There is no change in policy or approach on this issue. The need for an SSRA will be assessed on a case-by-case basis by EPA regional and State RCRA permit officials. These officials have asked for flexibility to determine whether some sites present low enough risks, based on a variety of indices, that a full risk assessment need not be performed as part of the permitting process. Our current policy allows for this type of flexibility. To help permit officials assess the need for an SSRA, we provided a list of qualitative guiding factors in the final rule for them to take into consideration.
For more information, see http://www.epa.gov/epaoswer/hazwaste/combust/.
How should a RCRA permitting authority determine whether an SSRA is necessary for any given facility?
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