Interim Status Facilities

To qualify for interim status, the facility must have been in existence on or before August 21, 1991, and must have submitted a Part A permit application by this date. If the facility already had a permit for another activity, owners/operators must have submitted a permit modification under interim status. If the facility was already operating under interim status for another activity, then it was required to comply with the requirements for changes under interim status.

Until U.S. EPA calls in the facility's Part B permit application, where precise permit conditions will be established through a trial burn, owners/operators of interim status BIFs must ensure compliance with emission standards by showing certification of precompliance and certification of compliance. As the deadlines for these certifications have already passed, all interim status BIFs, except for possible extenuating circumstances, should be in the compliance stage.

23.2.1.5.1 Certification of Precompliance

In order to certify precompliance, the owner/operator established operating conditions under which the BIF would meet emissions standards. These operating conditions must have included feed rates of hazardous waste, metals, chlorine and chloride, and ash. The operating conditions should have been documented in a certification of precompliance, submitted by August 21, 1991. Prior to submitting this certification of compliance, interim status owners/operators were not allowed to feed hazardous waste with a heating value of <5000 Btu/lb into a boiler or industrial furnace (5).5 By requiring burners to demonstrate that a waste's heating value is greater than or equal to 5000 Btu/lb, the Agency was able to ensure a high enough temperature and long enough residence time in the boiler to destroy hazardous constituents at a rate that is protective of human health and the environment.

23.2.1.5.2 Certification of Compliance

Owners/operators that were required to submit a certification of precompliance must have conducted compliance testing to verify the operating conditions on or before August 21, 1992. Within 90 days after compliance testing, the owner/operator must have submitted a certification of compliance containing operating conditions based on the results of the testing. The certification included a description of any changes that had taken place since precompliance, as well as the test data and results of quality assurance and quality control work. Throughout the remainder of interim status, the BIF is required to comply with the operating limits contained in this certification.

As mentioned above, interim status BIFs must be operated much in the same way as those facilities with permits. As with permitted BIFs, owners/operators of interim status BIFs must comply with all applicable TSDF regulations in Part 265. In addition, because interim status facilities have not yet conducted trial burns to ensure compliance with the standards, U.S. EPA has placed some restrictions on their use and what types of hazardous waste these facilities may burn. These restrictions are discussed below.

23.2.1.5.3 Prohibition on Burning Dioxin-Containing Waste

A BIF operating under interim status may not burn dioxin-containing hazardous wastes or any material derived from one of these wastes.

23.2.1.5.4 Special Requirements for Interim Status Furnaces

Interim status furnaces are required to comply with all of the performance standards with the exception of the DRE. In addition, U.S. EPA established special interim status requirements for industrial furnaces to ensure adequate combustion of hazardous waste until more stringent, permitted conditions could be established through completion of the facility's trial burn. These conditions include minimum temperatures, assurance of adequate oxygen, and continuous hydrocarbon monitoring.

These requirements do not apply to a furnace that burns hazardous waste solely as an ingredient. The requirements also do not apply to any furnace that feeds the hazardous waste into the hot end of the furnace, where products are normally discharged and fuels are normally fired.

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