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Self-Implementing a Non-Waste Determination Under the Non-Hazardous Secondary Materials (NHSM) Rule
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Self-Implementing a Non-Waste Determination Under the Non-Hazardous Secondary Materials (NHSM) Rule

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Dan Holland of All4 Inc. presents "A Template for Self-Implementing a Non-Waste Determination Under the Non-Hazardous Secondary Materials (NHSM) Rule." The presentation covers documentation, …

Dan Holland of All4 Inc. presents "A Template for Self-Implementing a Non-Waste Determination Under the Non-Hazardous Secondary Materials (NHSM) Rule." The presentation covers documentation, non-waste legitimacy criteria, and provides a basic timeline to complete self determination.

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  • 1. A Template for Self-Implementing a Non-Waste Determination Under the Non-Hazardous Secondary Materials (NHSM) Rule Presented to the AF&PA, NCASI AND AWC BOILER MACT WORKSHOP by All4 Inc. Dan Holland| dholland@all4inc.com | 610-933-5246 ext 15 March 13, 2013 www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688
  • 2. A Typical Scenario    2 Alternate Fuel Supplied by Third Party Vendor Biomass Component Post Consumer Component Your environmental compliance is clearly our business.
  • 3. How Do I Document My NHSM?    3 DIY Vendor Third-Party Consultant Your environmental compliance is clearly our business.
  • 4. Documentation Includes   4 Sufficient Processing of NHSM Demonstrating Legitimacy Criteria are Met Your environmental compliance is clearly our business.
  • 5. NHSM Non-Waste Legitimacy Criteria    5 Managed as a Valuable Commodity Meaningful Heat Content Comparable Contaminant Levels Your environmental compliance is clearly our business.
  • 6. Engineered Fuel with Specifications for      6 BTU Content Sizing Moisture Level Minimal Dusting Metals Removal Your environmental compliance is clearly our business.
  • 7. HAPs, HAP Precursors Testing   7 Include What You Know to be There Exclude What You Know Not to be There Your environmental compliance is clearly our business.
  • 8. Homogeneous Nature of NHSM   8 Amount of Sampling Required Data In Lieu of Sampling (Fuel Vendor’s Information) Your environmental compliance is clearly our business.
  • 9. Boiler MACT Recordkeeping    9 Documentation of the NHSM Processing (required) Documentation of Legitimacy Criteria (suggested) Documentation of Changes to NHSM (suggested) Your environmental compliance is clearly our business.
  • 10. Costs for Self Determinations   10 Analytical Costs $1,500 for 70 Contaminants Third-Party Preparation Budget $17,500 Your environmental compliance is clearly our business.
  • 11. Timeline to Complete a Self Determination    11 4-6 weeks To Build the Demonstration 2-4 weeks for Analytical Results Comfort Letters Take 6-12 Months Your environmental compliance is clearly our business.
  • 12. Self Determinations are in Your File Cabinet  12 “…persons who burn NHSM are ultimately responsible.” Your environmental compliance is clearly our business.
  • 13. 1054 Days and Counting (it’s a Sunday by the way) Dan Holland| dholland@all4inc.com | 610-933-5246 ext 15 March 13, 2013 www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688