Yes. Phase I (cement kilns, incinerators and lightweight aggregate kilns) and Phase II (boilers and hydrochloric acid production furnaces) sources still need a RCRA permit to operate even after they submit a Notification of Compliance documenting compliance. However, the RCRA permit only needs to address basic hazardous waste management including: general facility standards; corrective action; other hazardous waste management units (such as storage units); other combustor-specific concerns such as materials handling; and, any risk-based combustor emission and operating requirements that are more stringent than the relevant MACT standard. (The inapplicable RCRA combustion performance standards of 40 CFR Parts 264, 265, 266, and 270 can be removed from the RCRA permit via a streamlined permit modification procedure.) The Clean Air Act title V permit will focus on the operation of the combustion unit including the MACT air emission standards and related operating parameters.
For more information, visit the hazardous waste combustion web page.