Frequent Questions

Will hazardous waste combustors have both RCRA and CAA permits?

Yes, but not as regards their emission standards or operating conditions. For emissions and operating conditions, only one permit -- the Clean Air Act Title V permit -- will be required in the vast majority of cases. The only exception will be risk-based emissions limits and operating requirements that would be placed into the general facility permit under RCRA.
Facilities subject to the hazardous waste combustor MACT standards are by law required to have both RCRA permits and title V permits issued under the Clean Air Act. However, the two permits will address different aspects of the facility. 

In the final rule we chose to place the MACT emissions standards only in the Clean Air Act regulations at 40 CFR part 63 Subpart EEE, and rely on implementation through the air program, including operating permit programs developed under title V. Under this approach, MACT air emissions and related operating requirements are to be included in title V permits. RCRA permits will continue to be required for all other aspects of the combustion unit and the facility that are governed by RCRA (e.g., corrective action, general facility standards, other combustor-specific concerns such as materials handling, risk-based emissions limits and operating requirements, as appropriate, and other hazardous waste management units).

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