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The Civil Engineering Handbook, Second Edition
or for boilers and industrial furnaces (BIF): hydrogen chloride/chlorine gas emissions within acceptable
risk-based emission limits (known as Tiers I, II, III, or adjusted Tier I); metals emission limits within
risk-based limits; products of incomplete combustion (PIC) emissions within risk-based limits; and a
limit of 180 mg of particulate matter per dry standard cubic meter (mg/dscm) (0.0015 gr/scf) of gas
emitted through the stack.
The metal emission limits are set for three categories of metals: volatile, semivolatile, and nonvolatile
metals. The categories are based on whether the particular metal is likely to be a vapor, solid, or both in
the incinerator stack. Mercury is the only volatile metal that is regulated. The semivolatile metals, like
antimony and lead, partially volatilize in the stack. They can be emitted as a metal vapor and as a
particulate. The nonvolatile metals, such as chromium, do not volatilize to a measurable extent in the
stack. They are released to the environment as particulates.
These standards were set based on the levels of performance that have been measured for properly
operated, well-designed combustion units. Although for most wastes the 99.99 DRE is considered to be
protective of human health and the environment, a more stringent standard of 99.9999 DRE was set for
wastes containing dioxins or furans because of the U.S. EPA’s and the public’s concern about these
particularly toxic chemicals.
Permits are developed by determining the likely operating conditions for a facility, while meeting all
applicable standards and other conditions the permitting authority may feel are necessary to protect
human health and the environment. These operating conditions are specified in the permit as the only
conditions under which the facility can legally operate. The permit also specifies the maximum rate at
which different types of wastes may be combusted, combustion unit operating parameters, control device
parameters, maintenance and inspection procedures, training requirements, and other factors that affect
the operation of the combustion unit. The permit similarly sets conditions for all other hazardous waste
storage, treatment, or disposal units to be operated at the facility.
Recognizing that it would take the U.S. EPA and authorized states many years to process all permit
applications, Congress allowed hazardous waste facilities to operate without a permit under what is
referred to as interim status. Owners and operators of interim status combustion units must demonstrate
that the unit meets all applicable performance standards and emission limits by submitting data collected
during a trial burn.
Once the trial burn is completed, the data are submitted to the permitting agency and reviewed as
part of the trial burn report. It is within the permitting agency’s discretion to reject the trial burn data
if they are insufficient or inadequate to evaluate the unit’s performance. Once the data are considered
acceptable, permit conditions are developed based on the results of the successful trial burn.
Since, approximately 1996, the U.S. EPA has been developing a different permitting approach for new
combustion units. As of early 2001, this approach is substantially in place. Under this new approach, a
RCRA permit must be obtained before construction of a new hazardous waste combustion unit begins.
The RCRA permit for a new combustion unit covers four phases of operation: (1) a “shake- down period,”
when the newly constructed combustion unit is brought to normal operating conditions in preparation
for the trial burn; (2) the trial burn period, when burns are conducted so that performance can be tested
over a range of conditions; (3) the period after the trial burn (this period may last several months), when
data from the trial burn are evaluated, and the facility may operate under conditions specified by the
permitting agency; and (4) the final operating period, which continues throughout the life of the permit.
The permitting agency specifies operating conditions for all four phases based on a technical evaluation
of combustion unit design, the information contained in the permit application and trial burn plan, and
results for trial burns for other combustion units. These operating conditions are set so that the com-
bustion units theoretically will meet all performance standards at all times. Results from the trial burn
are used to verify the adequacy of these conditions. If trial burn results fail to verify that performance
standards can be met under some operating conditions, the permit will be modified for the final operating
phase so that the combustion unit cannot operate under these conditions.
The process for review of a permit application may vary somewhat depending on the permitting
agency. The basic process, however, consists of five steps: