Hazardous Waste Combustor MACT Replacement Standards: Legal Issues

摘要

This paper will address potential legal issues affecting the HWC MACT Replacement Standards Rule. Specifically, the paper will analyze the legal constraints on the development of floor and beyond-the-floor MACT standards placed on EPA by CKRC v. EPA, 255 F. 3d 855 (D.C. Cir. 2001) ("CKRC"), the case that remanded the original HWC MACT rule. The paper will also address potential future challenges by various stakeholders to the methodologies currently under consideration by EPA.