An owner/operator wishing to operate a new hazardous waste BIF is required to obtain an RCRA permit before beginning construction of the unit. The purpose of this permit is to allow the new BIF to establish operating conditions that will ensure adequate protection of human health and the environment. The BIF permit process consists of four operational phases: pretrial burn, trial burn, posttrial burn, and final operating conditions.
The pretrial burn phase of the permit allows the BIF to achieve the 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 BIF to a point of operational readiness to conduct a trial burn. This phase is often referred to as the shakedown period.
The trial burn can be seen as the "test drive" of the BIF. 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. These 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 the conditions in the permit that are required for conducting an effective trial burn, meaning that the burn will be representational of the BIF's intended day-to-day operation and will yield meaningful data for analysis.
The posttrial burn period is the time for U.S. EPA to evaluate all of the data that were recorded during the BIF's trial burn. To allow the operation of a hazardous waste BIF following the completion of the trial burn, U.S. EPA establishes permit conditions that are sufficient to ensure that the unit will meet the BIF 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.
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 BIF are sufficient to ensure compliance with BIF standards and protection of human health and the environment. Owners/operators of BIFs must comply with the final permit conditions for the duration of the permit, or until the permit is modified. The unit must be managed in accordance with all of the operating conditions described in the permit and established by the trial burn.5
While most BIFs 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).
The omnibus provision allows the Regional Administrator or state to incorporate into a permit any provision deemed necessary to protect human health and the environment. Specifically, this allows U.S. EPA to incorporate additional terms or conditions not found in the regulations, if site-specific circumstances dictate this result.21 Under the U.S. EPA Strategy for Hazardous Waste Minimization and Combustion, U.S. EPA directed the states and Regions to conduct site-specific risk assessments (incorporating direct and indirect exposures) into a combustion unit's permit using this omnibus authority. These risk assessments can be conducted by either the implementing agency or the facility (subject to agency oversight) during the permitting process.
On December 11, 1995, U.S. EPA published a final rule expanding the role of public participation in the RCRA permitting process. This rule affects BIFs by increasing the extent of public participation during the trial burn process. Specifically, the permitting agency is required to issue a public notice prior to approving a facility's trial burn plan and must announce the commencement and completion dates for all trial burns. The Public Participation Rule20 also included some changes to the procedural requirements for permitting interim status facilities.
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