Frequent Questions

Can my permitting authority issue a combined RCRA and CAA permit for my facility?

Yes, it is possible. Some states can issue multi-media permits, including both RCRA and CAA requirements, under joint program authority. These permits must cite the appropriate authority (either CAA or RCRA) for each condition and be signed by the appropriate officials for each program. Each permit condition is then enforced under its respective authority. While these types of permits have been issued successfully, it should be noted that the possibility exists for enforcement under both RCRA and CAA statutes.
 
For more information, see the section entitled "3. What Considerations Were Made for Ease of Implementation?" in the preamble to the final rule at 64 FR 52976, September 30, 1999. See also http://www.epa.gov/epawaste/hazard/tsd/td/combust/toolkit/index.htm.

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