Frequent Questions

After a source submits a Notification of Compliance documenting compliance with the MACT emission standards, will it ever have to conduct a RCRA trial burn?

Traditionally, a RCRA trial burn serves three primary functions: (1) demonstration of compliance with performance standards such as destruction and removal efficiency; (2) determination of operating conditions that assure the hazardous waste combustor can meet applicable performance standards on a continuing basis; and (3) collection of emissions data for incorporation into a SSRA that, subsequently, is used to establish risk-based permit conditions where necessary. The hazardous waste combustion MACT rule transfers the first two functions of a RCRA trial burn from the RCRA program to the CAA program (as part of the comprehensive performance test requirements), so clearly the traditional RCRA trial burn will no longer be applicable. The responsibility for collecting emissions data needed to perform an SSRA is not transferred to the CAA program, however, because SSRAs are exclusively a RCRA matter. Thus, a facility may still have to conduct some sort of "risk burn" to generate data for an SSRA.

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