The Agency recommends that permitting authorities evaluate the need for a site-specific risk assessment (SSRA) on a case-by-case basis. SSRAs are not anticipated to be necessary for every facility, but should be conducted for facilities where there is some reason to believe that operation in accordance with the MACT standards alone may not be protective of human health and the environment. If an SSRA demonstrates that operation in accordance with the MACT standards may not be protective of human health and the environment, permitting authorities may invoke the RCRA omnibus authority to require additional conditions as necessary. We consider this an appropriate course of action to ensure protection of human health and the environment under RCRA, given current limits to our scientific knowledge and risk assessment tools.
For more information, see http://www.epa.gov/epaoswer/hazwaste/combust/.
Does the Agency still expect each facility to conduct a site-specific risk assessment (SSRA) as part of the Hazardous Waste Combustion Emission Standards permitting process?
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