Regulatory Approach to Making Operational Changes under the CAA and RCRA

摘要

For those energy recovery facilities that utilize hazardous waste fuel, there are often changes in the operations that become necessary over time. The ability from a regulatory perspective to make those changes is tightly linked to both the CAA and RCRA regulations, can be somewhat complex, and can take considerable time and cost to implement. This paper lays out the potential range of activities necessary to evaluate and implement the changes from a regulatory point of view. Areas addressed include Hazardous Waste Combustor Maximum Achievable Control Technology (HWC MACT) testing and plans, and Title V and RCRA permitting. Also included is a discussion about addressing risk assessment issues, including ensuring that the risk assessment results remain valid for operations after the operational changes have been implemented. As the regulations have evolved from BIF to the HWC MACT, the regulatory elements necessary to address operational changes have continued to evolve. The change from having emissions limits and operating parameters under RCRA shifting to the CAA has been an important step in defining the RCRA/CAA division of authority. Additionally, ongoing operational changes must be addressed with respect to the overlying RCRA and CAA requirements.