Waste Combustion Industry Profile
Schreiber, Yonley & Associates provides compliance services in all aspects of environmental regulations and requirements, and specializes in applying non-hazardous and hazardous waste combustion regulations. Our technical expertise in dealing with the various combustion-related regulations is nationally recognized. Our highly experienced technical staff allows Schreiber, Yonley & Associates to provide outstanding service, not only on technical issues, but also by developing relationships with the regulatory agencies and community members.
The services that we provide include environmental permitting, regulatory compliance; environmental compliance audits, trial burn/comprehensive performance test and risk assessment coordination and oversight; regulatory interpretation and agency communication; air quality management; and communication and public relations support. Technical services that our staff provide to waste combustion facilities address the realm of environmental regulations, with a specific focus on Clean Air Act (CAA), including National Emission Standard for Hazardous Air Pollutants from Hazardous Waste Combustion (HWC NESHAP or HWC MACT), Commercial and Industrial Solid Waste Incinerator Rules (CSWI) and the solid and hazardous waste components of the Resource Conservation and Recovery Act (RCRA). In addition, we perform technical studies on issues ranging from dioxin, metals and organic emission determinations, to appropriate practices for management of wastes. Some of the key service areas that we provide to hazardous waste combustion facilities are as follows.
Permitting and Compliance
Schreiber, Yonley & Associates has extensive experience assisting clients in planning for and complying with the complex requirements of the RCRA and MACT combustion rules. This experience has included working with industry to coordinate with EPA during the development of the BIF, HWC MACT and CISWI rules. We have developed RCRA permit applications and compliance plans for many facilities, and have worked extensively with the HWC MACT portion of the cement industry in communicating regulatory and technical issues. We have also organized and coordinated work groups on Boiler and Industrial Furnace (BIF) and MACT compliance issues among the cement industry, the U.S. EPA (Regions 4, 5 and 7) and state agencies since the mid-1990s.
The constant change and development of environmental regulations continues to have a significant effect on waste management facilities. Our in-depth understanding of the regulations applicable to the combustion industry has made us a leader in providing technical assistance with interpreting, developing and implementing regulatory programs.
Our engineers have assisted many hazardous waste combustion facilities with implementing the HWC MACT rules. We have worked with facilities to provide comprehensive assistance analyzing plant operations, records, permits, and emissions testing and monitoring to demonstrate and facilitate compliance with the MACT rules. Our services include strategic planning to help regulated facilities plan implementation steps, preparing and updating HWC MACT required plans and procedures, evaluating emissions for complying with the emissions standards, coordinating and overseeing emissions testing programs, and managing associated CAA permitting.
Environmental Compliance Audits
Schreiber, Yonley & Associates has performed numerous comprehensive and media-specific environmental audits for the non-hazardous and hazardous waste combustion industry. An on-site inspection of the facility and a detailed examination of applicable records is conducted to determine the facility’s compliance with CAA, RCRA, Clean Water Act (CWA), Superfund Amendment and Reauthorization Act (SARA) and other applicable environmental regulations. We have particular expertise auditing facilities to assess their procedures for operating in compliance with the BIF and MACT rules.
Trial Burn/Comprehensive Performance Tests and Risk Assessments
We are able to use our extensive knowledge and experience with combustion facilities to assist clients in developing and implementing trial burn/comprehensive performance tests, and coordinating risk assessments under RCRA and the CAA. Schreiber, Yonley & Associates has participated in all aspects of testing including preparing test plans, participating in agency negotiations, overseeing testing, assessing data quality, and preparing comprehensive test reports.
Our staff has also been extensively involved in coordinating with industry, EPA and risk assessment firms on preparing risk assessment protocols and reports for combustion facilities as part of the overall permitting process.
Regulatory Agency Communications
For both the prevention and resolution of enforcement actions, Schreiber, Yonley & Associates is a leader in assisting and representing combustion facilities in communications with regulatory agencies. A number of our staff have worked at and/or managed state or federal regulatory agencies. This insight not only helps in interpreting regulations, but also in working with the agencies to develop plans for implementing compliance. We routinely work with corporate attorneys or with outside legal representation to develop and implement compliance and business strategies.
Clean Air Act Implementation
Schreiber, Yonley & Associates’ staff provides a wide range of services specific to CAA requirements. These services include CAA compliance audits, emissions inventories, air toxic evaluations, stack/source testing, CEM certification, process hazard review, ambient air monitoring, visual emissions assessments, air contaminant dispersion modeling, data management and air permitting including Prevention of Significant Deterioration (PSD), New Source review (NSR) and Title V.
Our firm has the ability to provide engineering, modeling, permitting and testing with in-house personnel and resources, allowing the client an option to assess emissions, ensure compliance, and develop permits utilizing the services of only one firm. We have completed Title V Operating Permit applications for multiple cement manufacturing facilities located throughout the United States.
Dioxins Formation Research and Control
Our experience in working with dioxins and furans includes working with clients, regulatory agencies, and the public in developing and implementing dioxin testing programs and source testing programs. Since 1979, we have studied the formation and behavior of dioxins and furans and have presented data to U.S. EPA headquarters as well as several U.S. EPA regions and state agencies. Schreiber, Yonley & Associates’ extensive background in dioxin research and combustion technology allows us to develop dioxin strategies specific to a particular facility.
Communications, Training, and Community Relations Programs
Our staff has experience working independently with the client or in conjunction with a public relations firm to provide technical support for public meetings and media events. Our experience includes coordinating industry work groups to collectively communicate environmental concerns to state and federal regulatory agencies. Having the necessary background in the sensitivity of public issues, the regulations, and in the technical aspects of hazardous waste management and cement operations, we support our clients in achieving the goal of building trust and a foundation upon which to exchange information within a community.
Other services our firm provides include Occupational Safety and Health Act (OSHA) training for hazardous waste operations (HAZWOPER), operations training with respect to combustion issues; and development of health and safety plans, community exposure evaluations and health profiles.