This paper considers the direct and indirect impacts on facility operations and financial performance resulting from the retrofits required to comply with the tighter emissions standards and more stringent operating requirements imposed by the Clean Air Act Amendments of 1990 (CAAA). While all large municipal waste combustors (>250 tons per day) and many smaller units (>250 TPD) have already made the initial financial and operational adjustments required by CAAA-induced changes, many small combustors preparing to comply with the Subpart BBBB requirements, have yet to experience these changes. Since most large WTE facilities only began operating under the new CAAA scenario during or shortly before December 2000, the long-term cost impacts of these changes are only now becoming clear. The Subpart BBBB standards are nearly identical to the standards imposed on large combustors. Each existing WTE facility operator affected by Subpart BBBB must determine whether the standards can be met with existing air pollution control devices and existing emission monitoring equipment, or if a facility retrofit is required. If a facility retrofit is required, the economics of continued operation as compared to alternative disposal options must be considered.

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