Standardized
Permit
Rule
Conference
Call
Discussion
on
extending
to
off­
site
February
10,
2003
Attendees
Name
Organization
Name
Organization
Joan
Sowinski
Colorado
Jan
Palumbo
EPA
Region
10
Doug
Outlaw
Florida
Sonya
Sasseville
EPA/
OSW
Bill
Mundy
Georgia
Dale
Ruhter
EPA/
OSW
Bob
Bullock
Idaho
David
Eberly
EPA/
OSW
Rob
Morrison
Rich
Nussbaum
Missouri
Mark
Eads
EPA/
OSW
Paul
Counterman
New
York
Jeff
Gaines
EPA/
OSW
Jill
Pafford
North
Carolina
Jim
Thompson
EPA/
OECA
Anne
Dobbs
Texas
Lynn
Holloway
EPA/
OECA
Allan
Moore
Utah
Laurel
Celeste
EPA/
OGC
Barbara
Simcoe
ASTSWMO
We
introduced
the
topic
for
discussion
by
providing
some
basic
background
of
the
proposed
rule,
and
briefly
described
some
of
the
comments
received
in
relation
to
the
question
of
extending
the
rule
to
offsite
facilities
(
facilities
that
manage
wastes
generated
off­
site).

Then
posed
the
question
to
the
states
about
how
they
would
feel
about
extending
to
off­
site
if
there
were
a
requirement
to
submit
a
waste
analysis
plan
and
closure
plan
with
the
application,
or
whether
there
were
additional
requirements
beyond
those
mentioned
that
would
make
extending
to
off­
site
more
palatable.

NY:
Paul
Counterman
began
by
offering
that
they
would
be
very
much
opposed
to
extending
the
rule
to
off­
site,
noting
numerous
problems
encountered
with
existing
facilities
that
would
be
worse
if
under
a
standardized
permit.
He
indicated
problems
with
recycling
facilities,
facilities
with
improper
waste
storage.
Paul
indicated
that
there
are
problems
with
compliance
at
existing
permitted
facilities,
and
how
much
worse
matters
could
be
under
a
standardized
permit.
If
permitted
facilities
don't
always
comply,
how
could
standardized
permit
holders
be
trusted
to
comply?
Not
so
much
a
matter
of
trust,
but
that
a
system
of
less
accountability
(
with
a
standardized
permit)
would
not
be
in
everyone's
interest.
Also
expressed
concern
over
public
opinion
with
regard
to
not
being
able
to
have
a
full
review
of
permit
application
information
before
permit
issuance.
GA:
Bill
Mundy
agreed
with
NY
NC:
Jill
Pafford
agreed
that
it
would
not
be
a
good
idea
to
extend
to
off­
sites.
In
NC,
permitted
commercial
operations
often
involve
many
different
types
of
wastes
stored/
treated
in
complicated
arrangements.
These
would
not
be
suited
for
a
standardized
permit.

CO:
Joan
Sowinski
agreed
with
the
other
participants.
Her
experience
was
that
many
permitted
facilities
were
often
complex
and
had
environmental
problems.
comments.

MO:
Rob
Morrison
concurred.
His
experience
was
that
their
various
facilities
needed
closer
scrutiny
(
than
a
standardized
permit
would
provide)
in
order
to
assure
the
public
that
the
operations
were
being
conducted
safely.
Such
operations
included
hazardous
waste
fuel
blending,
waste
explosives
treatment,
and
storage,
materials
handling.
Most
fires,
for
instance,
occur
with
inappropriate
materials
handling,
when
incompatible
wastes
are
mixed,
or
other
safety
measures
are
not
followed.
In
practice,
Rob
felt
the
standardized
permit
(
if
included
off­
site)
would
complicate
inspections,
putting
an
increased
burden
on
inspection
and
enforcement
resources.

Region
10:
Jan
Palumbo
felt
the
overall
regular
permitting
process
was
an
"
educational"
process
to
end
that
the
Region
/
State
could
work
more
effectively
with
the
facility,
and
that
the
facility
understood
the
permitting
requirements
better.

FL:
Doug
Outlaw
expressed
agreement
with
what
the
other
States
said.

UT:
Allan
Moore
expressed
agreement
with
what
the
other
States
said.

CO:
Joan
expressed
agreement.

Question
raised
whether
extending
to
off­
site
would
be
a
step
in
the
right
direction?

ID:
Bob
Bullock
felt
the
rule
should
be
limited
to
facilities
managing
wastes
generated
on
site.
Extending
to
off­
site
would
add
too
much
ambiguity
to
the
permitting
process.

We
asked
whether
anything
would
help
­
is
there
anything
we
could
add
to
the
rule
to
make
extending
to
off­
site
acceptable?

GA:
Bill
said
that
having
a
requirement
for
a
"
complete
letter
of
credit,"
payable
to
the
state
that
would
fund
any
cleanup
or
closure
activities
that
could
possibly
be
expected
to
occur.

We
asked
whether
limiting
the
off­
sites
to
"
captives
only,"
those
being
facilities
under
the
same
corporate
entity,
would
be
acceptable,
and
under
what
conditions?

NY:
Paul
said
that
he'd
be
ok
with
captives
if
we
required
up
front
a
waste
analysis
plan,
a
closure
plan,
and
provided
a
very
tight
definition
of
what
it
meant
to
be
of
the
same
corporate
entity.

CO:
Joan
asked
what
about
federal
facilities
­
the
army
for
instance?
Concern
about
the
variety
of
wastes
federal
facilities
manage,
similar
to
concerns
about
commercial
facilities
where
complex
handling
processes,
poor
handling
practices.
Also,
concern
of
extending
to
off­
sites
because
of
the
requirement
that
federal
facilities
be
treated
the
same
as
other
offsite
facilities.

ID:
Bob
did
not
think
we
should
extend
to
captives.
Also,
concern
for
federal
facilities.
Not
just
limited
to
waste
analysis
plan
issues,
but
operational
concerns
such
as
having
proper
fire
suppression
systems,
and
meeting
other
safety
requirements.
Setting
operational
parameters
are
critical
to
a
safe
permit,
and
there
is
a
need
to
have
more
information
up
front
prior
to
setting
permit
conditions.
The
standardized
permit
would
not
provide
for
the
necessary
level
of
detail
and
review.

GA:
Bill
did
not
think
we
should
extend
to
captives.

FL:
Doug
indicated
they'd
be
ok
with
captives
if
facilities
were
truly
in
the
same
company,
i.
e.,
the
facilities
are
in
the
type
of
business
such
that
each
facility
would
be
familiar
with
the
waste
stream
being
generated
and
managed.

NC:
Jill
indicated
that
they'd
be
ok
with
captives
on
a
case­
by­
case
basis.

We
asked
about
extending
the
rule
to
facilities
that
engage
in
energy
recovery,
recycling
operations?

NY:
Paul
indicated
that
NY
did
not
have
any
facilities
engaged
solely
in
recycling.
Recycling
operations
often
are
integrated
into
various
other
facility
operations.

We
asked
NY
whether
there
was
any
incentive
for
companies
to
sector
out
their
recycling
operations.
Paul
felt
that
no,
there
wasn't
any
incentive
for
this
to
occur.

NC:
Jill
said
that
extending
to
recycling
would
not
be
good.
They've
had
problems
in
the
past
with
recycling
operations,
so
State
law
now
requires
a
RCRA
permit
for
recycling
operations
(
full
part
B­
type
permit).
Problems
included
bad
handling
practices
and
how
they
review
the
permit
application
to
get
a
good
handle
on
facility
operations.

FL:
Doug
said
their
situation
is
similar
to
NY.
If
the
recycling
was
real
and
not
sham,
then
not
such
a
bad
thing,
but
what
other
waste
constituents
are
going
"
along
for
the
ride"?

GA:
Bill
said
that
the
solvent
reclaimers
have
"
left
a
mess
behind,"
and
asked
others
if
they
had
problems
with
the
reclaimers.
Doug
(
FL)
and
Paul
(
NY)
said
yes.
Paul
mentioned
contamination
problems
left
behind
by
precious
metals
recyclers
who've
claimed
the
precious
metals
exemption.

We
thanked
the
participants
for
taking
the
time
to
participate
in
the
call.
