| Requirement & Regulatory Citation |
Requirement & Regulatory Citation Full
Text |
| AIR
EMISSIONS-SUBPART AA, BB and CC CHECKLIST. |
*AIR
EMISSIONS-SUBPART AA, BB and CC CHECKLIST |
|
Subpart AA. |
*Subpart
AA |
|
Background: If a facility (TSD or LQG) manages
hazardous wastes greater than 10 ppmw of
organics in a process vent used in distillation,
fractionation, solvent extraction, thin-film
evaporation, air or steam stripping, Subpart
AA may apply. Subpart AA would
not apply in a bona-fide closed loop scenario
at LQGs and TSDs. To comply, the facility
would need to determine if the process vent(s)
releases greater than 3.0 lbs/hr and 3.1
tons/year of organic air emissions to the
atmosphere. If it does not release
that much then the facility is in compliance
with Subpart AA. If its emissions
are greater, then a control device is necessary
to bring the facility into compliance. The
control device may be a condenser, flare,
carbon absorber, etc... that brings the
equipment?s emission rate below the 3.0
lbs/hr and 3.1 tons/year, or reduces the
organic emissions by 95%.
|
Background:
If a facility (TSD or LQG) manages
hazardous wastes greater than 10 ppmw of organics
in a process vent used in distillation, fractionation,
solvent extraction, thin-film evaporation,
air or steam stripping, Subpart AA may apply. Subpart
AA would not apply in a bona-fide closed loop
scenario at LQGs and TSDs. To comply, the
facility would need to determine if the process
vent(s) releases greater than 3.0 lbs/hr and
3.1 tons/year of organic air emissions to
the atmosphere. If it does not
release that much then the facility is in
compliance with Subpart AA. If
its emissions are greater, then a control
device is necessary to bring the facility
into compliance. The control device
may be a condenser, flare, carbon absorber,
etc... that brings the equipment?s emission
rate below the 3.0 lbs/hr and 3.1 tons/year,
or reduces the organic emissions by 95%. |
|
Objective: The Inspector should try to determine if Subpart
AA applies at a particular facility and,
if applicable, evaluate the facility?s efforts
to achieve compliance. Has the
facility calculated or measured the organic
emissions from all vents and compared that
with the emissions limit?. |
Objective:
The Inspector should try to determine if Subpart
AA applies at a particular facility and, if
applicable, evaluate the facility?s efforts
to achieve compliance. Has the
facility calculated or measured the organic
emissions from all vents and compared that
with the emissions limit? |
|
1.
(a) Is this facility a Large Quantity Generator;
Interim Status TSD; or Permitted TSD? If
NO, do not continue with the RCRA Air Emissions
checklists. |
1.
(a) Is this facility a Large Quantity Generator;
Interim Status TSD; or Permitted TSD? If
NO, do not continue with the RCRA Air Emissions
checklists. |
|
2.
(a) Does the facility have any hazardous
waste management unit using the following
processes: distillation, fractionation,
thin-film evaporation, solvent extraction,
air stripping and steam stripping? If
NO, then proceed to the Subpart BB checklist. |
2.
(a) Does the facility have any hazardous waste
management unit using the following processes:
distillation, fractionation, thin-film evaporation,
solvent extraction, air stripping and steam
stripping? If NO, then proceed
to the Subpart BB checklist. |
|
If
YES, list each process vent that is associated
to one of the processes. |
If
YES, list each process vent that is associated
to one of the processes. |
|
(b)
Does the hazardous waste contain greater
than 10 ppmw organics?. |
(b)
Does the hazardous waste contain greater than
10 ppmw organics? |
|
(c)
Are any of these processes exempt
under the closed loop recycle exemption?. |
(c)
Are any of these processes exempt
under the closed loop recycle exemption? |
|
If
YES, please describe system. |
If
YES, please describe system. |
|
(d)
For those process vents with a yes answer
to 2(b) describe the waste(s), unit(s) and
processes. |
(d)
For those process vents with a yes answer
to 2(b) describe the waste(s), unit(s) and
processes. |
|
(e)
Identify those process vents with a no answer
to 2 (c), and describe the information/
documentation used to make the determination
(collect this information and submit to
EPA). |
(e)
Identify those process vents with a no answer
to 2 (c), and describe the information/ documentation
used to make the determination (collect this
information and submit to EPA). |
|
3(a) Is the total hourly emission rate of the affected
process vents greater than 3 lb/hr?; and . |
3(a)
Is the total hourly emission rate of the affected
process vents greater than 3 lb/hr?; and |
|
(b)
Is the facility-wide yearly emission rate
greater than 3.1 tons/yr?. |
(b)
Is the facility-wide yearly emission rate
greater than 3.1 tons/yr? |
|
(c)
If the answer to 3(a) or 3(b) is no, describe
the calculations done by the company to
support this determination (Provide copies
of the calculations and associated information
and submit it to EPA). |
(c)
If the answer to 3(a) or 3(b) is no, describe
the calculations done by the company to
support this determination (Provide copies
of the calculations and associated information
and submit it to EPA). |
|
4.(a) If the answer to 3.(a) or (b) is Yes, did the facility install
control devices to reduce the emissions? (ALL
TSDS MUST HAVE THE CONTROL DEVICES IN PLACE). |
4.(a)
If the answer to 3.(a) or (b) is Yes, did
the facility install control devices
to reduce the emissions? (ALL
TSDS MUST HAVE THE CONTROL DEVICES IN PLACE). |
|
(b)
Do the calculations/analysis seem reasonable? (Are
they current? Are facility operating
hours (e.g., 8 or 24 hours/day) correct?
Have worst case scenarios been considered?). |
(b)
Do the calculations/analysis seem reasonable? (Are
they current? Are facility operating
hours (e.g., 8 or 24 hours/day) correct? Have
worst case scenarios been considered?) |
|
(c)
If the control devices are not in place,
is there an implementation schedule in the
facility?s operating record? (APPLICABLE
TO LQGS UNTIL JUNE 1999). |
(c)
If the control devices are not in place, is
there an implementation schedule in the facility?s
operating record? (APPLICABLE TO LQGS UNTIL
JUNE 1999) |
|
If
NO, explain:. |
If
NO, explain: |
|
5.(a) Are control devices inspected and/or monitored
at least once each operating day to ensure
proper operation?. |
5.(a)
Are control devices inspected and/or monitored
at least once each operating day to ensure
proper operation? |
|
(b)
Is there any indication of a problem with
the operation of the control devices?. |
(b)
Is there any indication of a problem with
the operation of the control devices? |
|
(c)
In case of problems, were corrective measures
implemented immediately?. |
(c)
In case of problems, were corrective measures
implemented immediately? |
|
If
NO, explain:. |
If
NO, explain: |
|
IF
THE FACILITY IS SUBJECT TO THE SUBPART AA
RULE AND IS USING A CONTROL DEVICE AND YOU
ARE UNSURE OF THE COMPLIANCE STATUS, COLLECT
THE DESIGN AND MONITORING DATA AND FORWARD
TO THE EPA OFFICE FOR REVIEW. |
IF
THE FACILITY IS SUBJECT TO THE SUBPART AA
RULE AND IS USING A CONTROL DEVICE AND YOU
ARE UNSURE OF THE COMPLIANCE STATUS, COLLECT
THE DESIGN AND MONITORING DATA AND FORWARD
TO THE EPA OFFICE FOR REVIEW. |
|
Subpart BB. |
*Subpart
BB |
|
Background: If a facility (TSD or LQG) has equipment
(any valve, pump,compressor, pressure relief
device, sampling connection system, flange,
open-ended valve or line) that contacts
hazardous wastes greater than 10 percent
organics, that facility is subject to the
inspection and monitoring requirements of
Subpart BB. If the equipment
used to transport hazardous waste with greater
than 10 percent organics is used for less
than 300 hours per year, then the facility
is excluded from the requirements of 264/265.1052
through 264/265.1060 of this subpart if
the equipment is identified as required
in 264/265.1064(g)(6). |
Background:
If a facility (TSD or LQG) has equipment (any
valve, pump,compressor, pressure relief device,
sampling connection system, flange, open-ended
valve or line) that contacts hazardous wastes
greater than 10 percent organics, that facility
is subject to the inspection and monitoring
requirements of Subpart BB. If
the equipment used to transport hazardous
waste with greater than 10 percent organics
is used for less than 300 hours per year,
then the facility is excluded from the requirements
of 264/265.1052 through 264/265.1060 of this
subpart if the equipment is identified as
required in 264/265.1064(g)(6). |
|
Objective: The Inspector should try to determine if Subpart
BB applies at a particular facility and,
if applicable, evaluate the facility?s Leak
Detection and Repair (LDAR) program. Does
it cover all the effected equipment, what
is its frequency (monthly, quarterly) and
are there records of timely (<15 days)
equipment repair when leaks are detected. The
importance of compliance with Subpart BB
is a function of the amount and volatility
of a facility?s waste. |
Objective:
The Inspector should try to determine if Subpart
BB applies at a particular facility and, if
applicable, evaluate the facility?s Leak Detection
and Repair (LDAR) program. Does
it cover all the effected equipment, what
is its frequency (monthly, quarterly) and
are there records of timely (<15 days)
equipment repair when leaks are detected. The
importance of compliance with Subpart BB is
a function of the amount and volatility of
a facility?s waste. |
|
6.
Does the facility have any valves or pumps
that contain or contact hazardous wastes
greater than 10 percent organics?. |
6.
Does the facility have any valves or pumps
that contain or contact hazardous wastes greater
than 10 percent organics? |
|
7.
Does the facility have any compressors,
pressure relief devices, sampling connection
systems, flanged pipe open-ended
valve or line that contain or contact hazardous
wastes greater than 10 percent organics?. |
7.
Does the facility have any compressors, pressure
relief devices, sampling connection systems,
flanged pipe open-ended valve or
line that contain or contact hazardous wastes
greater than 10 percent organics? |
|
8.
Is the facility claiming the < 300 hours
exemption?. |
8.
Is the facility claiming the < 300 hours
exemption? |
|
9.
If the answer to Questions 6 or 7 is yes,
and the facility is not claiming the <300
hour exemption, then does the facility have
a list of each piece of equipment that is
subject to Subpart BB?. |
9.
If the answer to Questions 6 or 7 is yes,
and the facility is not claiming the <300
hour exemption, then does the facility have
a list of each piece of equipment that is
subject to Subpart BB? |
|
10.
Has this equipment been marked as required
by the Subpart BB Regulations?. |
10.
Has this equipment been marked as required
by the Subpart BB Regulations? |
|
11.
Has the facility implemented a LDAR program?. |
11.
Has the facility implemented a LDAR program? |
|
Describe the program: |
Describe
the program: |
|
FOR
PUMPS AND VALVES IN LIGHT LIQUID
OR GAS/VAPOR SERVICE. |
*FOR
PUMPS AND VALVES IN LIGHT LIQUID
OR GAS/VAPOR SERVICE |
|
LIGHT LIQUID SERVICE: For a hazardous waste to be in
light liquid service, the vapor pressure
of one or more of the organic constituents
in the material must be greater than 0.3
Kilopascals at 20 degrees C and the total
concentration of pure organic constituents
having a vapor pressure greater than 0.3
kilopascals at 20 degrees Centigrade is
equal to or greater than 20 percent by weight. |
LIGHT
LIQUID SERVICE: For a hazardous waste to be
in light liquid service, the vapor pressure
of one or more of the organic constituents
in the material must be greater than 0.3 Kilopascals
at 20 degrees C and the total concentration
of pure organic constituents having a vapor
pressure greater than 0.3 kilopascals at 20
degrees Centigrade is equal to or greater
than 20 percent by weight. |
|
12.Is each pump in light liquid monitored monthly to
detect leaks?. |
12.Is
each pump in light liquid monitored monthly
to detect leaks? |
|
13.
Is each pump in light liquid service checked
by visual inspection each calendar week
for indications of liquids dripping from
the pump seal?. |
13.
Is each pump in light liquid service checked
by visual inspection each calendar week for
indications of liquids dripping from the pump
seal? |
|
14.
Is each valve in light liquid service or
gas/vapor service monitored monthly for
leaks?. |
14.
Is each valve in light liquid service or gas/vapor
service monitored monthly for leaks? |
|
EQUIPMENT IN HEAVY LIQUID SERVICE. |
*EQUIPMENT
IN HEAVY LIQUID SERVICE |
|
16.Are pumps, valves in heavy liquid service, pressure
relief devices in light liquid or heavy
liquid service and flanges and other connectors
in light or heavy liquid service monitored
for leaks by visual, olfactory, or any other
detection method?. |
16.Are
pumps, valves in heavy liquid service, pressure
relief devices in light liquid or heavy liquid
service and flanges and other connectors in
light or heavy liquid service monitored for
leaks by visual, olfactory, or any other detection
method? |
|
SUBPART CC OVERVIEW . |
*SUBPART
CC OVERVIEW |
|
The
Subpart CC regulations apply to Large Quantity
Generators and Treatment, Storage and/Disposal
Facilities that manage Hazardous Waste of
Volatile Organic Concentration of 500ppmw
or more on an average annual basis in Tanks
and Containers. |
The
Subpart CC regulations apply to Large Quantity
Generators and Treatment, Storage and/Disposal
Facilities that manage Hazardous Waste of
Volatile Organic Concentration of 500ppmw
or more on an average annual basis in Tanks
and Containers. |
|
For
Tank Storage, there are two levels that
a facility may use to manage their waste.
Tank Level 1 requires a fixed roof tank
which uses a maximum organic vapor pressure
to comply with Subpart CC. Tank
Level 2 designs can be one of five options.
These are: (1) an Internal Floating Roof (2)
an External Floating Roof (3)
a tank with a Fixed Roof vented through
a closed vent system to a control device
(4) a Pressure Tank (5) a tank
located inside an enclosure that is vented
through a closed vent system to an enclosed
combustion device. |
For
Tank Storage, there are two levels that a
facility may use to manage their waste. Tank
Level 1 requires a fixed roof tank which uses
a maximum organic vapor pressure to comply
with Subpart CC. Tank Level 2 designs
can be one of five options. These are: (1)
an Internal Floating Roof (2) an
External Floating Roof (3) a tank
with a Fixed Roof vented through a closed
vent system to a control device (4) a Pressure
Tank (5) a tank located inside
an enclosure that is vented through a closed
vent system to an enclosed combustion device. |
|
Most of the facilities will comply with Tank Level 1
which is the easiest to follow. The
other option that will be seen a lot would
be Tank level 2 Option 3. The
other options will be limited to a small
number of facilities and should be referred
to EPA for inspection. As a result,
the emphasis of this checklist has been
these two options. |
Most
of the facilities will comply with Tank Level
1 which is the easiest to follow. The
other option that will be seen a lot would
be Tank level 2 Option 3. The other
options will be limited to a small number
of facilities and should be referred to EPA
for inspection. As a result, the
emphasis of this checklist has been these
two options. |
|
For
Container Storage, most of the facilities
will store their waste in DOT approved containers.
RCRA regulations already cover such storage
and as a result, most facilities will be
in compliance with the container storage
regulations of the Subpart CC regulations. |
For
Container Storage, most of the facilities
will store their waste in DOT approved containers.
RCRA regulations already cover such storage
and as a result, most facilities will be in
compliance with the container storage regulations
of the Subpart CC regulations. |
|
The
checklist does not deal with Surface Impoundments
because there are only a few active ones
remaining in the Region. These should be
referred to EPA for inspection. |
The
checklist does not deal with Surface Impoundments
because there are only a few active ones remaining
in the Region. These should be referred to
EPA for inspection. |
|
RCRA SUBPART CC CHECKLIST FOR AIR EMISSIONS AT LQGS AND
TSDS. |
*RCRA
SUBPART CC CHECKLIST FOR AIR EMISSIONS AT
LQGS AND TSDS |
|
1.(a)Is this facility a TSD or a Large Quantity Generator?. |
1.(a)Is
this facility a TSD or a Large Quantity Generator? |
|
If
the answer is no, STOP, Air Emissions-Subpart
CC regulations do not apply. |
If
the answer is no, STOP, Air Emissions-Subpart
CC regulations do not apply. |
|
2.(a) Are there any units at the facility subject to
the CC Rule?. |
2.(a)
Are there any units at the facility subject
to the CC Rule? |
|
(b)
If the answer is no, what is the reason? Ref.
40 CFR 265.1080(b) (264.1080(b) exceptions
or 265.1083(c) (264.1082(c)) exemptions,
or the general exclusions in 265.1(g) (264.1(g)),
as applicable. |
(b)
If the answer is no, what is the reason? Ref.
40 CFR 265.1080(b) (264.1080(b) exceptions
or 265.1083(c) (264.1082(c)) exemptions, or
the general exclusions in 265.1(g) (264.1(g)),
as applicable. |
|
40
CFR 1080(b)exemptions:. |
*40
CFR 1080(b)exemptions: |
|
(1)
Unit did not receive HW after 12/6/96. |
(1)
Unit did not receive HW after 12/6/96. |
|
(2)
Using containers of less than 26 gallons
capacity. |
(2)
Using containers of less than 26 gallons capacity. |
|
(3)
Unit undergoing closure. |
(3)
Unit undergoing closure. |
|
(4)
Units used in an on-site RCRA or CERCLA
clean-up. |
(4)
Units used in an on-site RCRA or CERCLA clean-up. |
|
(5)
Mixed Radioactive and hazardous waste. |
(5)
Mixed Radioactive and hazardous waste. |
|
(6)
Units with CAA, NESHAPS or NSPS controls. |
(6)
Units with CAA, NESHAPS or NSPS controls. |
|
(7)
Tanks with process vents (Subject to Subpart
AA). |
(7)
Tanks with process vents (Subject to Subpart
AA). |
|
40
CFR 265.1083(c) exemptions: . |
*40
CFR 265.1083(c) exemptions: |
|
(8)
Waste stream less than 500 ppmw average
VOC. If so, was waste determination
done per 265.1084?. |
(8)
Waste stream less than 500 ppmw average VOC. If
so, was waste determination done per 265.1084? |
|
(9)
All waste placed in unit meets 268.40 (LDR)
limits. |
(9)
All waste placed in unit meets 268.40 (LDR)
limits. |
|
(10) Tank is used for bulk feed to incinerator and requirements
of 265.1083(5)(i)-(iii) are met. |
(10)
Tank is used for bulk feed to incinerator
and requirements of 265.1083(5)(i)-(iii) are
met. |
|
40
CFR 265.1 general exclusions/exemptions:. |
*40
CFR 265.1 general exclusions/exemptions: |
|
(11) Hazardous waste recycling unit exemption. |
(11)
Hazardous waste recycling unit exemption. |
|
(12) Satelite accumulation area. |
(12)
Satelite accumulation area. |
|
(13) Totally enclosed treatment facility exemption. |
(13)
Totally enclosed treatment facility exemption. |
|
(14) Elementary neutralization unit(corrosive). |
(14)
Elementary neutralization unit(corrosive). |
|
(15) Waste water treatment in tanks exemption. |
(15)
Waste water treatment in tanks exemption. |
|
(16) Emergency or spill management exemption. |
(16)
Emergency or spill management exemption. |
|
Except If exemption is based on (8) above, then STOP, subpart
CC does not apply. |
Except
If exemption is based on (8) above, then STOP, subpart
CC does not apply. |
|
3.
Is the average volatile organic concentration
of each waste management unit more than
500 ppmw determined on an average annual
basis at point of waste origination?. |
3.
Is the average volatile organic concentration
of each waste management unit more than 500
ppmw determined on an average annual basis
at point of waste origination? |
|
If
yes, does the facility have a list each
unit and the concentration in its operating
record? If no, indicate
if the determination for each unit is in
the facility operating record?. |
If
yes, does the facility have a list each unit
and the concentration in its operating record? If
no, indicate if the determination for each
unit is in the facility operating record? |
|
NOTE: IF FACILITY CLAIMS THAT ITS WASTE IS
BELOW 500PPM, THEN THE WASTE DETERMINATION
DOCUMENTATION SHOULD BE IN THE OPERATING
RECORD.INSPECTOR SHOULD REVIEW THIS DOCUMENTATION
AND SUBMIT IT TO EPA. |
NOTE: IF FACILITY CLAIMS THAT ITS WASTE IS
BELOW 500PPM, THEN THE WASTE DETERMINATION
DOCUMENTATION SHOULD BE IN THE OPERATING RECORD.INSPECTOR
SHOULD REVIEW THIS DOCUMENTATION AND SUBMIT
IT TO EPA. |
|
FOR
EACH UNIT, FOR WHICH A DETERMINATION HAS
BEEN MADE THAT THE HAZARDOUS WASTE CONTAINS
LESS THAN 500 PPM OF VOCS, ANSWER
THE FOLLOWING QUESTIONS. |
*FOR
EACH UNIT, FOR WHICH A DETERMINATION HAS BEEN
MADE THAT THE HAZARDOUS WASTE CONTAINS LESS
THAN 500 PPM OF VOCS, ANSWER THE
FOLLOWING QUESTIONS. |
|
4.
How was waste determination done? Using
Knowledge or Sampling? Ref 40
CFR 265.1084 (264.1083). |
4.
How was waste determination done? Using
Knowledge or Sampling? Ref 40 CFR
265.1084 (264.1083). |
|
(a)
If Knowledge was used, is there any documentation
on file?. |
(a)
If Knowledge was used, is there any documentation
on file? |
|
(b)
Is it adequate?. |
(b)
Is it adequate? |
|
(c)
If sampling was used, does the facility
have a written sampling plan?. |
(c)
If sampling was used, does the facility have
a written sampling plan? |
|
(d)(i) If facility used sampling, was the sampling done
by an EPA approved method?. |
(d)(i)
If facility used sampling, was the sampling
done by an EPA approved method? |
|
(e)
Has the waste stream changed since the initial
waste determination was done which would
cause the character of the waste to change
or to exceed the threshold levels for applicability
of Subpart CC?. |
(e)
Has the waste stream changed since the initial
waste determination was done which would cause
the character of the waste to change or to
exceed the threshold levels for applicability
of Subpart CC? |
|
(f)
If so, was a new waste determination done? If
yes, repeat 4(a)-(e) . |
(f)
If so, was a new waste determination done? If
yes, repeat 4(a)-(e) |
|
TANKS SUBJECT TO SUBPART CC. |
*TANKS
SUBJECT TO SUBPART CC |
|
5.
(a) Is HW having an average VO concentration
of more than 500 ppmw placed in a tank with
either level 1 or level 2 controls? (40
CFR 265.1085(b)(1)). |
5.
(a) Is HW having an average VO concentration
of more than 500 ppmw placed in a tank with
either level 1 or level 2 controls? (40
CFR 265.1085(b)(1)). |
|
Please note: The fixed roof and its closure devices shall
be visually inspected by the owner/operator
to check for defects that could
result in air pollutant emissions. Defects
include, but are not limited to, visible
cracks, holes, or gaps in the roof sections
or between the the roof and the tank walls;
broken, cracked or otherwise damaged seals
or gaskets on closure devices; and broken
or missing hatches, access covers, caps,
or other closure devices. An
initial inspection should be done before
any waste is stored in the tank and at least
once annually thereafter. |
Please
note: The fixed roof and its closure devices
shall be visually inspected by the owner/operator
to check for defects that could
result in air pollutant emissions. Defects
include, but are not limited to, visible cracks,
holes, or gaps in the roof sections or between
the the roof and the tank walls; broken, cracked
or otherwise damaged seals or gaskets on closure
devices; and broken or missing hatches, access
covers, caps, or other closure devices. An
initial inspection should be done before any
waste is stored in the tank and at least once
annually thereafter. |
|
6.
Were the tanks inspected for leaks before
waste was placed into the tank? If
yes, when was it done?. |
6.
Were the tanks inspected for leaks before
waste was placed into the tank? If
yes, when was it done? |
|
7.
Was an annual inspection done on the tanks
described in Question 6? If yes,
when was it done?. |
7.
Was an annual inspection done on the tanks
described in Question 6? If yes,
when was it done? |
|
|
