DSM Chemicals North America (DCNA) located in Augusta, Georgia combusts a hazardous waste fuel consisting of light organic by-products from Caprolactam manufacturing in two on-site boilers. DCNA initiated trial burn and risk assessment activities in response to Georgia Environmental Protection Division (EPD) directives in the late 1998 early 2000 timeframe. During the planning process, the U.S. Environmental Protection Agency (EPA) issued its Comparable Fuels Exclusion (CFE) regulations. U.S. EPA plans to issue revised CFE regulations in May 2007 to address issues related to some of the benchmark constituents contained in the 1998 regulation. DCNA's wastes met the rigorous CFE limits for 204 of the 206-benchmark constituents. However, it did not consistently meet the CFE limits for isobutyl alcohol and methyl ethyl ketone. DCNA evaluated these two hazardous constituents with respect to combustion properties and toxicity. Based on this review, DCNA believes that the risks associated with the presence of isobutyl alcohol and methyl ethyl ketone in the waste fuel is minimal.DCNA presented its data and analysis to the Georgia EPD and requested that it be exempt from risk testing requirements as part of the trial burn/CPT process. EPD has not yet acted upon the request, and with the Phase II MACT compliance date pending, DCNA is faced with several interesting questions. Will DCNA have to comply with the Phase II MACT before the revised CFE rule is promulgated? If so, will EPD continue to require risk testing? This paper will present the technical details of DCNA's arguments and provide a current update on DCNA's quest for comparable fuels exclusion.
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