Coordinated testing may not be possible for all hazardous waste combustors. Some sources may not be able to test under one set of conditions that addresses all data needs for both MACT implementation and SSRAs. SSRA emissions testing traditionally is performed under worst-case conditions, but may be obtained under normal testing conditions when necessary. As noted in the April 1996 proposed rulemaking, as well as in the final rule preamble, we generally anticipate sources will conduct MACT performance testing under conditions that are at the edge of the operating envelope or the worst-case to ensure operating flexibility. Regardless of which test conditions are used to collect SSRA emissions data, under the coordinated testing scenario, those conditions should be consistent with the MACT performance test to the extent possible.
Similarly, a source may experience difficulty integrating MACT performance testing with SSRA emissions testing due to conflicting goals in establishing enforceable operating parameters, i.e., a parameter cannot be maximized for purposes of the SSRA data collection while at the same time be properly maximized or minimized for purposes of performance testing. It is additionally important to ensure that the feed material used during the performance testing is appropriate for SSRA emissions testing. When collecting emissions data for an SSRA, testing with actual worst-case waste is preferred to ensure that the testing material is representative of the toxic, persistence and bioaccumulative characteristics of the waste that ultimately will be burned. However, even if multiple tests need to be performed to accomplish all of the objectives, it is still advantageous to conduct these tests in the same general time frame to minimize mobilization and sampling costs.
Finally, the timing of the required tests may cause difficulty for some sources wishing to use coordinated testing. As we discussed in the May 1997 NODA, if the timing of the SSRA data collection does not coincide with the MACT performance test requirement, the performance test should not be unduly delayed.
For more information, see http://www.epa.gov/epawaste/hazard/tsd/td/combustion.htm/.
What are some points to keep in mind in trying to determine if it is appropriate to coordinate MACT comprehensive performance tests with RCRA risk burns?
Have more questions? Submit a request