Successful RCRA Part B Permitting at a Facility underStringent Regulatory Scrutiny

摘要

A large-scale manufacturing facility that burns liquid hazardous wastes for energy has usedthese wastes since 1991 as a partial replacement for coal. Such burning is an efficient way todestroy many of the hazardous compounds in the liquids similar to hazardous wasteincineration, but for the purpose of energy recovery. However, storage and subsequent use oflarge quantities of hazardous waste derived fuel is much-debated and heavily-regulated by theState and Federal environmental agencies. This use has been criticized by local citizens andenvironmental and public health groups who argue that air pollution is often created by theburning of hazardous wastes. The facility has been the subject of notices of violation andheavy fines from the State agency, and has been required to implement extensiveimprovements. Additionally, an internal hazardous waste storage tank incident occurred in1997 at the facility. The State agency continues to assiduously scrutinize every activity at thisfacility. Upon obtaining the assignment to assist the facility with the 10-Year, RCRA Part BPermit Renewal application, Golder Associates discussed the status of the relationship betweenthe facility and both the regulators and the surrounding community. An accurate recognition ofthe status of these relationships helps create a strategy to obtain the cost-effective permitconditions and limit the strength or voracity of the opposition during the Permit-renewalprocess. The facility has had difficulty in addressing some of the regulatory demands,particularly because the captioned Permit was only one of many required. Therefore,developing and nurturing a positive working relationship with the State agency and the localcommunity became an essential part of the permitting process. This paper describes thesuccessful RCRA Part B Permit Renewal process through effective relationship-building at afacility that was under intense scrutiny by the regulators and faced community opposition.