United Sutu
Eftvtronnwmel Protection
Off ic* of
Solid Waste tnd
Emergency Response
DIRECTIVE NUMBER: 0SWER #9503.50-1A(85)
TITLE: RSI Memorandum for KD&D Permits
APPROVAL DATE: December 23, 1985
EFFECTIVE DATE: December 23, 1985
ORIGINATING OFFICE: Office of Solid Waste
, Permits and State Programs Div.
B FINAL Permits Branch
r
D DRAFT
STATUS:
REFERENCE (other documents):
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J
Ljr i S u s .‘&P c . I ‘rr. .-
Wasriington DC 2O4 O L 503 50—1A(85)
EPA OSWER Directive Initiation Request I ’
Or nator r.formator
Name of Contact Person Mail Code Teleprione Number
Art Glazer WH—563 382—4692
Lead Office OUST Approved for Review
SgaiVr of Office D,rector / — • Date
U OERR owes c
OSW A.A OSWER Warren for Marcia lliams . L. .. 12T2485
Tifle
RSI Memorandum for RD+D Permits
Summary of Directi e
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-1-D units
Type of Di’ect.ve (Manual Policy Directive. Announcement etci Status
E Draft New
Final Fevi ion
Policy memo
Does tt,iS Directive Supersede Previous Yes No Does Supplement Previous Y 5
\c
Ii Yes to Either Question What Directive (number title)
N/A
Review Plan
A.A.OSWER 0 OUST 0 OECM 0 OtnerSpecify/
0 OERR 0 OWPE 0 OGC
0 OSW 0 Regions 0
Ti’s Request Meets OSWER Directives System Format
Sgrati . reo4 1 Lead Office Directives Ottic r Date
c L A ’a -
Warren 12—24—85
Sg ature of OSWER Directives Officer Date
EPA Form 1315.17(10 85)
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T UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_____ WASHINGTON, D.C. 20460
pgØ
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
DEC 2 3 QSWER Directive 1!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
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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.
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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, VII—X
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