Controlling volatile organic emissions from RCRA hazardous waste activities

Are you properly controlling volatile organic emissions from your Resource Conservation and Recovery Act (RCRA) hazardous waste activities?

To address specific environmental health and safety areas that have been identified as needing improvement to affect increased compliance, the Environmental Protection Agency (EPA) periodically assesses and identifies national compliance priorities, called National Compliance Initiatives (NCIs). One of the NPIs identified for FY 2020-2023 is reducing hazardous air emissions from hazardous waste facilities. This means increased focus on assessing compliance with RCRA air regulations during state and federal agency inspections.

Background
Many Treatment Storage and Disposal Facilities (TSDFs) and Large Quantity Generators (LQGs) of hazardous waste generate, handle, or treat hazardous wastes that contain volatile organic chemicals (VOCs). If not properly managed, VOC emissions from these activities may pose a risk to human health and the environment. To address this issue, the EPA implemented proper management, monitoring, and record keeping requirements for hazardous wastes containing VOCs. These regulations are found in 40 CFR Part 264/265 Subparts AA, BB, and CC and are summarized as follows:

• Subpart AA – Applies to management of leaks from process vents associated with distillation, fractionization, thin-film evaporation, solvent extraction, and air or stream stripping operations that manage hazardous waste with VOC content of at least 10 ppm.
• Subpart BB – Addresses controls for equipment (e.g., pumps, valves, connectors, pressure relief devices) that contact hazardous waste with VOC content of at least 10 percent and are in service for 300 or more hours per calendar year.
• Subpart CC – Requires control of emissions from tanks, containers, and surface impoundments, if they contain hazardous wastes with a VOC content of at least 500 ppm at the point of generation.

Results so Far
Focus on RCRA air requirements will be ongoing, but EPA noted the following items from FY 2020:

• Completed 142 (114 on-site, 28 off-site) EPA compliance evaluations for the RCRA Air NCI.
• Developed web-based inspector training for EPA and state inspectors.
• Identified and repaired over 230 hazardous waste releases as a result of inspections.
• Developed strategies for effective off-site compliance monitoring to evaluate facilities potentially subject to RCRA air regulations.

What you can do now
Here are some things that your facility can do for assessing RCRA air compliance:

• Subpart BB Compliance
  • Document whether equipment subject to Subpart BB is in light or heavy liquid service.
  • Conduct field audits to verify each piece of equipment (pumps, valve, connectors, etc.) is
    assigned a unique identification number and clearly identified.
  • Verify that inspections/monitoring of equipment is conducted on the appropriate schedule and are appropriately documented.
  • Verify that any leak found is tagged with a readily visible weatherproof identification tag, marked with the equipment identification number and date the leak was detected. Verify that tags are removed after completion of repairs
• Subpart CC Compliance
  • Verify that proper documentation of Volatile Organic (VO) content is on file for any hazardous waste stream excluded from Subpart CC requirements due to VO content less than 500 ppm by weight.
  • For hazardous waste tanks and containers, verify determinations have been made as to what level of organic vapor control is necessary based on tank/container size and maximum vapor pressure of the hazardous waste (Level 1, Level 2)
  • Verify that inspection and/or monitoring records are on file at the facility.

TRC Environmental can assist you with RCRA air compliance through our professional staff who have experience with managing, interpreting, and auditing Subpart AA, BB, and CC regulations.