Frequent Questions

How will EPA be assured that a combustion device is not operated in a manner which causes higher and/or different product of incomplete combustion emissions which could cause a significant risk to human health and the environment?

After a facility has successfully conducted emissions testing under the MACT requirements, operating limits will be established to assure that the combustion device continues to operate in a safe manner. These operating limits directly control emissions of organic hazardous air pollutants that can be PICs. These operating limits are reported to the regulatory Agency in a Notification of Compliance and are enforceable. The Notification of Compliance is ultimately incorporated into a title V permit issued under the Clean Air Act. 

During emissions testing, facilities are generally required to operate their combustion device under worst case conditions in order to establish an operating range (or envelope). Facilities are required to operate within the range that they successfully establish during their emissions test, including a range that ensures that 99.99% of organics are destroyed. Some facilities may also be required to conduct a risk burn under RCRA authority in order to generate additional data on PICs for a site specific risk assessment (SSRA). If an SSRA indicates a need for additional permit conditions in order to ensure that, in that particular instance, additional controls are warranted in order to ensure sufficient protectiveness, those conditions may be imposed and enforced under RCRA's omnibus authority.

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