The Tier Management Decision

Owners and operators choose which level of hydrogen chloride, chlorine gas, and metals monitoring is optimum for their facility. If they decide upon a lower numbered tier, the level of monitoring and modeling will be lower. However, the amount of waste the facility is allowed to feed and the permitted emission rate of total chlorine will also be lower. Thus, it is important that the selected tier matches the expected volume and toxic nature of the waste feed at the facility.

When determining which tier to select, the owners and operators of a facility should consider the following factors:

• Physical characteristics of the facility and surrounding terrain
• Projected waste compositions and feed rates
• Level of resources available for conducting analysis, monitoring, and modeling

Owners and operators must decide if the additional costs of conducting analysis, monitoring, and modeling are worth the benefit of being able to possibly combust waste with a higher concentration of regulated material. Once a tier is selected for a facility, the owners and operators must comply with the standards associated with the selected tier (refer to 40 CFR 266.107).

To learn more about RCRA safety standards visit our RCRA Refresher Online Training web page.