Frequent Questions

Why have a streamlined permit modification procedure for Phase 1 HWC MACT standards?

When developing the Phase 1 HWC MACT standards, we recognized that many owners or operators might need to make changes to their combustion equipment or processes in order to comply with the anticipated emission limits. For example, a facility may have to add an electrostatic precipitator to its incineration system to comply with the MACT particulate matter standard. For facilities operating under RCRA permits, these changes must be incorporated into the permit before they may be put in place at the facility. We were concerned that the RCRA permit modification procedures, as a practical matter, would not allow facility owners or operators to complete the modifications in time to meet the Phase 1 HWC MACT compliance time frames. We did not want the RCRA permit modification process to hinder a facility's ability to comply with the new emission standards, so we promulgated a streamlined procedure to address this concern (Appendix I to 270.42 section L.9). 

For more information regarding the streamlined permit modification procedure, see the RCRA Streamlined Permit Modification Fact Sheet  (PDF, 368 KB).

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