Solid/Hazardous Waste Management
Spectrum assists our clients in the permitting and use of non-hazardous secondary materials (NHSMs), solid waste, and hazardous waste. EPA has issued four rules that will provide substantial reductions in the release of hazardous air pollutants into the atmosphere, and provide substantial benefits to the many communities where these units are located. The four rules were developed together because of the interrelationship among them.
Three of the rules establish emission standards under the Clean Air Act (CAA) for boilers and incinerators, while the other rule was developed under the Resource Conservation and Recovery Act (RCRA). The RCRA rule identifies which non-hazardous secondary materials are, or are not, solid wastes when burned in combustion units, such that: Non-hazardous secondary materials considered solid wastes under RCRA would be subject to the section 129 CAA requirements and Non-hazardous secondary materials not considered solid wastes under RCRA would be subject to the section 112 CAA requirements. Under the RCRA rule, traditional fuels, including historically managed traditional fuels (e.g. coal, oil, natural gas) and “alternative” traditional fuels (e.g. clean cellulosic biomass) are not secondary materials and thus are not solid wastes. Specific services which Spectrum provides are provided below.
The Maryland Department of the Environment (MDE) Land Management Oil Control Program requires owners of Underground Storage Tank (UST) fuel systems to have a Maryland certified Third Party Inspector conduct an inspection of their USTs to ensure compliance with federal, state, and local environmental regulations governing USTs. Additionally, MDE requires that owners of UST systems to follow a three-year cycle of performing third-party UST inspections to certify regulatory compliance. Spectrum provides services for performing an third-party inspection of their UST systems and also providing guidance that would help assure that they maintain compliance with applicable environmental regulations. Spectrum’s staff is certified as MDE Third-Party UST Inspectors.
40 CFR 112 specify Spill Prevention, Control, and Countermeasure (SPCC) regulation which requires a facility that has an above ground storage capacity of 1,320 gallons to conduct a periodic inspection of their petroleum Aboveground Storage Tanks (AST). Spectrum assists our clients by conducting a routine monthly and annual inspection as required by the SPCC regulation. We also can provide training to client’s personnel on how to conduct these monthly and annual inspections. Spectrum’s has staff that is certified as a STI SP001 Inspectors.
EPA Comfort Letter
Alternate fuel products to be burned for energy recovery in combustion units are considered to be a non-waste fuel, and not a solid waste, if it meets the requirements stipulated in the EPA Non-Hazardous Secondary Material (NHSM) Rule requirements specified in 40 CFR 241.3(b)(4). To be designated as a non-waste fuel under 40 CFR 241.3(b)(4), requires that processing of NHSM meets the definition of “processing” defined in 40 CFR 241.2 and the “legitimacy criteria” defined in 40 CFR 241.3(d)(1). Spectrum has developed a number of EPA Comfort Letters to determine whether the alternative fuels proposed to be burned would be considered by EPA to be a either solid waste or a non-hazardous fuel. Spectrum has assessed NHSM including dried biosolids and various engineered fuels containing municipal solid waste (MSW) and non- MSW (i.e., recyclable portions only).
Alternate NHSM Permitting
Spectrum has assisted a number of our industrial clients with the permitting associated with use of alternate fuels consisting of Non-Hazardous Secondary Materials (NHSMs) to supplement their use of traditional fossil fuels, including coal and petroleum coke. These NHSM alternate fuels were assessed for being able to meet the Plant’s current Title V Operating Permit air emission limits as well as for determining if use of the alternate fuels would impose any new air quality or solid waste regulatory permitting requirements. The permitting services includ the use of the alternate fuel in the Plant’s combustion unit but also include the transport, handling, storage, and delivery of the alternate fuel to the Plant’s combustion unit.
CISWI Rule Applicability Assessments
Spectrum has in-depth knowledge of assessing the impact of the CISWI/Solid Waste rulemaking on various industries and we are very familiar with the various proposed and final CISWI, Solid Waste, MWC, and NESHAP/NSPS Rules.
Spectrum experience includes assisting industrial clients with the assessment of the applicability of these EPA Rules and developing a strategy for determining the “right regulatory fit” for each Plant accounting for current and planned alternate fuel use, capital investment required to be compliant with each Rule, and the regulatory timetable associated with the anticipated effective dates for each Rule.