Omnibus permitting authority

As U.S. EPA continues to revise the regulatory program for incinerators in order to adequately protect human health and the environment, the omnibus permitting authority, site-specific risk assessments, and public participation issues have received greater attention. The following discusses both issues in greater detail. 

U.S. EPA may require owners and operators of hazardous waste combustion units to comply with additional performance standards by virtue of the omnibus authority. This authority allows U.S. EPA to incorporate additional terms and conditions into a facility s permit as necessary to protect human health and the environment. 

U.S. EPA recommends that site-specific risk assessments, incorporating direct and indirect exposures, be considered during the combustion unit s permitting process. These risk assessments may be used to evaluate the unit s impact on the surrounding environment. If a site-specific risk assessment shows that additional protection should be afforded to the surrounding environment, U.S. EPA typically will use the omnibus authority to impose the necessary permit conditions. 

The hazardous waste regulations of Alabama, Arkansas, Oregon, and Utah do not require an HRA as a condition for obtaining a RCRA hazardous waste incinerator permit. However, state authorities have required HRAs at each of the chemical agent disposal facilities based on the RCRA omnibus authority. The RCRA permits for ANCDF, PBCDF, UMCDF, and TOCDF all require that an HRA or an HRA addendum be submitted after each trial burn or performance test. 

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