Common Deficiencies in RCRA Part B Incinerator Applications

Although requirements are listed in the regulations and guidance is provided in various publications, certain types of information often are deficient in RCRA Part B incinerator applications, resulting in deficiency notices and delays in the permitting process. This paper presents an approach for preparing an incinerator permit application and identifies common deficiencies in the applications. Specific "problem areas" discussed include engineering descriptions, process monitoring, gaseous emission monitoring, automatic waste feed cutoff systems, waste characterization, sampling and analysis, quality assurance/quality control, and general considerations. The paper also suggests approaches to satisfy requirements for these common problem areas resulting in an application that is more likely to be approved by a permit reviewer.