incine.txt

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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