Case Study

BOILERS AND INDUSTRIAL FURNACE (BIF) RULES

A citizens group turned to SEA for expert support in a case involved alleged violations of RCRA's hazardous waste burning standards. In a case involving the impacts of burning hazardous waste at a specific facility, a Declaration was prepared to address the premise of the defendant's motion that the federal BIF Rules for hazardous waste-burning cement kilns are so comprehensive and stringent that no facility could possibly create an "imminent and substantial endangerment" to public health and the environment.

This declaration demonstrated that this premise is incorrect and addresses a secondary issue raised in the motion and supporting declarations; the relative judgement that hazardous waste-burning cement kilns are more stringently regulated than hazardous waste incinerators.

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