Permit Phases

An owner/operator wishing to operate a new hazardous waste incinerator is required to obtain an RCRA permit before construction of the unit commences.

The purpose of a hazardous waste incinerator permit is to allow a new hazardous incinerator to establish conditions including, but not limited to, allowable waste feeds and operating conditions that will ensure adequate protection of human health and the environment. The incinerator permit covers four phases of operation: pretrial burn, trial burn, posttrial burn, and final operating conditions.

23.1.2.4.1 Pretrial Bum

The pretrial burn phase of the permit allows the incinerator to achieve a state of operational readiness necessary to conduct the trial burn. The pretrial burn permit conditions are effective for the minimum time (not to exceed 720 h) required to bring the incinerator to a point of operational readiness to conduct a trial burn. This phase is often referred to as the shakedown period.

23.1.2.4.2 Trial Burn

The trial burn can be seen as the "test drive" of the incinerator. It is the time when the owner/ operator will bring the unit up to operational readiness, monitor the key operating conditions, and measure the emissions. The trial burn test conditions are based on the operating conditions proposed by the permit applicant in the trial burn plan submitted to U.S. EPA for evaluation. U.S. EPA establishes conditions in the permit necessary to conduct an effective trial burn, meaning that the burn will be representational of the incinerator's intended day-to-day operation and will yield meaningful data for analysis.

23.1.2.4.3 Posttrial Burn

The posttrial burn period is the time for U.S. EPA to evaluate all of the data that were recorded during the incinerator's trial burn. To allow the operation of a hazardous waste incinerator following the completion of the trial burn, U.S. EPA establishes permit conditions sufficient to ensure that the unit will meet the incinerator performance standards. This posttrial burn period is limited to the minimum time required to complete the sampling, analysis, data computation of trial burn results, and the submission of these results to U.S. EPA.

23.1.2.4.4 Final Operating Conditions

After reviewing the results of the trial burn, U.S. EPA will modify the permit conditions again, as necessary, to ensure that the operating conditions of the incinerator are sufficient to ensure compliance with incinerator standards and protection of human health and the environment. Owners/ operators of incinerators must comply with the final permit conditions for the duration of the permit, or until the permit is modified.

23.1.2.4.5 Data in Lieu of Trial Burn

While most incinerators must undergo a trial burn, it is possible for a facility to submit extensive information in lieu of the trial burn. U.S. EPA believes that most combustion units will need to conduct trial burns in order to develop operating conditions that ensure compliance with the performance standards. Data submitted in lieu of the trial burn, therefore, must originate from a unit with a virtually identical design that will burn wastes under virtually identical conditions (i.e., located at the same facility).

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