RCRA Permit Writers RCRA Organic Air Emission Standards

RCRA Permit Writers’ RCRA Organic Air Emission Standards (OAESs) Overview: Subparts AA, BB and CC 11 -30 -2015 1

Thanks for the Opportunity! If you have any questions, or need to talk more in detail on the particulars or pertinents, feel free to contact me. Denise Housley housley. denise@epa. gov 404 -562 -8495 11/24/2020 2

Overview § Describe the types of facilities, equipment, and units subject to the RCRA Organic Air Emission Standards § Discuss the purpose of the Standards, statutory authority and states’ authorization § Explain how facilities can demonstrate compliance with the Standards § Discuss how we see compliance in the Part B Permit Application and write specific OAESs into enforceable Hazardous Waste Management Permit Conditions. 11/24/2020 3

Applicability: Who Is Covered? § Treatment, Storage and Disposal Facilities (TSDFs) subject to 40 CFR Part 270. § Permitted. § Interim status. § Recycling units at hazardous waste management facilities otherwise subject to permitting standards. § Large Quantity Generator (LQG) less-than-90 -day accumulation tanks and containers. § Tip: Pretty much any place that uses solvents should be considered subject to the OAES until they prove otherwise. [40 CFR 264. 1030(b)(1 -3)] 11/24/2020 4

RCRA Organic Air Emissions Standards: What Is Subject to the Standards? Hazardous waste management units (HWMUs) and associated equipment that manage organic hazardous waste streams. § Subpart AA: Process vents at Treatment, Storage and Disposal Facilities (TSDFs) and LQGs. § Subpart BB: Equipment leaks at TSDFs and LQGs. § Subpart CC: Tanks, Surface Impoundments, Containers and Miscellaneous Units at TSDFs. § LQG containers and tank systems (i. e. , less-than-90 -day units). § Recycling Units are potentially subject to Subparts AA and BB. § Subparts AA , BB and CC apply to storage prior to recycling. 11/24/2020 5

Consider… http: //www. epa. gov/compliance/resources/publications/assistance/ldarguide. pdf 11/24/2020 6

States with RCRA Organic Air Emission Standards Authorization The Standards are effective for all interim status and permitted hazardous waste facilities in all states. § Most states are authorized for the RCRA Organic Air Emission Standards and are responsible for applying the Standards and inspecting for compliance. § If a state is not authorized for the Standards, EPA is responsible for implementing them (e. g. , inspecting for compliance and issuing permit conditions). 11/24/2020 7

The OAESs’ Regulated Universe: Facts to Keep in Mind § Most TSDs and LQGs that manage organic waste streams are subject to the Standards. § Most commonly subject to Subparts BB and CC. § Many facilities claim exemptions from the Standards but most are not valid at most of facilities. § Look closely if they are claiming exemptions or if they are claiming they are not applicable. Its tricky. § The application of the Standards is extremely detailed and specific to the unit, equipment, and device. 11/24/2020 8

RCRA Organic Air Emissions Standards: What Is the Control Approach? § The application of a OAES subpart is based on organic content of the hazardous waste streams handled and the existence of physical, unit-, equipment- and device-specific emission controls that must be installed and operating. § Units that manage waste below the following Subpart threshold organic concentration levels are exempt from the Subpart’s control requirements: § Subpart AA – 10 parts per million by weight (ppmw) total organic concentration of waste stream. § Subpart BB – equipment contacting waste with total organic concentrations of 10% by weight. § Subpart CC – 500 ppmw average volatile organic concentrations at point of origination. 11/24/2020 9

RCRA Organic Air Emissions Standards: What Is Subject to the Standards? SUBPART EQUIPMENT/UNITS COVERED AA Certain process vents ≥ 10 ppmw total organic concentration BB Equipment leaks for equipment in contact with HW stream ≥ 10 % by weight total organic concentration CC 11/24/2020 WASTE STREAM THRESHOLD CONCENTRATION Tanks, surface impoundments ≥ 500 ppmw average VOC at and containers the point of origination 10

RCRA Organic Air Emission Standards: How Is Compliance Demonstrated? § All hazardous waste handling facilities should be able to demonstrate compliance with their waste determination records, written Leak Detection and Repair (LDAR) Program, monitoring and inspection records. § An inspector should ask to see these during inspection. § A permit writer needs to see the detailed LDAR Program spelled out (including inspection/monitoring frequency, forms, procedures and training; maintenance procedures and forms) in the Part B and a list of all equipment and units that are subject to the OAESs. § Use a OAES RCRA Permit Application Information Notice of Deficiency (NOD) letter or the use the attachment to the NOD, to identify all subject equipment and units at a facility for the permit. 11/24/2020 11

RCRA Organic Air Emission Standards: How Is Compliance Demonstrated? § The standards intend for the facility to demonstrate compliance through monitoring and recordkeeping that should be maintained in the facility’s operating records for future inspections. The following should be well detailed in the RCRA Permit Application to ensure appropriate records will be maintained in the operating record to demonstrate compliance: § Control choices need to be well documented and the records on leak detection, repair and inspection should be well detailed to clearly show compliance. § Employee training should be well documented to show employee expertise in leak detection methods, corrective action, and recordkeeping of repairs. § Can be combined with tank/HWMU inspection and recordkeeping for simplicity and to prevent the need for redundant inspections required by Subparts I, J, K, X, AA, BB, and CC. 11/24/2020 12

About Leak Detection & Repair (LDAR) Programs § Although LDAR requirements vary among regulations, all LDAR programs have 5 basic elements: § identifying components § leak definition § monitoring components § repairing components § record keeping § LDAR is a work practice designed to identify leaking equipment so that emissions can be reduced through repairs. 11/24/2020 13

Leak Detection & Repair (LDAR) Programs (The Heart of OAESs) § A component that is subject to LDAR requirements must be monitored at specified, regular intervals to determine whether or not it is leaking. Any leaking component must then be repaired or replaced within a specified time frame. § For more LDAR program details and requirements refer to "Leak Detection and Repair - A Best Practices Guide, " EPA-305 -D-07 -001, October 2007: http: //www. epa. gov/compliance/resources/publications/assistance/ldar guide. pdf § This Guide can provide more information on emissions reductions credited to well executed LDAR programs. 11/24/2020 14

Subpart AA: Process Vents What Vents Must Comply? § Applies to certain TSD and LQG process vents associated with: § § § Distillation Fractionation Thin-film evaporation Solvent extraction Air or steam stripping § Units that manage hazardous wastes with (total) organic concentrations of at least 10 parts per million by weight (ppmw). 1/11/2012 15

Subpart AA: Process Vent Definition Process vent Any open-ended pipe or stack that is vented to the atmosphere either directly, through a vacuumproducing system, or a tank associated with hazardous waste distillation, fractionation, thin-film evaporation, solvent extraction, air stripping or steam stripping operations. (40 CFR § 264. 1031) 11/24/2020 16

Subpart AA: Applicability Determination Is the unit: No Yes Is the unit one of the following types of units - Distillation, Fractionation, Thin-film Evaporation, Solvent Extraction, Air or steam Stripping? Yes Is the unit exempt under 40 CFR § 264. 1 or § 264. 1030 / § 265. 1. or § 265. 1030? No Is the unit associated with a process vent as defined in Section 264. 1031? No Yes Does the unit mange hazardous waste with an organic concentration >= 10 ppmw? No Not Regulated Under Subpart AA §Permitted or interim status? §Recycling unit at permitted/interim status facility? §Large quantity generator accumulating hazardous waste? Yes Regulated Under Subpart AA 11/24/2020 17

Process Vent: Applicability Distillation Column The feed tank vent, bottoms and accumulator tanks’ vents and condenser process vent, above, would be subject to Subpart AA control of their process vent emissions. 11/24/2020 18

Subpart AA: Emissions Control Requirements § Reduce total organic emissions from ALL affected process vents below 3 lb/h and 3. 1 tons/yr or use unit-specific control devices to reduce the total organic emissions by 95 percent by weight. § Engineering calculations or performance tests must be used to determine compliance. § The Standard specifies documentation that must be used for engineering calculation demonstrations. (40 CFR § 264. 1035(b)(4)(iii), RCRA Organic Air Emission Standard Brief Sheet Tool, page 21) § If the facility chooses to use a control device, Subpart AA specifies closed-vent system and control device performance, monitoring, and repair requirements. § If a closed-vent system to a control device is used, the closed-vent system and control device must be operating at all times when emissions may be vented. (All this information on how the facility complies must be detailed in their RCRA Permit Application. ) 11/24/2020 19

Subpart AA: Inspection & Monitoring § § Each control device must have installed and operating. § A flow indicator device that records at least once per hour. § A monitoring device to continuously monitor the control device’s operation. § The monitoring device required to be used to monitor the process vent is control device-dependent. § A monitor installed, calibrated, maintained, and operated in accordance with manufacturer’s specifications. The facility must inspect monitoring records at least once each operating day. § If control device inspection indicates a problem, the facility must immediately implement corrective action and record the resolution of the problem in the operating records. § Closed vent systems must be monitored annually; detectable emissions controlled as soon as practicable, but not later than 15 days. (This information demonstrating the facility is in compliance must be detailed in their RCRA Permit Application. ) 11/24/2020 20

Subpart BB: Equipment Standards Distillation Column The equipment associated with the tanks and bottoms receiver above (e. g. , pumps, valves, connectors, piping) would be subject to Subpart BB. 11/24/2020 21

Subpart BB: What Equipment Is Subject? § Equipment that contacts hazardous waste streams containing at least 10% total organic concentrations by weight. § Specific requirements are detailed for: § § § § Pumps Compressors Pressure relief devices Sampling connecting systems Open-ended valves or lines Valves Flanges and other connectors 11/24/2020 22

Subpart BB: Applicability Determination Is the unit: § § No Yes Does the equipment meet the definition of “equipment” in section 264. 1031? No Yes Is the unit exempt under 40 CFR § 264. 1 or § 264. 1050 / § 265. 1. or § 265. 1050? Yes No Does the equipment come into contact with hazardous waste with an organic concentration of at least 10% by weight? No Not Regulated Under Subpart BB § Permitted or interim status? A recycling unit at a facility that has other operating units subject to a RCRA permit or in interim status awaiting permit? Large quantity generator accumulating hazardous waste? Yes Regulated Under Subpart BB 11/24/2020 23

Subpart BB: Exemptions § Equipment that is in vacuum service. § See 264. 1050(e)/265. 1050(d) for exemption. § See 264. 1064(g)(5)/265. 1064(g)(5) for recordkeeping. § Equipment that contains or contacts hazardous waste with organic concentration of at least 10% by weight for less than 300 hours per calendar year. § See 264. 1050(f)/265. 1050(e) for exemption. § See 264. 1064(g)(6)/265. 1064(g)(6) for recordkeeping. § § Any pumps in light liquid service designed to operate with ‘no detectable emissions’ (<500 ppm above background), that has no externally actuated shaft penetrating the pump housing, and demonstrates ‘no detectable emissions’ by specified methods. Any pump equipped with closed vent system to a control device that captures leaks from pump seals. 11/24/2020 24

Subpart BB: Exemptions § Permit Writers should note that there is not any exemptions of equipment subject to RCRA Subpart BB, even if there are Clean Air Act (CAA) Subparts that the equipment may be subject too. § The facility can however, use a combined recordkeeping system for both for RCRA Subpart BB and Clean Air Act (CAA)LDAR requirements if the recordkeeping system maintains all Subpart BB required information and is readily available for RCRA inspector review onsite. § But, the equipment is still subject to compliance with RCRA Subpart BB. 11/24/2020 25

Subpart BB: Pumps in Light Liquid Service § Monitored monthly to detect leaks. § Visually inspect weekly for indication of liquids dripping from pump seal. § Instrument reading of 10, 000 parts per million (ppm) or greater indicates a leak. § Indications of liquids dripping from pump seal indicates a leak. 11/24/2020 26

Subpart BB: Compressors § § § Equipped with a seal system with a barrier fluid system. Seal system operation and performance requirements are specified in the Standard. Barrier fluid must not be a hazardous waste with organic concentration of 10 percent by weight or greater. Have a sensor to detected failure of each seal or barrier fluid system, or both seal and barrier system. Check sensor monthly if equipped with audible alarm, otherwise check daily. 11/24/2020 27

Subpart BB: Pressure Release Devices in Gas/Vapor Service § Operated with no detectable emissions (< 500 ppm above background) except during pressure releases. § Safety devices used to relieve pressure during emergency events, must be returned to no detectable emissions (to be monitored and confirmed within five days) after each pressure release event. § Repair requirements when a leak is detected. 11/24/2020 28

Subpart BB: Sampling Connections § Must be equipped with a closed-purge, closed-loop, or closed-vent system. § In-situ or no-purge sampling systems are exempt. § Some operational requirements on purge return. 11/24/2020 29

Subpart BB: Open-ended Valves or Lines § Can’t have open ended lines. § Must be equipped with cap, blind flange, plug or second valve. § Operational requirements for second valves and double-block-and-bleed systems are specified by the Standard. Cap on the end of an open line. 11/24/2020 30

Subpart BB: Valves in Gas/Vapor or Light Liquid Service § Monitored monthly by Method 21. § A leak is equal to 10, 000 ppm or greater. § Valve is exempt from monthly monitoring if designed to operate with ‘no detectable emissions’ and tested annually. § Special requirements for valves unsafe to monitor and difficult to monitor. 11/24/2020 31

Subpart BB: Everything Else Heavy service pumps and valves, light and heavy liquid service pressure relief devices and flanges and connectors. § Visual, audible, olfactory or other leak detection monitoring required. § Should be monitored concurrent with tank/HWMU inspections for efficiency. § Repair requirements: 1 st attempt within 5 days / repaired within 15 days (next slide). § Inaccessible or ceramic/ ceramic-lined connectors are exempt. 11/24/2020 32

Subpart BB: Repair Requirements § Leak must be repaired as soon as practicable, but no later than 15 calendar days after detected. § First attempt at a repair shall be made no later than 5 calendar days after detected. § Delays in repair beyond 15 days must be documented and reported semi-annually if the facility is permitted. [ 40 CFR Sections 264. 1059, 265. 1059] 11/24/2020 33

Subpart BB: Recordkeeping Requirements Equipment identification numbers, Associated HWMU identification, Location of equipment on the HWMU, Type of equipment, Waste state and percent-by-weight total organics in waste stream contacting the piece of equipment, § Control method used to comply with Standard, § Can be recorded with other similar records for CAA compliance and with RCRA tank, HWMU or container inspection records. § § § 11/24/2020 34

Subpart BB: Recordkeeping for Leaks When a leak is detected: § Equipment shall be identified with additional weatherproof visible ID as a leaker (with the date of leak detection) (a total of 2 tags). § Record should be entered into inspection log, including: § Instrument, operator, and equipment identification number, § Cause and hazardous waste leaking, § Dates and method of repair. 11/24/2020 35

Subpart BB: Permitted TSD Reporting Requirements § Semi-annual report for: § Valve, pump, or compressor leak not repaired as required, § Dates of HWMU shutdowns, § Control device exceedance(s), § When, what, how long, repair date, cause and repair information. § Report is not required if no exceedance occurs. § The RCRA Permit Application must identify all pieces of and how the facility is complying with the Standard. OAES Conditions should be included in the Permit that facilitate compliance inspection written to include a clear measure or way to demonstrate compliance. 11/24/2020 36

RCRA Subpart CC - Overview Circa 1935 Chemical Plant in New Jersey. 11/24/2020 37

Subpart CC Applicability § Affected units are containers, tanks, surface impoundments, and miscellaneous unit which are: § Subject to permit (Part 264), interim status (Part 265) or lessthan-90 -day large quantity generator (Part 262) standards, and, § Not expressly exempted from the standards. § Subpart CC requires organic emission controls on affected units, unless the average Volatile Organic (VO) concentration of hazardous waste managed in unit is < 500 ppmw at point of waste origination. 11/24/2020 38

Subpart CC: Applicability Determination Any Tanks, Containers, Surface Impoundments, Miscellaneous Units? No Yes Does any of the Subpart CC Applicability Exclusions Apply? Yes No Has the Unit Received Hazardous Waste on or After 12/6/96? No Yes Does Unit manage a Hazardous Waste having an average volatile organic concentration of 500 ppmw or greater at the point of origination? No Not Regulated Under Subpart CC Are such units subject to RCRA Permitting, Interim Status, or less-Than 90 Day Large Quantity Generator Standards? Yes Regulated Under Subpart CC No (Exemptions from certain control requirements may apply) 11/24/2020 39

Examples of RCRA Exemptions that Apply to Subpart CC § Wastewater treatment units and elementary neutralization units, § For more information on these exemptions, a separate training is available to explain them in detail. § Emergency or spill management units, § Totally enclosed treatment facilities, § Hazardous waste recycling units (if no other permitted units at facility), § Conditionally exempt small quantity generators (CESQG). 11/24/2020 40

Examples of RCRA Exemptions that Apply to Subpart CC (Continued) Small quantity generators (SQG) Satellite accumulation areas RCRA empty containers Onsite CERCLA and RCRA corrective action units Nuclear Regulatory Commission (NRC) or equivalent permit-controlled units managing radioactive mixed waste § Containers less than 26. 4 gallons § There are other less common permitting exemptions also listed § § § 11/24/2020 41

Hazardous Waste Management Units (HWMUs) subject to Equivalent Emission Control Requirements of CAA NESHAPs or NSPSs Subpart CC exempts units which § Are required to comply with comparable subparts of 40 CFR Part 60, 61 or 63 for unit-specific control of fugitive volatile organic emissions from HWMUs and § Are required to install and operate air emission controls on each subject HWMU Note 1: Exemption is frequently misinterpreted Note 2: Exemption is not as commonly applicable as it appears Note 3: Units can be subject to CAA rules yet not required to comply with the CAA rule and are not exempted from Subpart CC 11/24/2020 42

Subpart CC: What Is the Point of Waste Origination? § Owner or operator is responsible for ensuring the waste determination is representative of current worst case waste streams. § Repeat when waste stream or process changes, § Update annually. § The point of origination is where a hazardous secondary material (e. g. ; sludge or by-product) produced by a process is intended to be discarded (i. e. , no longer can be used and is diverted from or separated from the production process). § Solid waste produced by the system becomes a hazardous waste as defined by Part 261. 11/24/2020 43

What Is Considered a Volatile Organic Compound? § Organic compounds with a Henry’s law constant value of at least 0. 1 mole-fraction-in-the-gas phase/mole-fraction-inthe liquid-phase at 25 degrees Celsius. (40 CFR 265. 1081) § Appendix VI of Part 265 presents a list of compounds known to have a Henry’s law constant values less than the cutoff level. 11/24/2020 44

How Is the VO Concentration Determined? § Testing: § Sample hazardous waste, § Analyze samples using one of seven specified methods or other method validated using specified procedures (Method 25 D). § Process knowledge: § Application of owner/operator experience using appropriate information. § VO concentration must be determined for each waste stream. 11/24/2020 45

Process Knowledge § Provides flexibility to use available information to determine VO concentration of a hazardous waste. § Information sources can be: § Existing information collected for other purposes, § New information collected specifically for the waste determination, § For hazardous waste generated off-site, information provided to TSDF by waste generator. 11/24/2020 46

Subpart CC: Container Control Requirements 11/24/2020 47

Determination of Applicable Level of Control for Containers Table 2, here below, provides a matrix for determining the applicable control level for a container EPA 530 -F-98 -011 July 1998 US EPA Region 3 http: //www. epa. gov/osw 11/24/2020 48

Container Level 1 Controls § Three control alternatives: § Use container that meets DOT regulations, § Use a tight-fitting cover on the container and ensure there are no visible gaps, § Use organic vapor suppression barrier on or above the hazardous waste in the container. § May use conservation vents or safety device if normally closed. § The Permit Application must specify the selected control methods for each HWMU managing a waste stream subject to Subpart CC. 11/24/2020 49

DOT Container Use and Compliance with Subpart CC Container Standards § In Department of Transportation (DOT) hazardous materials (Haz. Mat) regulations, waste makeup or constituents all have specified DOT containers in which the waste is allowed to be stored and transported. § Each approved container for a specific waste has been tested in a multi-test procedure by DOT. § Approved containers for specific waste constituents can be found tabulated in 49 CFR Part 172. 11/24/2020 50

Container Level 2 Controls Three control alternatives § Use container that meets DOT regulations § Use container that operates with no detectable organic emissions as tested using Method 21 § Use container that is demonstrated to be vapor-tight within the last 12 months using Method 27 11/24/2020 51

Splash Loading: Not Allowed for Level 2 Containers Organic vapors emissions Fill pipe Hatch cover Organic vapors Waste 11/24/2020 52

Example of Acceptable Loading Procedures that Meet Transfer Requirement 11/24/2020 53

Container Level 3 Controls § Two control alternatives § Vent container directly through a closed-vent system to a control device § Container inside an enclosure which is exhausted through a closed-vent to a combustion control device § Transfer requirements same as Level 2 § Standard specifies design and operating criteria for venting vapors directly to a control device 11/24/2020 54

Container Level 3 Enclosures must meet the design and operating criteria specified in “Procedure T Criteria for and Verification of a Permanent or Temporary Total Enclosure” under 40 CFR 52. 741 11/24/2020 55

Subject Container Example: The Dumpster 11/24/2020 56

Subject Container Example: The Roll-off 11/24/2020 57

Subject Container Example: The Vacuum Truck 11/24/2020 58

Subpart CC: Control Requirements for Tanks 11/24/2020 59

Tank Level 1 Tank must meet ALL three conditions to qualify to use Tank Level 1 controls (i. e. , fixed roof): § Maximum organic vapor pressure of waste is less than tank design capacity for the maximum organic vapor pressure of the worst case hazardous waste managed. § Contents are not heated to temperatures above the temperature of vapor pressure determination. § No waste stabilization done in the tank. 11/24/2020 60

Tank Level 1 Controls - Fixed Roof § Fixed roof is stationary (doesn’t fluctuate with the level of material in tank). § An integral part of the structural design, or, § May separate from rest of tank (e. g. , removable top on a vertical tank), § Fixed roof openings can be equipped with: § Closure devices if no visible cracks, holes, gaps or other open spaces when secured in closed position, § Permanent openings if vented to an organic emission control device, § Pressure relief devices (e. g. , conservation vent) that are vented to atmosphere if set point is appropriate for tank design pressure limits. 11/24/2020 61

Typical Fixed-Roof Tank Pressure/vacuum valve (for venting) Gauge hatch Manhole Hazardous Waste Manhole 11/24/2020 Nozzle (for submerged fill or drainage) 62

Tank Level 2 Controls § Tanks that hold waste exceeding the Level 1 criteria or cannot be proved otherwise are required to use Level 2 controls. § Tanks must be regularly inspected. § Records of all inspections, regardless of the control level, must be kept at the facility for a minimum of 3 years after the date of the inspection. 11/24/2020 63

Tank Level 2 - Design Options Five design options allowed for Level 2 Tank Controls § Cover vented to control device § Pressure tank § Tank inside enclosure which is vented to combustion control device § Fixed roof with internal floating roof § External floating roof 11/24/2020 Covered Level 2 Tank vented to control device. 64

Determination of Applicable Level of Control for Tanks This table provides a matrix for determining the applicable tank control level EPA 530 -F-98 -011 July 1998 US EPA Region 3 http: //www. epa. gov/osw 11/24/2020 65

Waste Transfer Operations § Transfer of hazardous waste among Level 2 tanks and surface impoundments subject to Subpart CC must be conducted using hard-piping or other closed system that does not allow exposure of the waste to the atmosphere § An individual drain system meeting the requirements of 40 CFR Part 63, Subpart RR is considered a closed system 11/24/2020 66

Control Requirements for Surface Impoundments 11/24/2020 67

Subpart CC Example: Cover Vented to a Control Device 11/24/2020 68

Last Note: Conservation Vents § One of the common problems found onsite relating to fugitive air emissions from conservation vents on Level 1 tanks is that the vent appears to be venting all the time. § To address this issue in permitting, the Permit Writer should require the following information be included in the Permit Application. § The manufacturer’s design specifications for the Level 1 tank that has a conservation vent and the conservation vent’s manufacturer specified set point. Tank design specs include the maximum working pressure. § The conservation vent set point (i. e. , pressure at which the conservation vent will open) should not be less than the maximum working design pressure of the tank. § The vacuum pressure of the conservation vent should not be less 11/24/2020 than the Level 1 tank’s working vacuum pressure. 69

Again, Thanks for the Opportunity! If you have any questions, or need to talk more in detail on the particulars or pertinents, feel free to contact me. Denise Housley housley. denise@epa. gov 404 -562 -8495 11/24/2020 70