Potential Problems with the Current RCRA Incineration Permit Process

Abstract

The current hazardous waste incinerator permitting process is highly uncertain, complex, and unnecessarily restrictive, which makes a permitted facility very difficult to operate on a continuous basis without permit violations. This paper discusses the problems in the current regulation and enforcement practices. Some solutions are suggested. It is suggested that the current highly conservative permitting approach of disallowing any operating conditions or banning any waste feeds which the permit writer may have the slightest doubt of failing to meet the four-9s destruction and removal efficiency (DRE) requirement for even a few seconds, should be reevaluated. It is suggested that a more reasonable approach, using practical engineering judgment to allow those operating conditions and waste feeds which should be able to meet the DRE requirement, should be considered by the regulatory agencies.