THE ALPHABET ENGINEER, FRIEND OR FOE?

摘要

Various regulations promulgated under the Resource Conservation and Recovery Act (RCRA) require that an independent, qualified, registered professional engineer-frequently abbreviated as IQRPE, but much more frequently and derisively referred to as the alphabet engineer-certify various construction and closure activities. While limited to a one-time inspection and certification at most RCRA-regulated facilities, the activities conducted to meet this requirement at various chemical agent incineration facilities and radioactive waste vitrification facilities have morphed into complex programs. This has included extending the programs to non-permitted systems at RCRA regulated facilities; multi-year programs involving numerous full-time on-site staff, and total project costs well into the multi-million dollar range. Furthermore, strict adherence to the U.S. EPA generic quality assurance project plan for hazardous waste combustion units has led to the use of a third party auditor during comprehensive performance tests. While not necessarily requiring the services of an IQRPE, this de facto requirement mirrors the RCRA requirements, even though there is no similar requirement in the Clean Air Act regulations. The original intent behind the RCRA IQRPE requirements, the normal application of these requirements, and the extent to which these activities have stretched are examined to answer one overall question: Is it all worth it? Through a series of interviews with facility managers, regulators, and engineers, this paper seeks to answer this question.