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Implementation Issues with Subpart CC
Implementation Issues with Subpart CC
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Implementation Issues with Subpart CC
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One of the major implementation issues associated with Subpart
CC and the other RCRA Organic Air Emission Standards is the
lack of detailed permit conditions. Often times the permit
condition states simply that the facility must comply with
Subparts AA, BB and CC. This is not sufficient. Permit
conditions must be unit specific. EPA Region 4 has developed
a Model Permit to be used as a starting point for developing
site-specifc permit conditions. In addition, an example of a
site specfic permit from EPA Region 8 has also been provided. |
| Implementation Issues with Subpart CC |
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Description: Another issue is the lack of facility awareness regarding the
regulations. Often, the facility mistakenly believes that units are
exempt from the regulations due to overlap with the CAA or
other RCRA exemptions. These units are often not identified in
the permit application or go unnoticed until an inspection. EPA
Region 2 has developed a 3007 Information Request which
may be useful in identifying those units which require permitting.
Another tool that has been developed for the permit writer is a
template of notice of deficiency comments which may be used
during the permit application review process to obtain additional
information. |
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