Texas Natural Resource Conservation Commission Austin Texas Memorandum From: Lawrence E. Pewitt, P.E., Director, Permits Program To: All Regional Offices Date: November 12, 1992 Subject: Portable Incinerators Burning Process and Used Motor Oil Filters During the past several months, a number of companies have contacted the Texas Air Control Board Office in Austin to discuss the permitting requirements for small portable incinerators, generally 100-200 pound-per-hour capacity, which would be used to burn filters at plant sites around the state. The majority of companies indicated the primary waste would be used process filters and used motor oil filters at gas and oil plants across the state. The companies envision moving the incinerator from site to site, burning the waste on site and leaving the ash for disposal by the company which hired their service. The ash from the incinerator will be classified as a "special waste" under the Texas Natural Resource Conservation Commission's Municipal Solid Waste Management Regulation, as defined in memo from Mr. C. Wayne Lee, Manager, Engineering/Evaluation and Planning, municipal Solid Waste Division. The disposal of the ash will require written authorization from the Municipal Solid Waste Division. Tests for total metals and leachable metals using the Toxicity Characteristic Leaching Procedure (TCLP) will have to be submitted to the Municipal Solid Waste Division to obtain authority to dispose of the ash. The waste stream to be processed by these units has been classified by the Texas Water Commission as a special waste and Standard Exemption No. 2 would not be applicable. Therefore, these incinerators should be permitted. Each unit would initially be permitted at a specific site and the special provisions of the permit would define the relocation requirements. The input of the regional offices will be essential in developing permit provisions for relocation and regional office approval of each new site. Please provide our office with any information or comments the region may have regarding this matter. cc: Mr. C. Wayne Lee, Manager, Engineering/Evaluation and Planning, Municipal Solid Waste Division, Texas Natural Resource Conservation Commission Ms. Debra Barber, Deputy Director, TACB Field Operations