IMPACT OF HWC MACT ON RCRA COMBUSTION SOURCES IN THE STATE OF LOUISIANA

摘要

The purpose of this paper is to discuss the impact of the Hazardous Waste Combustor Maximum Achievable Control Technology (HWC MACT) Rule on the Resource Conservation and Recovery Act (RCRA) combustion sources in the state of Louisiana. HWC MACT affects thirty-one sources in Louisiana, making Louisiana the second most impacted state in the country. HWC MACT introduces three types of changes to regulation of the affected combustion sources. First, HWC MACT introduces certain requirements not imposed under the RCRA program. Second, certain requirements previously regulated under the RCRA program are now regulated under the CAA. Lastly, some requirements imposed by the RCRA program are not included in the HWC MACT Rule. The HWC MACT Rule has had a profound effect on the regulation of RCRA combustion sources. HWC MACT adds to and tightens emission rate limits prescribed under RCRA. Under RCRA, all operating limits were monitored either instantaneously or as hourly rolling averages. HWC MACT adds twelve hour rolling averages and yearly limits. Additionally, emission limits and operating requirements previously outlined in the RCRA Permit are now regulated via the Title V Permit. Test results for a third of the incinerators in the state of Louisiana are currently under review. Through a study of these results, it can be concluded that some of the changes brought forth by the HWC MACT Rule are more restrictive while some of the changes are more lax.