permittee is finished with one machine, he may want to decon- taminate and dispose or sell it, but then he wishes to continue similar experiments. Is this considered partial closure of an RD&D permit ? RD&D permits should cover all experimental processes to minimize the need for permit modifications. The permit applicant should identify, as best they can, all potential alterations or additions to their experimental equipment and this information should be covered in the permit. Given the uncertainty with RD&D activities, we see no problem with including conditions in the permit to cover activities that could potentially occur but do not actually happen. Decontaminating and disposing or selling one machine, when other equipment is still operating, should be considered partial closure of the RD&D facility. Since an RD&D facility is required to have a closure plan, the permit should address procedures to partially close. Permittees should be required to decontaminate equipment which will be sold. The procedures for decontamination should be specified in the permit. 4. Has any decision regarding mobile RD&D units been made ? Not at this time. As you may know, we have formed a workgroup to develop recommendations for expediting the permitting of mobile treatment units, including RD&D activities. We expect to issue a set of draft recommendations to the Regions for comment in a month or so. In the meantime if you have specific questions on permitting mobile units or wish to provide your thoughts on the issue please contact Art Glazer on 382—4692. ------- —3— If you have any further questions on permitting RD&D facilities please contact Art Glazer on 382—4692 cc: Peter Guerrero Bruce Weddle Art Glazer William Rhea Permit Section Chiefs Region I—V 1 VII—X ------- |