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Subpart X Permit Conditions
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| Subpart X Permit Conditions |
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Description: Permit writing for a Subpart X unit should be similar
to that for any other hazardous waste management
unit. The general process and format are the same. |
| Standard Permit Conditions |
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Description: The permit writer should carefully check the original
Part A application and verify with the owner/
operator the identity of the person/company that is
legally responsible for operating the regulated units
that the permit is issued for, and the legal owner of
the property. |
| Waste Minimization |
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Description: Waste minimization is one of the most important
components of a Subpart X permit, especially for
OB/OD units. Permit conditions should address
how the facility will be working on new or existing
demilitarization technologies, and working towards
developing better methods of OB/OD or
replacement technologies. |
| Land Disposal Restriction (LDR) Requirements |
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Description: LDR conditions are applicable to Subpart X Units
because the Land Disposal Regulations apply
treatment technologies to munitions and other
wastes. |
| Toxicity Characteristics (TC) |
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Description: The permit writer must evaluate whether TC wastes
will be managed in the unit. However, caution is
urged since some waste types might have multiple
listings. OB/OD units may require TC permit
conditions to address metals and explosives, and
mechanical units may require TC permit conditions
to address solvents and metals. |
| Air Emission Requirements (Subpart AA, BB and CC) |
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Description: Air emission conditions should only be included if
they are applicable to the unit design. Subpart X
units need to be considered from a total emissions or
mass-balance standpoint when evaluating controls. |
| Corrective Action |
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Description: Corrective Action conditions should address any
past contamination from the operation of the
Subpart X Unit(s). Ground water monitoring of
Subpart X areas should be covered under the
ground water (40 CFR Part 264, Subpart F)
provisions that are applicable to the unit(s). |
| Compliance with Other Laws |
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Description: The permit writer must perform an evaluation for
compliance with other laws prior to permitting the
facility. This includes evaluations for the Endangered
Species Act, Wild and Scenic Rivers Act, and
Historical Preservation Act. |
| Unit-Specific Conditions |
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Description: Specific unit conditions need to be written for the
Subpart X unit. |
| Schedule of Compliance |
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Description: The compliance schedule should be sorted by
regulatory issues as they are addressed in main text
of the permit. Enforceable language should include
specific due dates and conditions that request
information “Within __ Days of …”. Time deadlines
are always on the Permittee, not the Agency. |
