CEMP-ET
EI 11C302
1 October 1997
(5) Even if test results meet RCRA requirements, local or state pollution regulations may
require that plant discharges be disposed in a separate landfill area (monofill). Local regulations
may also require the ash be mixed with Portland cement or otherwise stabilized to minimize the
possibility of undetected contaminants leaching out after being land filled. The design of the
incinerator facility and the ash/ residue disposal facility must include an area of adequate size for
handling and storage of all of the ash and other solid residues (e.g., spent scrubber sorbent)
produced by the incinerator plant during operation.
(6) The fly ash and the gas cleanup system residues if disposed separately from the bottom
ash, may be land filled in a special monofill or may be required to undergo special treatment before
placement in a Subtitle D landfill. The amount of material falling into this category is usually a small
percentage of the original waste stream (i.e., 1-5% by weight).
5-5. ENVIRONMENTAL PERMITTING.
a. Professional Assistance. Each proposed facility must satisfy unique conditions and limits
imposed by the permitting authorities. Regulatory authorities that have jurisdiction must be
identified, as well as, the current regulations that apply to the project.
b. Environmental Assessment/ Environmental Impact Statement. An Environmental Impact
Statement (EIS) may have to be prepared as part of the permitting process. If several older boiler
plants without pollution controls are to be shut down, and less pollutants emitted as a result of
operating an incinerator plant with emission controls, credit can be taken for the net reduction in
emissions. If an EIS is not required, an Environmental Assessment (EA) will be necessary, if for no
other reason than to document why the EIS is not needed. Inordinate concern by the public over
an incinerator project may force the issuance of an EIS. This concern may also require preparation
of other reports, not required by regulations, in order to demonstrate the thoroughness of the
planning process and to preempt legal challenges that can cause long delays in the completion of
the project. Some civilian companies found out the hard way that the legal challenges turned out
to be considerably more expensive than the cost of dealing with the public's concerns ahead of
time. This can be especially true if the regulators or the public believe that the decision to build has
occurred without proper consideration of all environmental consequences.
c. Permit Hearing. Local pollution control boards may have stringent, regulations due to
public concern over the local ambient environmental quality. Official public hearings as specified in
the federal regulations (40CFR 60.23) are required if the state has chosen to accept the provisions
of this regulation. Demonstration of compliance to all requirements will have to be made at the
hearing. Informal meetings with public officials and citizen groups should be encouraged only after
the project planners and the engineers have demonstrated their environmental data base is
complete and accurate.
d. BACT, LAER, MACT and RACT.
(1) There are four emission control concepts that the designer should be aware of: Best
Available Control Technology (BACT), Lowest Achievable Emission Rate (LAER), Maximum
Available Control Technology (MACT), and Reasonable Available Control Technology (RACT).
(2) BACT. BACT refers to a standard of performance and not a specific pollution control
technology. However, the standard of performance frequently has been established by a specific
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