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Guidelines for In-Situ Burn Policy Approval in EPA Region 8

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This document outlines the current in-situ burn policy for EPA Region 8. It details the necessary checklist and information required for field operating support coordinators (FOSCs) to obtain approval from the Regional Response Team (RRT). Essential components include the date of request, volume of oil spilled, area description, wetland type, air quality approvals, and operation descriptions. Compliance with state, local, and federal regulations is crucial, including obtaining burning permits. The guidelines also emphasize the importance of consulting with trustees and adhering to appropriate removal actions.

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Guidelines for In-Situ Burn Policy Approval in EPA Region 8

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  1. EPA Region 8 In-situ Burn Policy

  2. Current Policy - per Region 8 RCP • Annex VII • Checklist • To be endorsed by FOSC and submitted for RRT approval • State and RP must also sign • Requires the following information

  3. Checklist Info Requirements • Date of Request • Volume Spilled • Volume and oil thickness to be burned • Description of area to be burned • Wetland type/dominant plant species • State/Local Air Quality Approval • Notifications made • Description of Operations

  4. NCP Authorities • No specific mention of in-situ burn • Mention of “on-site” burning in 300.310(c) w/r to disposal, not response tactics • Burning Agent • 300.5 – improves combustibility through chemical or physical means. • 300.310(a) allows use of chemical agents in accordance with 300.915 (Subpart J) • 300.910 – Area Committees shall address the desirability of using the various types of agents.

  5. NCP Authorities • 300.320(a)(2) • OSC shall “determine the course of action to be followed to ensure immediate and effective removal…of the discharge.” • 300.305 • trustees shall be consulted on appropriate removal action to be taken • Proper removal definition: • 300.322(a)(3)(ii) – removal efforts are in accordance with appropriate regulations.

  6. Other considerations • No blanket permit exemption or ARAR concept in Subpart D • Any state/local burning permits must be obtained prior to burn • Any federal/state/local laws governing open burns must be complied with • Non-attainment areas will present problems

  7. Suggested Revisions • Any burn requiring a burning agent is already covered by existing chemical countermeasure approval procedures in Annex VIII. • Change Annex VII to a true checklist for the OSCs – consider all potential permits or other regs that need to be met. • Be ready to facilitate after hours contacts w/ state and local air programs.

  8. Discussion Anyone? Bueller…Bueller?

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