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Document Record Detail



Full Document:
Title:SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
RCRA Online Number:13221
Date:09/02/1988
To:Directors, Regions 1-10
From:Lowrance
Organization of Recipient:EPA
Description: Aboveground bolted flange joints that are inspected daily do not need secondary containment. Joints where waste may contact the thread must meet the secondary containment requirement for tank ancillary equipment. A trench below tank waste lines may qualify as secondary containment if it is sized to contain a release and if the trench is dry so that leaks can be detected. Discusses the status of new tank systems at facilities permitted between 7/14/86 and 1/12/87. To meet the definition of a boiler, the combustion chamber and energy recovery section must be of integral design. A unit with a “post-combustion” chamber between the combustion and energy recovery sections is not a boiler. A unit with a combustion section connected to an energy recovery unit by a duct and a control system is not a boiler. A unit with innovative insulation installation does not qualify as boiler under a variance petition if the insulation does not provide significantly better performance. The determination of boiler efficiency should be conducted under controlled conditions following a method specified by the American Society of Mechanical Engineers. Thermal relief vents can be used in the design of a new incinerator, but a permit should require backup systems to minimize their use. Addresses the application of the minimum technology requirements (3004(o)) to the vertical and lateral expansions of surface impoundments and landfills. The minimum technology waiver petition was granted due to alternate design and operational factors. The 3004(o)(2) waiver petition that would prevent the migration of contaminated groundwater beyond the waste management area (e.g. surface impoundment) is inadequate because it does not prevent all groundwater contamination. Incinerators may be eligible for research, development, and demonstration (RDD) permits. Provides guidance on the duration of Research, Development, and Demonstration (RDD) permits beyond a calendar year and criteria for renewing RDD permits. Discusses the applicability of the new tank system regulations in authorized v. unauthorized states. Includes guidance on the selection of principal organic hazardous constituent (POHCs) and the use of surrogate v. actual wastes during the incinerator trial burn. The actual waste can be spiked during the trial burn to raise principal organic hazardous constituent levels. Addresses the sampling frequency during a trial burn. The mass feed rate of a principal organic hazardous constituent (POHC) input used for destruction and removal efficiency (DRE) calculations must equal mass feed rate in the wastestream only. When sampling for particulates and semi-volatile POHCs during an incinerator trial burn, two separate Modified Method 5 (MM5) trains should be used. Only one confirmatory sampling event is necessary to trigger compliance monitoring. Discusses the disposal of purged water generated during groundwater sampling and analysis. An owner of a landfill or surface impoundment submitting a no migration waiver petition must use a worst-case soil permeability factor in groundwater modeling. The constituent concentration, retardation factors, and constituent half-life must be evaluated when developing a model for a no migration waiver petition for a surface impoundment or a landfill (3004(o)(2)). The owner of a site with a complex hydrogeology should use a 2 or 3-dimensional model to support a no migration demonstration. Provides criteria for evaluating landfill composite bottom liner equivalency. Addresses the evaluation of a final cover slope using a soil loss equation. EPA recommends the use of glass vessels when performing compatibility testing on a high-density polyethylene (HDPE) liner. Scarifying and remolding do not meet the minimum technological requirements for a landfill secondary soil liner. A contingency plan must designate a sufficient number of emergency coordinators to provide 24-hour and vacation coverage. The federal regulations require a compressive strength test for stabilized wastes (going to a landfill) that pass the paint filter test only if true chemical stabilization has not occurred.
Regulatory Citation(s) : 261.3, 260.10, 264.55, 264.90, 264.98, 264.99, 264.190, 264.193, 264.221, 264.301, 264.314, 264.340, 264.342, 265.190, 266.100, 270.16, 270.16(g), 270.19, 270.65 EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Hazardous Waste; Permits and Permitting; Tanks; TSDFs; Boilers; Burning; Combustion of Hazardous Waste; Hazardous Waste Recycling; Industrial Furnaces; Treatment; Variances; Permits and Permitting; Test Methods; Petitions; Surface Impoundments
Approximate Number of Hardcopy Pages:22
EPA Publication Number:NA
RPPC Number (if applicable): 9523.00-17
Official OSW Policy:Yes

 

 
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