Operating Requirements

Operating requirements for BIFs are determined on a site-specific basis, and serve as day-to-day requirements that the facility must follow in order to ensure compliance with the emission standards set by the regulations. The BIF regulations do not specify precise operating requirements that all units must follow; rather, units must establish operating standards that allow them to meet the emission standards in the regulations. In addition to the general operating standards discussed below, the BIF may establish operating standards for feed rate, combustion temperature, flue gas temperature, contaminant concentrations in stack gases, and other conditions as determined necessary.

23.2.1.3.1 Management Prior to Burning

The management of hazardous waste prior to burning in a BIF is subject to all applicable RCRA regulations. Generators of hazardous waste are required to comply with Part 262 regulations, while transporters of hazardous waste are subject to Part 263. In addition, any storage prior to burning is subject to the hazardous waste storage regulations in Parts 264/2654 and the permitting requirements of Part 270 unless the unit is a small quantity burner. This management requirement includes storage activities conducted by the burner as well as any intermediaries.

23.2.1.3.2 TSDF Standards

Permitted BIFs are subject to all of the general TSDF standards including general operating standards, preparedness and prevention, contingency plan, use of the manifest system, closure and financial assurance, and corrective action.

23.2.1.3.3 Hazardous Waste Analysis

The BIF owner/operator must perform a waste analysis27 to identify the type and quantity of hazardous constituents that may be reasonably expected to be found in the waste. The facility must provide an explanation for any constituents not included in the analysis. In addition to the initial analysis, the owner/operator must conduct periodic sampling and analysis to ensure that the hazardous waste is within the limits of the facility's permit.

23.2.1.3.4 Fugitive Emissions

The BIF must be operated such that emissions escaping from the combustion chamber are minimized. The owner/operator has two options from which to choose21:

1. Maintain a negative pressure in the combustion zone so that air is pulled into the unit rather than escaping into the atmosphere.

2. Totally seal the combustion chamber so that no emissions can escape to the environment.

23.2.1.3.5 Direct Transfer

Facilities that transfer hazardous waste directly from a transport vehicle (e.g., a tanker truck) to the BIF without first storing the waste must comply with special requirements.5 Generally, direct transfer operations must be managed in a manner similar to that required by the regulations for hazardous waste storage tanks and containers. In addition, the direct transfer equipment must have a secondary containment system, the owner/operator must visually inspect the operation at least once every hour, and the facility must keep records of these inspections.

23.2.1.3.6 General Standards

In addition to the standards described above, the BIF owner/operator must fulfill requirements for establishing an automatic waste feed cutoff system. The facility must also conduct inspection and monitoring, maintain certain records, and close in accordance with given regulations.

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