Permit Modification to Consolidate HWC MACT Rule Requirements in the Facility Title V Permit

摘要

While most affected facilities have implemented the HWC MACT requirements, many are still under dual regulatory oversight because of legacy RCRA permit requirements. This can lead to oversight by both the air and waste branches of US EPA or state government, and may leave a facility open to dual enforcement for duplicate and sometimes conflicting requirements. US EPA made it clear in the preamble to the 1999 HWC MACT Rule that it intended for air emission requirements for hazardous waste combustors and the corresponding operating requirements to be removed from the facility RCRA permit and instead be placed in the facility Title V air permit. This paper describes which requirements can be duplicative and should be eliminated from the RCRA permit once the facility is in compliance with the HWC MACT requirements. Strategies and examples are presented for successfully modifying the RCRA permit to remove duplicative requirements.