United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305W)
EPA530-R-97-057
PB98-108 129
November 1997
vvEPA
RCRA, Superfund & EPCRA
Hotline Training Module
Introduction to:
Hazardous Waste
Incinerators
(40 CFR Parts 264/265, Subpart O)
Updated July 1997
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DISCLAIMER
This document was developed by Booz-Allen & Hamilton Inc. under contract 68-WO-Q039 to EPA, It is
intended to be used as a training tool for Hotline specialists and does not represent a statement of EPA
policy.
The information in this document is not by any means a complete representation of EPA's regulations or
policies. This document is used only in the capacity of the Hotline training and is not used as a reference
tool on Hotline calls. The Hotline revises and updates this document as regulatory program areas change.
The information in this document may not necessarily reflect the current position of the Agency. This
document is not intended and cannot be relied upon to create any rights, substantive or procedural,
enforceable by any party in litigation with the United States.
RCRA, Superfund & EPCRA Hotline Phone Numbers:
National toll-free (outside of DC area) (800) 424-9346
Local number (within DC area) (703) 412-9810
National toll-free for the hearing impaired (TDD) (800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Time,
Monday through Friday, except for federal holidays.
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S0272-101
REPORT DOCUMENTATION
PAGE
° 1. REPORT NO.
0 EPA530-R-97-057
2.
4. Title and Subtitle
RCRA, SUPERFUND, AND EPCRA HOTLINE TRAINING NODULE: INTRODUCTION TO
HAZARDOUS WASTE INCINERATORS (40 CFR PARTS 264/265, SUBPARTS 0)
* 5. Report Date
0 NOVEMBER 1997
6.
7. Author(s)
0 8. Performing Organization Rept. No
9. Performing Organization Name and Address
U.S. EPA
OFFICE OF SOLID UASTE
401 N STREET, SW
WASHINGTON. DC 20460
10. ProJect/Task/Uork Unit No.
11. Contract(C) or Grant(G) No.
(C) 68-WO-0039
12. Sponsoring Organization Name and Address
BOOZ-ALLEN & HAMILTON
4330 EAST WEST HIGHWAY
BETHESOA, MARYLAND 20814
0 13. Type of Report & Period Covered
" TRAINING - UPDATED 7/97
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
ONE OF A SERIES OF MODULES DEVELOPED AS A TRAINING TOOL FOR HOTLINE SPECIALISTS. INTRODUCES THE CONCEPT OF BURNING
HAZARDOUS WASTES IN UNITS REGULATED UNDER RCRA AND OUTLINES THE REQUIREMENTS FOR ONE TYPE OF DEVICE - THE INCINERATOR.
EXPLAINS WHAT AN INCINERATOR IS AND HOW INCINERATORS ARE REGULATED. STATES THE CONDITIONS UNDER WHICH AN OWNER/OPERATOR
NAY BE EXENPT FROM SUBPART 0. DEFINES PRINCIPAL ORGANIC HAZARDOUS CONSTITUENT (POHC) AND DESCRIBES THE CRITERIA UNDER
WHICH A POHC IS SELECTED. DEFINES DESTRUCTION AND REMOVAL EFFICIENCY (DRE). DESCRIBES THE INTERACTION BETWEEN COM-
PLIANCE WITH PERFORMANCE STANDARDS AND COMPLIANCE WITH INCINERATOR OPERATING CONDITIONS ESTABLISHED IN THE PERMIT.
DEFINES AND EXPLAINS THE PURPOSE OF A "TRIAL BURN." THE INFORMATION IN THIS DOCUMENT IS NOT A COMPLETE REPRESENTATION
OF EPA'S REGULATIONS OR POLICIES, BUT IS AN INTRODUCTION USED FOR HOTLINE TRAINING PURPOSES.
17. Document Analysis a. Descriptors
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
RELEASE UNLIMITED
° 19. Security Class (This Report)" 21. No. of Pages
0 UNCLASSIFIED : ° 16
0 20. Security Class (TMs Page) ° 22. Price
8 UNCLASSIFIED " 0.00
(See ANSI-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
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HAZARDOUS WASTE INCINERATORS
CONTENTS
1. Introduction 1
2. Regulatory Summary 3
2.1 Overview of Combustion 3
2.2 Subpart O Applicability 4
2.3 Performance Standards , 5
2.4 Operating Conditions 6
2.5 Permit Phases 7
2.6 Waste Analysis 8
2.7 Monitoring and Inspections 9
2.8 Management of Residues... 9
2.9 Closure..... 9
2.10 Comparison of Permitted and Interim Status Incinerators 10
3. Regulatory Developments 13
4. Special Issues .'. 15
4.1 Omnibus Permitting Authority 15
4.2 Public Participation.. 15
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Hazardous Waste Incinerators - 1
1. INTRODUCTION
Incineration is a commonly employed technology used to destroy hazardous waste.
When Congress enacted the Resource Conservation and Recovery Act (RCRA) in
1976, it directed EPA to establish performance, design, and operating standards for all
hazardous waste treatment, storage, and disposal facilities (TSDFs). EPA
promulgated both general facility standards that apply to all TSDFs and
requirements for specific types of units (e.g., incinerators, landfills, and surface
impoundments) in 40 CFR Parts 264 and 265. The regulations under Parts 264 and
265, Subpart O, apply to owners and operators of facilities that incinerate hazardous
waste.
This training module introduces the concept of burning hazardous wastes in units
regulated under RCRA and outlines the requirements for one type of device — the
incinerator. When you have completed this module you will be able to explain
what an incinerator is, understand how incinerators are regulated, and apply the
appropriate regulations when assisting Hotline callers. Specifically, you will be able
to:
• State the conditions under which an owner/operator may be exempt from
Subpart O
* Define principal organic hazardous constituent (POHC) and describe the
criteria under which a POHC is selected
» Define destruction and removal efficiency (DRE)
• Describe the interaction between compliance with performance standards and
compliance with incinerator operating conditions established in a permit
• Understand the definition and purpose of a "trial burn."
Use this list of objectives to check your knowledge of this topic after you complete
the training session.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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2 - Hazardous Waste Incinerators
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
-------
Hazardous Waste Incinerators - 3
2. REGULATORY SUMMARY
Waste materials are burned in incinerators, boilers, and industrial furnaces for
various purposes. The purpose of the burning is directly related to the type of
device. Incinerators are used primarily for the destruction of hazardous
constituents; however, some energy or material recovery may occur. Boilers and
industrial furnaces, on the other hand, may burn wastes not only for destruction,
but also to achieve significant energy or materials recovery. The regulations that
apply to each activity vary with the type of waste that is burned, the type of
combustion device, and the purpose of the burning.
The Subpart O standards for hazardous waste incinerators primarily regulate the
emissions that result from the combustion process. Specifically, the regulations
restrict the emissions of orgaracs, hydrogen chloride (HC1), and particulate matter
(PM), as well as fugitive emissions. A very important aspect of the regulations is
that compliance with operating conditions specified in the permit is deemed to be
compliance with the limits for organics, HC1, and PM.
Incinerators in existence on May 19, 1980, were allowed to continue burning
hazardous waste if the units complied with the Part 265, Subpart O, interim status
standards. On November 8, 1989, however, interim status terminated for all
existing hazardous waste incinerators unless the owner/operator had submitted a
Part B permit application by November 8,1986 (§270.73(f)). Due to this deadline,
there are very few incinerators presently operating under interim status. This
module, therefore, focuses primarily on the requirements for permitted, rather than
interim status, incinerators. There is a comparison of the requirements for
permitted and interim status incinerators at the end of this module.
2.1 OVERVIEW OF COMBUSTION
To facilitate an understanding of the Subpart O regulations, it is important to be
familiar with the combustion process itself. Incineration is the controlled burning
of substances in an enclosed area. During a burn, wastes are fed into the
incinerator's combustion chamber. As the wastes are heated, they are converted
from solids and liquids into gases. These gases pass through the flame and are
heated further. Eventually, the gases become so hot that the organic compounds in
the gases break down into their constituent atoms. These atoms combine with
oxygen and form stable gases that are released to the atmosphere after passing
through air pollution control devices (APCDs).
For incineration to be an effective method for destroying wastes' hazardous
properties, combustion must be complete. Three critical factors ensure the
completeness of combustion in an incinerator: (1) the temperature in the
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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4 - Hazardous Waste Incinerators
combustion chamber, (2) the length of time wastes are maintained at high
temperatures, and (3) the turbulence, or degree of mixing, of the wastes and the air.
Operating conditions are specified in each incinerator permit to ensure that these
factors are present to promote complete combustion.
The stable gases produced by incineration are primarily carbon dioxide and water.
Depending on waste composition, however, small quantities of carbon monoxide,
nitrogen oxides, HC1, and other gases may form. Also, if combustion is not
complete compounds known as product of incomplete combustion (PICs) may be
emitted. RCRA regulations control the amount of HC1 released from the APCD.
Another by-product of the combustion process is ash. Ash is an inert solid material
composed primarily of carbon, salts, and metals. During combustion, most ash
collects at the bottom of the combustion chamber (bottom ash). When this ash is
removed from the combustion chamber, it may be considered hazardous waste via
the derived-from rule or because it exhibits a characteristic. Some ash, however, is
carried up with the gases as small particles, or particulate matter. These particles are
also collected in the APCD in accordance with RCRA-established limits.
As a hazardous waste management practice, incineration has several unique
attributes. First, if properly conducted, it permanently destroys toxic organic
compounds contained in hazardous waste by breaking their chemical bonds and
reverting them to their constituent elements, thereby reducing or removing their
toxicity. Second, incineration reduces the volume of hazardous waste by converting
solids and liquids to ash. Land disposal of ash, as opposed to untreated hazardous
waste, is therefore both safer and more efficient. Incineration, however, will not
destroy inorganic compounds, such as metals, present in hazardous waste. Residue
ash from incinerators is subject to applicable RCRA standards and may need to be
treated for metals or other nonorganic constituents prior to land disposal.
2.2 SUBPART O APPLICABILITY
The Subpart O standards apply to units that treat or destory hazardous waste and
which meet the definition of an incinerator. An incinerator is any enclosed device
that uses controlled flame combustion and does not meet the criteria for
classification as a boiler, sludge dryer, carbon regeneration unit, or industrial furnace
(§260.10). Typical incinerators include rotary kilns, liquid injectors, controlled air
incinerators, and fluidized bed incinerators. The definition of incinerator also
includes units that meet the definition of infrared incinerator or plasma arc
incinerator. An infrared incinerator is any enclosed device that uses electric-
powered resistance as a source of heat and which is not listed as an industrial
furnace. A plasma arc incinerator is any enclosed device using a high intensity
electrical discharge as a source of heat which is not listed as an industrial furnace.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Incinerators - 5
All devices classified as incinerators which burn hazardous waste must follow the
Subpart O standards, with the following exception. The Regional Administrator
must exempt an owner/opera tor applying for a permit from all of the incinerator
standards in Subpart O, except waste analysis and closure, if the hazardous waste fed
into an incinerator is considered low risk waste (§264.340(b)). The criteria for
defining a waste as low risk are:
* The waste is a hazardous waste listed in Part 261, Subpart D, or identified in
Subpart C only for ignitability, corrosivity, or both
or
« The waste is a hazardous waste listed in Part 261, Subpart D, or identified in
Subpart C only for reactivity, and will not be burned with other hazardous
wastes (this exemption does not apply to wastes that are reactive for
generating toxic gases when mixed with water (§261.23(a)(4), or cyanide or
sulfide gases (§261.23(a)(5))
and
• The waste contains none of the hazardous constituents listed in Appendix
VIII of Part 261.
2.3 PERFORMANCE STANDARDS
The Subpart O standards for hazardous waste incinerators set performance standards
which limit the quantity of gaseous emissions an incinerator may release.
Specifically, the regulations set limits on the emission of organics, HC1, and PM.
The following section outlines the requirements for each of these substances.
ORGANICS
To obtain a permit, an owner/opera tor must demonstrate that emission levels set
for various hazardous organic constituents are not exceeded. EPA's principle
measure of incinerator performance is its destruction and removal efficiency (DRE).
A 99.99 percent DRE means that one molecule of an organic compound is released
to the air for every 10,000 molecules entering the incinerator. A 99.9999 percent DRE
means that one molecule of an organic compound is released to the air for every
one million molecules entering the incinerator.
Since it would be impossible to monitor the DRE results for every organic
constituent contained in a waste, certain principal organic hazardous constituents
(POHCs) are selected for monitoring and are designated in the permit. POHCs are
selected based on high concentration in the waste feed and difficulty in burning
compared to other organic compounds. If the incinerator achieves the required DRE
for the selected POHCs, then it is presumed that the incinerator should achieve the
same or better DRE for organic compounds that are easier to incinerate.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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6 - Hazardous Waste Incinerators
RCRA performance standards require a minimum DRE of 99.99 percent for POHCs
designated in the permit and a minimum destruction and removal efficiency of
99,9999 percent for dioxin-bearing wastes F020, F021, F022, F023, F026, or F027
(§264.343(a)).
HYDROGEN CHLORIDE
HC1 is an acidic gas that forms when chlorinated organic compounds in hazardous
wastes are burned. An incinerator burning hazardous waste cannot emit more than
1.8 kg of HC1 per hour or more than 1 percent of the total HC1 in the stack gas prior
to entering any pollution control equipment/ whichever is larger (§264.343(b)).
PARTICULATE MATTER
PM is tiny particles of ash that are carried along with the combustion gases to the
incinerator's stack. The incinerator regulations control metal emissions through
the performance standard for particulates, since metals are often contained in or
attached to the particulate matter. A limit of 180 milligrams of particulate matter
per dry standard cubic meter of gas emitted through the stack has been established in
§264.343(e).
2.4 OPERATING CONDITIONS
The goal of setting operating conditions for hazardous waste incinerators is to
ensure compliance with the performance standards discussed in the previous
section (i.e., for organies, HC1, and PM). An incinerator permit specifies operating
conditions that have been shown in a trial burn to result in the incinerator meeting
these performance standards. A very important aspect of the regulations is that
compliance with the operating conditions specified in the permit is deemed to be
compliance with the performance standards for organies, HC1, and PM (§264.343(d)).
A RCRA permit for a hazardous waste incinerator sets operating conditions that
specify allowable ranges for, and requires continuous monitoring of, certain critical
parameters. Operation within these parameters ensures that combustion is
performed in the most protective manner and the performance standards are
achieved. These parameters, or operating conditions, include (264.345(b)):
* Maximum allowable carbon monoxide levels in stack emissions
• Allowable ranges for temperature
• Maximum waste feed rates
• Combustion gas velocity
* Limits on variations of system design and operating procedures.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Incinerators - 7
In addition, during the start up and shut down of an incinerator, hazardous waste
must not be fed into the unit unless it is operating within the conditions specified in
the permit (§264.345(c)). An incinerator must cease operations when changes in
waste feed, incinerator design, or operating conditions exceed limits designated in its
permit (§264.345(f)).
FUGITIVE EMISSIONS
Operating conditions are also set to control fugitive emissions. Fugitive emissions
are gases that escape from the combustion chamber (for example, gases may escape
through the opening where wastes are fed into the combustion chamber) and do not
pass through pollution control devices. Fugitive emission control methods are (1)
maintaining negative pressure in the combustion zone so that air will be pulled
into the APCD rather than escaping into the ambient air, or (2) totally sealing the
combustion chamber so that no emissions can escape to the environment
(§264.345(d)).
2.5 PERMIT PHASES
An owner/op era tor wishing to operate a new hazardous waste incinerator is
required to obtain a RCRA permit before construction of the unit commences.
The purpose of a hazardous waste incinerator permit is to allow a new hazardous
incinerator to establish conditions including, but not limited to, allowable waste
feeds and operating conditions that will ensure adequate protection of human health
and the environment. The incinerator permit covers four phases of operation: pre-
trial burn, trial burn, post-trial burn, and final operating conditions (§270.62).
PRE-TRIAL BURN
The pre-trial bum phase of the permit allows the incinerator to achieve a state of
operational readiness necessary to conduct the trial bum. The pre-trial burn permit
conditions are effective for the minimum time (not to exceed 720 hours) required to
bring the incinerator to a point of operational readiness to conduct a trial burn. This
phase is often referred to as the shakedown period.
TRIAL BURN
The trial burn can be seen as the "test drive" of the incinerator. It is the time when
the owner/operator will bring the unit up to operational readiness, monitor the key
operating conditions, and measure the emissions. The trial burn test conditions are
based on the operating conditions proposed by the permit applicant in the trial burn
plan submitted to EPA for evaluation. EPA establishes conditions in the permit
necessary to conduct an effective trial burn, meaning that the burn will be
The information in this .document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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8 - Hazardous Waste Incinerators
representational of the incinerator's intended day-to-day operation and will yield
meaningful data for analysis.
POST-TRIAL BURN
The post-trial burn period is the time for EPA to evaluate all of the data that was
recorded during the incinerators trial burn. To allow the operation of a hazardous
waste incinerator following the completion of the trial burn, EPA establishes permit
conditions sufficient to ensure that the unit will meet the incinerator performance
standards. This post-trial burn period is limited to the minimum time required to
complete the sampling, analysis, data computation of trial burn results, and the
submission of these results to EPA.
FINAL OPERATING CONDITIONS
After reviewing the results of the trial burn, EPA will modify the permit conditions
again, as necessary, to ensure that the operating conditions of the incinerator are
sufficient to ensure compliance with incinerator standards and protection of human
health and the environment. Owners/operators of incinerators must comply with
the final permit conditions for the duration of the permit, or until the permit is
modified.
DATA IN LIEU OF TRIAL BURN
While most incinerators must undergo a trial burn, it is possible for a facility to
submit extensive information in lieu of the trial burn (§270.19(c)). EPA believes that
most combustion units will need to conduct trial burns in order to develop
operating conditions that ensure compliance with the performance standards. Data
submitted in lieu of the trial burn, therefore, must originate from a unit with a
virtually identical design that will burn wastes under virtually identical conditions
(i.e., located at the same facility).
2.6 WASTE ANALYSIS
During operation, the owner/operator of an incinerator must conduct sufficient
waste analyses to verify that the waste feed is within the physical and chemical
composition limits specified in the permit. This analysis may include a
determination of a waste's heat value, viscosity, and content of hazardous
constituents, including POHCs. Waste analysis also comprises part of the trial burn
permit application (§264.341). EPA stresses the importance of proper waste analysis
to ensure compliance with emission limits.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Incinerators - 9
2.7 MONITORING AND INSPECTIONS
The specific monitoring and inspection requirements for incinerators are found in
§264.347, The owner/operator must perform, at a minimum, the following
functions while incinerating hazardous waste:
• Monitor the combustion temperature, waste feed rate, and indicator of
combustion gas velocity on a continuous basis
• Monitor carbon monoxide on a continuous basis at a point downstream of
the combustion zone and prior to release into the atmosphere
* Sample and analyze the waste and exhaust emissions upon request of the
Regional Administrator to verify that the operating requirements established
in the permit achieve the performance standards
• Conduct daily visual inspections of the incinerator and associated equipment
• Test the emergency waste feed cut-off system and associated alarms at least
weekly unless otherwise directed by the Regional Administrator — at a
minimum operational testing must be conducted monthly
• Place monitoring and inspection data in the operating log.
2.8 MANAGEMENT OF RESIDUES
If an incinerator burns a listed hazardous waste, the ash is also considered a listed
waste. The derived-from rule states that any solid waste generated from the
treatment, storage, or disposal of a listed hazardous waste, including any sludge,
spill residue, ash, emission control dust, or leachate, remains a hazardous waste
unless and until delisted (§261.3(c)(2)(i)). The owner/operator must also determine
whether the ash exhibits any characteristics of a hazardous waste.
If an incinerator burns waste that only exhibits a characteristic of a hazardous waste,
the owner/opera tor must determine whether the ash exhibits any characteristics.
Ash that exhibits a characteristic must be managed as a hazardous waste.
2.9 CLOSURE
At closure, the owner/opera tor must remove all hazardous waste and hazardous
residues from the incinerator equipment site. In addition, as throughout the
operating period, if the residue removed from the incinerator is a hazardous waste,
the owner or operator becomes a generator of hazardous waste and must manage
the residue in accordance with the applicable requirements of Parts 262 through 266.
(The module entitled Closure/Post-Closure provides more detailed information on
general hazardous waste unit closure standards.)
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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10 - Hazardous Waste Incinerators
2.10 COMPARISON OF PERMITTED AND INTERIM STATUS
INCINERATORS
The requirements for interim status incinerators are very similar to the already
discussed regulations for permitted units. The interim status regulations, however,
are designed to be self-implementing as the facilities are already in operation on the
effective date of the standards.
Figure 1 compares the requirements for permitted and interim status incinerators.
Figure 1
COMPARISON OF PARTS 264 AND 265
INCINERATOR REQUIREMENTS
PART 264, PERMITTED
PART 265, INTERIM STATUS
WASTE ANALYSIS
(§264.341)
Heating value
Viscosity
Appendix VIII
WASTE ANALYSIS
(§265.341)
Heating value
Waste halogen and sulfur content
Waste lead and mercury content
PERFORMANCE STANDARDS
(§264,343)
99.99% ORE for POHCs
99.9999%. ORE for POHCs for dioxin-
bearing wastes
1.8 kg /hr or 1% HC1 emissions
ISOmg/dscmPM
PERFORMANCE STANDARDS
(§§265.345 and 265.352)
Bum hazardous waste only during
steady state operations
99.9999% DRE and certification for
dioxin-bearing wastes
MONITORING & INSPECTIONS
(§264.347)
Combustion temperature
Waste feed rate
Combustion gas velocity
Carbon monoxide (CO)
Daily inspections
Weekly operations test
MONITORING «Sc INSPECTIONS
(§265.347)
Monitor emission control system
every 15 minutes
Daily inspection
Daily operations test
CLOSURE
(§264.351)
Remove all hazardous waste and
residues
CLOSURE
(§265.351)
Remove all hazardous waste and
residues
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Incinerators -11
In addition, the trial burn process for interim status incinerators is different than
that discussed previously in this module. As interim status units were already in
operation on the effective date of the regulations the facility would submit their trial
burn plan for approval without ceasing operation. Once this plan is approved, the
facility would conduct the trial burn test (or submit data in lieu of the trial burn) and
continue operating under interim status until the final permit is issued.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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12 - Hazardous Waste Incinerators
The information in this document is not by any means a complete representation or EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
-------
Hazardous Waste Incinerators -13
3. REGULATORY DEVELOPMENTS
On April 19, 1996, EPA published a proposed rule, called the "MACT" rule (for
maximum achievable control technology), under the joint authority of RCRA and
the Clean Air Act to upgrade the emission standards for hazardous waste
combustors (61 FR 17358). Specifically, this rule will affect incinerators, cement
kilns, and lightweight aggregate kilns. EPA plans to address boilers and other
industrial furnaces in a future rulemaking. This rule will fulfill EPA's commitment
to upgrade emissions standards as stated in its Strategy for Hazardous Waste
Minimization and Combustion.
The rule proposes emissions standards for dioxins, furans, mercury, cadmium, lead,
PM, HC1, chlorine, hydrocarbons and carbon monoxide, and several low-volatility
metals. It also proposes a new comparable fuels exclusion, and makes significant
changes to the existing combustion regulations. EPA intends to finalize this
proposal in two parts. The first part, expected in late 1997 or early 1998, is likely to
include the comparable fuels exemption and the permit modification amendments.
The second part, expected later in 1998, will finalize the remainder of the April 19,
1996, proposal.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotlir
: topic used for Hotline training purposes.
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14 - Hazardous Waste Incinerators
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
-------
Hazardous Waste Incinerators - 15
4. SPECIAL ISSUES
As EPA continues to revise the regulatory program for incinerators in order to
adequately protect human health and the environment, omnibus permitting
authority, site-specific risk assessments, and public participation issues have
received greater attention. The following discusses both issues in greater detail.
4.1 OMNIBUS PERMITTING AUTHORITY
The omnibus provision, added by Congress in the 1984 Hazardous and Solid Waste
Amendments, allows the Regional Administrator or state to incorporate into a
permit any provision deemed necessary to protect human health and the
environment. EPA codified this authority in §270.32(b)(2). Even if a facility submits
a permit application that is complete and technically adequate, if site-specific factors
at the facility suggest that typical permit conditions or performance standards will
not assure protection of human health and the environment, the Agency can
impose additional conditions to ensure such protection. Regulators can invoke the
omnibus authority whenever a facility owner/opera tor is seeking a new permit,
reissue of an expiring permit, or when existing permits are reopened for
modification (in appropriate circumstances).
EPA has recommended that permit writers invoke the omnibus provision to more
stringently control emissions for toxic metals, HC1, and products of incomplete
combustion (PICs), and to enhance public participation in the combustion
permitting process. Also, under the Strategy for Hazardous Waste Minimization
and Combustion. EPA has directed states and regions to conduct site-specific risk
assessments (incorporating direct and indirect exposures) using the omnibus
authority. These risk assessments can be conducted by either the implementing
agency or the facility (with agency oversight) during the permitting process.
4.2 PUBLIC PARTICIPATION
On December 11,1995, EPA published a final rule expanding the role of public
participation in the RCRA permitting process. This rule affects incinerators by
increasing the extent of public participation during the trial burn process (60 FR
63417). Specifically, the permitting agency is required to issue a public notice prior to
approving a facility's trial burn plan, and must announce the commencement and
completion dates for all trial burns. The proposed public participation rule (59 FR
28680; June 2,1994) also included some changes to the procedural requirements for
permitting interim status facilities. These changes, however, were not finalized
because of pending technical revisions to the hazardous waste combustor standards.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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16 - Hazardous Waste Incinerators
See the Regulatory Development section of this module for a discussion of this
proposed rule.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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