October 2024

Temporary Units Compendium

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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.

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SEPA

United States
Environmental Protection
Agency


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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

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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."

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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)

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