October 2024 Temporary Units Compendium ¦ „ ¦ ¦ _,«¦¦¦ EPA 530-F-24-017 Supporting Memos, Regulations, and Policies Temporary Units (Title 40 of the Code of Federal Regulations Section 264.553): For temporary tanks and container storage areas used to treat or store hazardous remediation wastes during remedial activities required under 40 CFR Section 264.101 or Resource Conservation and Recovery Act Section 3008(h), or at a permitted facility that is not subject to 40 CFR Section 264.101, the Regional Administrator may designate a unit at the facility, as a temporary unit. A temporary unit must be located within the contiguous property under the control of the owner/operator where the wastes to be managed in the temporary unit originated. For temporary units, the Regional Administrator may replace the design, operating, or closure standard applicable to these units with alternative requirements with protect human health and the environment. Document Category RCRA Online/Resource Resource Title Document Date Notes Memo RO 13214 OECM Comments on Corrective Action Rule August 23, 1988 Summarizes agreement between Sylvia Lowrance (Director, Office of Solid Waste) and Edward Reich (Deputy Associate Enforcement Counsel) concerning Temporary Unit preamble language. "We will also develop additional preamble language explaining the legal rationale behind temporary units..." States that TUs will be limited to managing wastes that originate within the facility boundary. Memo RO 13461 Use of Proposed Subpart S Corrective Action Rule as Guidance Pending Promulgation of the Final Rule March 27, 1991 Memo from Lisa Friedman (Associate General Counsel, Solid Waste and Emergency Response Division) to Regional Counsel RCRA Branch Chiefs concerning which portions of the proposed Subpart S rule could be implemented immediately on a case-by- case basis without further rulemaking. 1 SEPA United States Environmental Protection Agency ------- Document Category RCRA Online/Resource Resource Title Document Date Notes "Several of the proposed regulations governing the management of wastes generated during a corrective action require changes in the existing regulations and thus may not legally be used as guidance until those changes have been made final and effective. Such proposed changes include the provisions allowing for waiver of applicable closure requirements, reduced requirements for 'temporary units', and any use of the CAMU concept other than to allow designation of an area of broad contamination as a single unit for purposes of determining what RCRA management standards apply." Memo RO 11665 Environmental Growth Initiative February 10, 1992 Memo from Don Clay (Assistant Administrator) to William Reilly (Administrator) concerning Clay's proposal to restructure and streamline OSWER's regulatory programs. RCRA Reform initiative and Temporary Units: "We will finalized [sic] a proposal to allow temporary storage and treatment at cleanup sites to be exempted from more stringent LDR treatment standards that were designed with permanent disposal in mind. Imposition of LDR treatment standards on temporary units has 2 ------- Document Category RCRA Online/Resource Resource Title Document Date Notes discouraged voluntary cleanups and added significant extra costs to mandatory cleanups." Federal Register 58 FR 8683 Corrective Action Management Units and Temporary Units; Corrective Action Provisions; Final Rule February 16, 1993 This rule "finalizes provisions for corrective action management units (CAMUs) and temporary units under subpart S of 40 CFR part 264. Both of these units function solely to manage wastes that are generated at a RCRA facility for the purpose of implementing remedial actions required at the facility (i.e., remediation wastes, as defined in this rule." Letter RO 11746 Response from Sylvia Lowrance (Director, Office of Solid Waste) to Doug MacMillan (Institute of Chemical Waste Management) regarding the impact ofCAMU regs on management of "as-generated" hazardous wastes. May 4, 1993 "As 1 understand from your letter, and from subsequent discussions with my staff, your primary concern is that as- generated containerized hazardous wastes being stored at a facility could be considered remediation wastes, and therefore could be managed at an area or a facility that has been designated as a CAMU, with the effect that those wastes would no longer be subject to the RCRA land disposal requirements, or to minimum technology requirements... We are willing to consider adding a clarification to the regulation that would specifically exclude management of as- generated wastes in CAMUs, as well as in temporary units. 1 would welcome further discussions with you and your organization on this matter." 3 ------- Document Category RCRA Online/Resource Resource Title Document Date Notes Memo RO 14291 Management of Remediation Waste Under RCRA October 14, 1998 Consolidation of existing guidance on RCRA regulations and policies that most often affect remediation waste management, including Temporary Units. Memo EC-G-2002-097 Summary Chart of October 14, 1998 Memorandum, "Management of Remediation Waste Under RCRA." October 15, 1998 "Corrective Action Temporary Units are a type of RCRA unit specifically for [remediation waste]. TUs may meet modified design, operating and closure standards instead of the RCRA standards that usually apply to tanks and containers. Prior state or EPA approval and specification of unit standards required. Operation limited to one year with opportunity for one one-year extension." Federal Register Notice 63 FR 65939 Hazardous Remediation Waste Management Requirements (HWIR-media) November 30, 1998 "In today's final rule, the Agency has revised the definition of CAMU, as well as the CAMU and temporary unit regulations themselves. This revision clarifies the Agency's interpretation of these provisions and accommodates EPA's new interpretation, promulgated today, that remediation-only facilities are not subject to the facility-wide corrective action requirement under RCRA section 3004(u)." Memo https://www.epa.gov/sites/default/files/2016- 04/documents/02camutu.pdf Corrective Action Management Units (CAMUs) and Corrective Action Temporary Units (TUs) -40 page compendium of memos/FR notices N/A Compilation of various guidance documents / memos / Federal Register notices pertaining to Temporary Units (some are specific to CAMUs and are labeled as such in the documents) 4 ------- |