Regional Offices

– Barre/Essex Jct./ Rutland/Springfield/St. Johnsbury AGENCY OF NATURAL RESOURCES

January 16, 2015 Mr. H. Curtis Spalding Regional Administrator EPA Region 1 (Mail Code ORA01

- 4) 5 Post Office Square, Suite 100 Boston, MA 02109

- 3912

Dear Mr. Spalding:

The State of Vermont hereby submits its application for authorization of certain revisions made to Vermont’s hazardous waste management program under the Resource Conservation & Recovery Act of 1976 (RCRA), as amended by the Hazardous & Solid Waste Amendments of 1984 (HSWA). The

app lication consists of this letter, a copy of the Vermont Hazardous Waste Management Regulations (VHWMR) that became effective on March 15, 2013 ( previously submitted to your staff) and an Attorney
General’s Statement.

Through this application, Vermont is se eking authorization for the VHWMR § 7

- 502(o)(8) permitting exemption

, along with the revision to the note following VHWMR § 7

- 502(o)(10)

, for on

- site treatment of
hazardous wastewater s by generators using wastewater evaporation unit s , and the VHWMR § 7

- 103 definition of “wastewater evaporation unit” . Following thorough review by this Division and the Office of Vermont’s Attorney General, it is our belief that these Vermont regulations are overall more stringent than corresponding federal RCRA regulations

, t hat Vermont ’s revised hazardous waste program meets the statutory criteria of RCRA § 3006

, and that Vermont can therefore be granted authorization to implement these provisions as part of its program in lieu of the federal program.

It should be noted that the VHWMR § 7

- 502(o)(8) permitting exemption is conditioned up on : 1) compliance with all applicable air emission control requirements under the Clean Air Act, the emission
thresholds established under the Vermont Air Pollution Control Regulations and, for large quantity generators, the air emission control requirements in 40 CFR part 265, subparts AA, BB and CC ; and 2) compliance with all applicable requirements specified throughout the VHWMR § 7

- 502(o) generator treatment exemp tion including the requirement to file notice in order for a company to operate under the exemption. I t is the practice of Vermont’s h azardous w aste management p rogram to review and approve all notifications submitted pursuant to VHWMR § 7

- 502(o) and, as a ppropriate, to impose additional standards as a condition of approval. Finally, Vermont does not allow hazardous waste evaporators to be operated State of Vermont Department of Environmental Conservation Waste Management & Prevention Division 1 National Life Drive

– Davis 1 Montpelier, VT 05620

- 3704 (802) 828

- 1138Regional Offices

– Barre/Essex Jct./ Rutland/Springfield/St. Johnsbury under the less stringent wastewater treatment unit exemption and

, as has been previously authorized, explicitl y prohibits the disposal of hazardous waste by evaporation.

The original copy of the Attorney General’s Statement is enclosed with the copy of this letter directed to Beth Deabay in the Office of Ecosystem Protection. I am confident that the continued coop eration between

our a gencies will lead to expeditious completion of this authorization process.

Sincerely,

Charles Schwer , Director Waste Management & Prevention Division

Cc: Beth Deabay