United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2224A)
EPA-305-B-97-002
December 1997
&EPA
Process-Based Self-Assessment Tool
for the Organic Chemical Industry
EPA Office of Compliance
Chemical Industry Branch
^X Xj Printed on paper that contains at least
r 20 percent postconsumer fiber.
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Background: The organic chemical manufacturing industry is subject to numerous
Federal regulations that have been enacted to protect human health and the
environment. A complex web of requirements results from the fact that little correlation
exists among regulations that target the same medium or activity. Industrial facilities
are responsible for understanding and complying with these requirements. Historically,
EPA has relied on a command and control approach to regulate industrial facilities, but
now is combining its traditional method with innovative compliance assessment
techniques such as self-assessments and facility management systems.
Many industrial facilities have found that using a complete facility Environmental
Management System (EMS) approach uncovers cost effective solutions for tackling all
the requirements as a whole instead of as individual components. In line with this
discovery, EPA is encouraging self-assessments as part of a complete facility EMS
approach to evaluate compliance with environmental regulations. A facility's drive to
identify cheaper, more effective ways to achieve compliance is consistent with EPA's
mission of clarifying and simplifying environmental regulatory control.
Purpose of document:This guide is a resource on Federal environmental regulations
for small- to medium-sized organic chemical manufacturing facilities. The purpose of
this manual is two-fold: 1) to provide a general approach for performing a multimedia
self-assessment to evaluate compliance with environmental regulations, and 2) to
provide industry-specific process and regulatory information necessary for conducting
an assessment at an organic chemical manufacturing facility. The general approach
section describes the steps for planning, conducting, and following up a multimedia
self-assessment. Industry-specific information is given to supplement the generic self-
assessment approach. This document describes processes found throughout the
chemical manufacturing industry and identifies potential releases from each process
and the environmental legislation associated with them. Additional regulatory
requirements (such as applicability, exemptions, monitoring, record keeping, and
reporting) potentially affecting organic chemical manufacturers are summarized by
statute in the appendices.
Approach:The self-assessment tools and statutes are described in the following
sections:
Module 1 - Process-Based Self-assessment ApproacFThis module
addresses process-based self-assessments and facility management systems.
Because every organic chemical manufacturing facility is unique, a general
assessment protocol is provided which can be adapted to an individual facility.
The protocol gives the steps for completing a process-based self-assessment.
These steps include defining the objectives and scope of the assessment,
identifying the assessment team, compiling and evaluating background
information, and preparing the assessment plan or strategy. Sample worksheets
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and templates are included to help develop and conduct the assessment.
Module 2 - Assessment Tool for Production Unit Processeslihis section
identifies many of the common unit processes performed at organic chemical
manufacturing facilities and lists possible releases and their related regulations.
The unit processes include materials handling, reactions, heat transfer, and
separation. The materials handling segment covers equipment such as pipes,
pumps, and storage tanks while the reactions section describes various reactors.
Heat transfer equipment such as heat exchangers, condensers, and evaporators
are covered, along with separation techniques like distillation, ion exchange,
filtration, drying, crystallization, centrifugation, and extraction.
Module 3 - Assessment Tool for Waste Treatment OperationsHhis module
describes waste treatment operations for air, water, and solid waste and
identifies potential releases and associated regulatory concerns. Baghouses,
wet scrubbers, thermal incinerators, flares, adsorption, boilers, cyclones, and
electrostatic precipitators are discussed for air emissions. Primary, secondary,
and tertiary wastewater treatment processes are summarized for water, and
landfills, sludge incineration, halogen acid furnaces, and surface impoundments
are described for solid waste.
Appendix A - Clean Air Act (CAA):Clean Air Act Titles I, III, V, and VI are
summarized in this appendix. Topics include NAAQS, NESHAPs, MACTs,
permitting, chemical accident protection, and stratospheric ozone protection.
This appendix also includes a section on assessment considerations that should
be evaluated during the on-site facility assessment. Regulatory summaries are
provided for performance standards, national emission standards, provisions for
prevention of chemical accidents, and protection of stratospheric ozone.
Appendix B - Safe Drinking Water Act (SWDA)This appendix describes the
public water system program, underground injection control program,
considerations for assessors, and regulatory requirements. Detailed
descriptions of the regulatory requirements include national primary and
secondary drinking water regulations which may be applicable to facilities that
produce their own potable water and the underground injection control program.
Appendix C - Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA):
This appendix summarizes the registration, reporting and packaging
requirements for pesticides and identifies key site assessment considerations.
FIFRA regulations described herein that may apply to organic chemical
manufacturers include registering pesticides and producers of pesticides,
labeling and packaging pesticides, submitting reports, and keeping records.
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Appendix D - Resource Conservation and Recovery Act (RCRATfte RCRA
appendix delineates the requirements for generation, transportation, treatment,
storage, and disposal of hazardous waste. Land disposal restrictions and
underground storage tank regulations are also discussed. The appendix also
contains a section detailing specific RCRA assessment considerations. RCRA
legislation summarized for organic chemical manufacturers includes
classification of generators; requirements for hazardous waste generators and
transporters; regulations for hazardous waste treatment, storage, and disposal;
and restrictions on land disposal and underground storage tanks.
Appendix E - Emergency Planning and Community Right-to-Know Act
(EPCRA): This appendix describes four regulatory programs applicable to
organic chemical manufacturers: hazardous substance notification, emergency
planning and notification, hazardous chemical reporting to the community, and
toxic chemical release inventory. The section also suggests key areas to
evaluate during compliance assessments. Regulatory summaries are included
for the following: designation, notification, and reportable quantities of
hazardous substances; emergency planning and notification; and reporting of
hazardous chemicals and toxic chemical releases.
Appendix F - Clean Water Act (CWA):This appendix includes effluent limit
guidelines, categorical pretreatment standards, NPDES and pretreatment
programs, effluent trading, spills and pollution prevention of oil and hazardous
substances, and reportable quantities of hazardous substances. The appendix
also includes a section on assessment considerations for water treatment and
summaries of regulations pertaining to the pretreatment and discharge of
effluent, discharge and pollution prevention of oil, and designation of hazardous
substances and their reportable quantities. Legislation specific to wastewater
discharges from the manufacture of organic chemicals, plastics, synthetic fibers
(OCPSF), pesticides, Pharmaceuticals, and gum and wood chemicals are also
detailed.
Appendix G - Toxic Substances Control Act (TSCAJFhe TSCA appendix
explains the requirements behind testing, premanufacture notices, significant
new use reporting, and specific hazardous substances and mixtures such as
water treatment chemicals. Record keeping and reporting are delineated,
including reporting requirements for significant adverse reactions, health and
safety data, and substantial risks. Applicable regulations for exporters and
importers, premanufacture notification, significant new uses, and protection
against unreasonable risks are identified along with suggestions of areas to
target in a self-assessment. Chemical-specific regulations are also described.
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Appendix H - References and ResourcesiThis appendix includes references
relating to process operations and waste treatment, pollution prevention,
environmental regulations, inspection procedures, and other relevant materials.
A list of resources for information about performing facility self-assessments is
also given.
This manual may not include all the Federal environmental regulations that an organic
chemical manufacturer must comply with, but it should serve as a starting point. Site
assessors should be aware that, in many instances, State or local regulations may be
more stringent than Federal requirements. Also, site-specific Federal, State, or local
permits may contain additional requirements beyond those specified in the regulations.
As such, part of a facility's EMS should be to check Federal, State, and local
regulations regularly and keep abreast of pending legislation that may impact the
facility.
DISCLAIMER
This document is intended as an aid to compliance with federal regulatory
requirements. The document does not, however, substitute for EPA's regulations, nor is
it a regulation itself. Thus, it cannot impose legally binding requirements on EPA,
States, or the regulated community. Because circumstances vary, this document may
not apply to a particular situation based on the circumstances, and facilities may be
subject to requirements that are different from or in addition to those described in this
document. EPA may change this guidance in the future, as appropriate.
NOTES TO USERS OF THIS DOCUMENT
This document contains both internal and external hyperlinks. Internal links, noted with
magenta text, link the reader to the applicable section, figure, appendix, etc. being
referenced. External links, noted with blue text, link the reader directly to a page on the
Internet (for readers with access to the Internet), consistent with the information being
described in this document. In addition, selecting the bookmark option from the top
menu in the Adobe Acrobat Reader software provides the user with a point and click
table of contents to simplify navigation in the document.
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ACKNOWLEDGMENTS
This document was prepared under the direction and coordination of Mr. Jeffery
KenKnight of the U.S. Environmental Protection Agency (U.S. EPA), Office of Compliance,
Chemical Industry Branch under Contract Number 68-C4-0072. EPA would like to
acknowledge the support of the following individuals:
George Jett U.S. EPA Office of Water
Daniel Fort U.S. EPA Office of Pollution Prevention and Toxics
Conrad Simon U.S. EPA Region 2
Robert Kramer U.S. EPA Region 3
Gerald Fontenot U.S. EPA Region 6
Ken Caring U.S. EPA National Enforcement Investigations Center
Gene Lubieniecki U.S. EPA National Enforcement Investigations Center
David Mahler Vista Chemical Company
Hugh Finklea Ciba-Geigy Corporation
In addition, acknowledgment is given to the many industry representatives, through
the Synthetic Organic Chemical Manufacturers Association, Inc. (SOCMA) and the Chemical
Manufacturers Association (CMA) that contributed their comments.
Photo credits for cover photography by S.C. Delaney/U.S. EPA. Cover photograph courtesy of Vista
Chemical Company, Baltimore, Maryland.
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TABLE OF CONTENTS
Module 1. Process-Based Self-Assessment Approach
1.1 Introduction 1-1
1.2 Process-Based Self-Assessments and Facility Management Systems 1-2
1.3 Preparing for a Process-Based Self-Assessment 1-4
1.4 Conducting the Self-Assessment 1-11
1.5 Assessment Follow-Up 1-20
1.6 Environmental Management System Case Study: Ciba-Geigy Corporation 1-22
Module 2. Assessment Tool for Production Unit Processes
2.1 Materials Handling 2-5
2.2 Reactions 2-16
2.3 Heat Transfer 2-21
2.4 Separation 2-30
Module 3. Assessment Tool for Waste Treatment Operations
3.1 Air Emission Treatment Processes/ Equipment 3-2
3.2 Wastewater Treatment Residuals and Applicable Regulations 3-21
3.3 Solid Waste Treatment and Disposal Processes/Equipment 3-45
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LIST OF APPENDICES
Appendix A. Clean Air Act
National Primary and Secondary Ambient Air Quality Standards A-2
National Emissions Standards for Hazardous Air Pollutants (NESHAP) and Maximum
Achievable Control Technology (MACT) Standards A-6
Permitting Program A-7
Stratospheric Ozone Protection A-9
CAA Assessment Considerations A-10
CAA Regulatory Requirements A-12
Appendix B. Safe Drinking Water Act
Public Water Supply Program B-l
Underground Injection Control Program B-2
SDWA Assessment Considerations B-3
SDWA Regulatory Requirements B-4
Appendix C. The Federal Insecticide. Fungicide, and Rodenticide Act
Registration of Pesticides and Pesticide-Producing Establishments C-l
FIFRA Assessment Considerations C-2
FIFRA Regulatory Requirements C-3
Appendix D. Resource Conservation and Recovery Act Requirements
Hazardous Waste Generation D-2
Hazardous Waste Transportation Regulations D-7
Hazardous Waste Treatment, Storage, and Disposal Regulations D-7
Land Disposal Restrictions D-8
Underground Storage Tank Regulations D-9
RCRA Assessment Considerations D-l 1
RCRA Regulatory Requirements D-12
Appendix E. Emergency Planning and Community Right-to-Know Act
Hazardous Substance Notification E-l
Emergency Planning and Notification E-l
Hazardous Chemical Reporting: Community Right-to-Know E-2
Toxic Chemical Release Inventory E-2
EPCRA Assessment Considerations E-3
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EPCRA Regulatory Requirements E-4
Appendix F. Clean Water Act
Effluents Limitations Guidelines and Categorical
Pretreatment Standards F-2
NPDES Program F-7
Pretreatment Program F-l 1
Policy on Effluent Trading in Watersheds F-13
Spills of Oil and Hazardous Substances F-14
Oil Pollution Prevention F-14
Reportable Quantities for Hazardous Substances F-l5
CWA Assessment Considerations F-15
CWA Regulatory Requirements F-17
Appendix G. Toxic Substances Control Act (TSCA)
Testing - §4 G-l
Pre-Manufacturing Notice Requirements - §5 G-3
Significant New Uses of Chemical Substances - §5(a)(2) G-3
Hazardous Chemical Substances and Mixtures - §6 G-4
Record Keeping and Reporting Requirements - §8(a) G-5
Significant Adverse Reactions - §8(c) G-6
Health and Safety Data Reporting - §8(d) G-6
Notification of Substantial Risks - §8(e) G-7
Chemical Exports and Imports - §§12 and 13 G-7
TSCA Assessment Considerations G-8
TSCA Regulatory Requirements G-9
Appendix H
References H-l
Resources H-7
in
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MODULE 1. PROCESS-BASED
SELF-ASSESSMENT APPROACH
1.1 INTRODUCTION
Historically, the U.S. Environmental Protection Agency (EPA) has relied on a
command-and-control approach to environmental protection. Today, however,
EPA is combining traditional
enforcement activities with more
innovative compliance approaches.
EPA's Office of Compliance was
established in 1994 to focus on
sector-based compliance assistance-
related activities. In line with this
shift, EPA is encouraging the
development of self-assessment
programs at individual facilities. Such
assessments can be a critical link to
continuous environmental
improvement and compliance.
Chemical manufacturing in the United
States is a broad, complex industry.
Unlike most industries, almost every
organic chemical manufacturing facility
is unique in the way that it pro cesses
raw materials into saleable products.
Developing specific facility-assessment
procedures that are accurate and
consistent for the entire industry is
difficult, if not impossible. This module
does not attempt to present detailed
procedures. Rather, it provides a
general assessment protocol that can
be implemented to suit the needs of
individual organic chemical
manufacturing facilities.
EPA developed this manual primarily
for small to medium sized organic
chemical manufacturing facilities. It
promotes process-based self-
assessments and provides an overview of the most common production unit
operations, associated waste streams, and summaries of the regulations and
statutes
potentially
applicable to
those waste
streams. Exhibit
1-1 lists the basic
elements to be
addressed and
evaluated in a
multimedia,
process-based
assessment.
Assessment Tool for Production Unit Processes
1.1
1-1
Introduction
1.2 Process-Based Self-Assessments and Facility
Management Systems 1-2
1.3 Preparing for a Process-Based Self-Assessment .... 1-4
1.4 Conducting the Self-Assessment 1-11
1.5 Assessment Follow-Up 1-20
1.6 Environmental Management System Case Study:
Ciba-Geigy Corporation 1-22
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-1
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The manual is not a facility Exhibit 1 -1. Basic Elements to be
specific compliance guide Addressed and Evaluated in Multimedia
but a starting point by which Process-Based Assessments
facilities can determine the
regulations they must
comply with. Facilities
interested in developing or
enhancing a comprehensive
and ongoing assessment
program can use this manual
as a technical resource and
tailor the information given
to meet their specific needs.
Raw Materials Waste Handling
Receiving Generation
Storage Collection
Mixing Storage
Transport Treatment
Disposal
Manufacturing Process Facility Operations
R&D Operations Operations and Maintenance
Laboratory Operations Emergency Response
Production Unit Operations
Product Storage
Product Shipping
Module 1 outlines a process-based facility assessment approach specific to organic
chemical manufacturing operations and addresses this as a component of facility
management systems. Modules 2 and 3 focus on production unit processes and
waste treatment operations, respectively, identifying specific emissions/releases and
regulations that potentially apply to each unit process and treatment operation.
Appendices A through G contain narrative summaries of environmental statutes
and regulations applicable to the organic chemical manufacturing industry that can
assist facility representatives in identifying specific regulatory requirements. The
reader should note that this self-assessment tool is intended solely as guidance.
Because applicable regulations are specific to each individual facility, the reader is
advised to use the Federal Register or the Code of Federal Regulations to
determine applicable requirements. In addition, Appendix H identifies a variety of
references and resources that can facilitate the preparation, conduct, and follow-up
associated with process-based self-assessments.
1.2 PROCESS-BASED SELF-ASSESSMENTS AND FACILITY
MANAGEMENT SYSTEMS
Businesses are faced with the challenge of achieving economic sustainability and
success while limiting the impact that their activities, products, or services may have
on the environment and human health. Business leaders have recognized that the
implementation of a comprehensive environmental management system (EMS) are
usually more effective and less costly than reacting to environmental problems as
they arise. The benefits of a proactive environmental program has been well
documented. Generally, EMSs outline an organization's structure, policies,
practices, procedures, processes, and resources intended to help a facility achieve
both its economic and environmental goals, without sacrificing one for the other.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. , 9
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Effective EMSs include a significant compliance assurance component designed to
detect, correct and prevent violations. A second goal of an effective EMS should
include components to ensure continuous environmental improvement through
pollution prevention, employee involvement, community outreach, and additional
environmental activities. Major components of an EMS include the following:
Management
commitment to
environmental protection,
supported by policies and
procedures
Compliance assurance
through self-assessment,
regulatory tracking, and
environmental planning
Implementation through a
formal structure, internal
and external
communications, training,
and education
ISO 14001 is in the forefront of
environmental management approaches
designed to ensure environmentally
responsible behavior worldwide.
Specifically, ISO 14001, a series of
environmentally-related standards and
specifications, outlines five issues basic to
EMSs:
(1) environmental policy,
(2) planning,
(3) implementation and operation,
(4) checking and corrective action, and
(5) management review.
Measurement and evaluation
Review and improvement by addressing "root causes" of any deficiencies
A major component of an
effective compliance assurance
program includes periodic and
routine self-assessment. The
self-assessment activities include
both formal and informal
inspections and reviews of
critical areas and programs by
responsible individuals. A
successful compliance
assurance program goes beyond the traditional "find and fix" approach and should
include training, measurement and tracking, distribution and communication,
corrective action, and accountability. To ensure compliance, action points that
require corrective action and accoutability should be set at limits tighter than the
relevant regulations require. A self-assessment program plays an integral part in
Under EPA's Environmental Leadership
Program (ELP), the Ciba-Geigy Corp. St.
Gabriel Plant has endeavored to up and
maintain an EMS and multi-media compliance
assurance program that is second to none. A
case study ofCiba's self-assessment program
is provided in Section 1.6 of this Tool.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-3
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the cyclical nature of an EMS, in which planning, implementation, measurement,
and review are an ongoing process.
1.3 PREPARING FOR A PROCESS-BASED SELF-ASSESSMENT
The various steps and the order of the steps to be taken in preparing for an
assessment depend on the intended scope of the assessment. However, the
following four steps are almost always required:
* Define the objective and scope of the assessment (e.g., whole facility, specific
unit production operations, or a single media focused assessment)
> Identify evaluator or assessment team members (e.g., skills or expertise
needed)
* Compile and evaluate background information (e.g., associated permits)
* Prepare assessment plan/strategy (e.g., order of actions to be taken).
While most process-based evaluations require that these four steps be performed,
the order of these steps and the level of intensity at which they are conducted will
vary depending on the nature and scope of the assessment. It is very important to
keep the planning and preparation efforts in scale with the level of effort estimated
for the assessment and to keep the planning process dynamic in response to
information identified during preparation (e.g., the scope of the assessment might
change after review of facility background information).
Define Objective and Scope
The scope of any assessment
The process-based self-assessment approach
is one of the tools available to a facility
developing or enhancing a comprehensive
compliance assurance program. The
process-based self-assessment approach
provides environmental managers with a link
between identified wastestreams and Federal
Regulatory Requirements.
will often be based on areas of
concern and, in some cases, on
available resources. For
example, the manufacture of a
specific chemical might be
identified as the source of
chronic water compliance
problems. In this instance, the
assessment can focus entirely
on the production units
potentially contributing to the compliance problem. It is important to note that
using the process-based assessment approach, the production of this one chemical
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. 1 *
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or the generation of one particular wastestream might require an evaluation of
ancillary process operations, such as raw material storage and handling or even
wastestreams with maintenance activities.
Optimally, facilities should perform process-based self-assessments on a regular
and periodic basis. They can be in the form of several routine, focused
assessments performed independently, or in concert with a pollution prevention
opportunity assessment or like project action, or as one comprehensive site
assessment.
Identify Assessment Team
The expertise of an individual or team of I T ,. .,] .,, ,
.,..,, , ,,, . ., Individuals responsible for
individuals should be consistent with , .,., r . , ,,
... . , , ., ,, facility assessments should
assessment objectives, the level of available ^^ assessment sMs
resources, and the complexity of the facility /. , ,. ~, ,.,., , ,,
v J J (including the ability to gather
being evaluated.
Tr ,.,..,,. ,. , ,, . through interviewing techniques
If a team of individuals is used it should consist , , , , Z \ -+1,
f . f ... ., , f . a/ra astute observations) with
of people familiar with the following:
factual, consistent information
sound understanding of the
processes and wastestreams
under evaluation.
> Process chemistry
* Engineering
> Equipment
* Standard operation and maintenance procedures
> Applicable environmental regulatory requirements.
At larger facilities, a team of several people will be needed to ensure that all
aspects of the facility can be adequately evaluated.
Once the team is formed, communication among members is of critical
importance. The team leader should have overall responsibility for the
assessment. This leader should maintain the focus of the evaluation and be able to
encourage communication so that background information and knowledge are
freely shared throughout the assessment process (i.e., pre-assessment, actual
onsite and follow-up assessment activities). It is important that, for each area
reviewed, at least one team member should be knowledgeable of the process
operations for that area. However, the assessment team should try to allow a
"fresh set of eyes" to evaluate a process. The person responsible for a particular
operation might be the most knowledgeable of day-to-day operations but not be
the best choice in identifying the significant compliance issues.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. i r
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Compile/Evaluate Background Information
The assessment team will need to collect the documents, such as permits,
manuals, regulations, and enforcement actions, required to perform the compliance
evaluation. These documents provide the information needed to characterize
facility processes (i.e., unit production operations) and identify known regulatory
requirements.
While State and Federal regulations require facilities to maintain and have available
many documents (e.g., shipping manifests, inspection records, discharge
monitoring records) useful in evaluating facility processes, the following have been
found helpful in identifying environmentally significant wastestreams:
> Mass balance worksheets (raw materials = input, waste/products=output)
> Facility map(s) showing buildings, unit production operations, and waste
management areas/operations
* Piping and instrumentation diagrams (P&IDs)
* Facility water/wastewater balance information
* Plant sewer map(s) showing all building collection systems, laterals and sewer
mains, and heat/material balance sheet(s) for the process(es)
> Operations manuals for specific processes
> 0 SHA Process Safety Management Manual for Highly Hazardous Chemicals
(required by 29 CFR 1910.119)
* List of emission points or wastestreams that have required or voluntary
monitoring (includes air, sewers, land, surface water)
> List of imported or exported feedstock, recydables, and waste materials
> Excess air emissions reports
> Pre-manufacturing notices (PMNs)
> Hazardous waste biennial reports
> Hazardous waste minimization reports
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. , n
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Life cycle analysis (products)
Spill logs
Process and operations reviews (PR/OPs) or hazard and operability studies
(HAZOPs)
Any startup, shutdown, or malfunction plan
Pollution prevention plan
Compliance Management System or EMS
Background information relevant to the Toxic Substance Control Act (TSCA)
(e.g., list of imported or exported feedstocks, recydables, and waste materials)
Past Emergency and Planning and Community Right-to-Know Act
(EPCRA) Toxic Release Inventory (TRI) reports and TRI data summaries for
similar facilities (i.e., similar facilities with dissimilar emissions might provide an
indication of pollution reduction opportunities).
Because one of the initial
activities in a process-based
self-assessment is an evaluation
of facility industrial processes
and supporting activities
relevant to the wastes^y-
products generated and
actual/potential environmental
impacts, an understanding of
facility operations (unit
production operations and
associated waste management
operations) is critical for a
successful evaluation.
Likewise, it is important to have at least a basic understanding of applicable, or
potentially applicable, environmental regulations. Therefore, in addition to
reviewing information relating to the primary evaluation objective(s), it is important
to compile and review background information regarding facility operations and the
facility's compliance history. It is also useful to prepare a pre-assessment
worksheet that serves as an internal check on the performance of all necessary
It may also be useful to contact industry-
specific trade associations and state technical
assistance providers to inquire about
audit/compliance guides or training manuals
that may be available for specific segments of
the industry. Appendix H of this guide
provides a comprehensive list of available
resources/references that may be of assistance
to organic chemical manufacturing facilities
during the conduct of a process-based self-
assessment. These references are organized
topically for ease of use.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-7
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pre-evaluation activities and can be used as a planning tool for pre-assessment
activities.
Prepare Assessment Plan/Strategy
The assessment plan/strategy ensures that team members are focused on the
assessment objectives, activities, assignments, and schedules and that required
information is obtained in an efficient
and effective manner. The breadth
and scope of the plan, which will vary
as a function of the assessment
objectives and the size and
complexity of the facility, can be fairly
To exemplify the potential value of
preparing a mass balance, a chemical
facility, as part of its EPCRA 313 report
preparation, prepared a mass balance to
approximate the emissions of chemicals
from its pro cesses. Th e facility w as
surprised to find that it was emitting
more than 1 million pounds ofmethanol
to the atmosphere via fugitive emissions.
Upon recognition of this problem, the
facility readily identified the source of its
methanol emissions to be product
separation centrifuges. Replacing these
centrifuges with a single vacuum filtration
unit reduced methanol emissions by
more than 99.9 percent.
simple or complex. Most plans will
include these items:
* General background information
on the facility, including
processes and known regulatory
issues
> Assessment objectives
> Assessment activities
> Team member responsibilities
> Tentative schedule for assessment activities, including dates for team meetings
> Health and safety plan, sampling plan, and/or quality assurance plan as
appropriate.
Exhibit 1-2 provides an example of an assessment plan worksheet.
For complex facilities, the assessment plan can also prioritize the individual unit
production operations used in the manufacturing processes and associated waste
management operations to be evaluated. The suggested strategy for evaluating
process operations is to conduct a material mass balance to follow material flows
through the plant (i.e., raw materials to wastes/products). Material flows should be
followed as far as possible, beginning with raw material receiving and storage and
continuing with manufacturing, utilities and maintenance, product storage, and
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-8
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Exhibit 1-2. Example Worksheet for a Process-Based
Self-Assessment Plan
Scope and Objectives of the Assessment
II. Assessment Activities
Actions to be taken
Processes to be evaluated
Individuals to be interviewed
Additional documents to be reviewed
Operations to be observed
Additional resources needed
III. Evaluators (provide the names of all members with needed expertise)
Team Leader
Clean Air Act Knowledge
Clean Water Act Knowledge
Resource Conservation and Recovery
Act Knowledge
Safe Drinking Water Act Knowledge
Emergency Planning and Community
Right-to-Know Act Knowledge
IV. Schedule
Team meetings
Onsite evaluation
Federal Insecticide, Fungicide, and Rodenticide Act
Knowledge
Toxic Substance Control Act Knowledge
Process Expertise
Facility Maintenance Operation Expertise
Other
Preliminary Report
Final Report and Action Plan
V. Background Information Review (provide comments on reviewed materials)
Shipping manifests
Previous assessments or inspection
reports
Discharge monitoring reports
Process block flow diagram(s)
Environmental permits
Operation and maintenance manuals
Applicable regulations
Mass balance worksheets
Facility map(s)
Piping and instrumentation diagrams
Facility water/wastewater balance
information
Plant sewer map(s)
Operations manuals for specific
processes
OSHA Process Safety Management
Manual for Highly Hazardous
Chemicals
VI. Additional Plans and Preparation Needed
Health and Safety Plan
Sampling Plan
List of emission points or wastestreams that have
required, or voluntary monitoring
List of imported or exported feedstock, recyclables,
and waste materials
Excess air emissions reports
Pre-manufacturing notices
Hazardous waste biennial reports
Hazardous waste minimization reports
Life cycle analysis (products)
Spill logs
Process and operations reviews or hazard and
operability studies
Any startup, shutdown, or malfunction plan
Pollution prevention plan
Compliance Management System or Environmental
Management System background information on
previous EPCRA Toxic Release Inventory
(TRL) reports and TRI data summaries for
similar facilities
Quality Assurance Plan
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-9
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waste management. Additionally, the strategy should include an overall facility-
wide component to evaluate potential site-wide environmental impacts or specific
facility-wide regulatory requirements (e.g., storm water control). The strategy
should be sufficiently flexible to allow for any needed mid-course corrections.
To ensure that the assessment team is familiar with the entire facility, a brief plant
orientation tour could be performed, during which each process to be addressed
is identified and responsibilities are assigned to each team member. The
assessment team should specify any safety equipment (i.e., hearing protection,
hard hats, safety boots, or respirators) needed during the assessment. Any areas
of the plant, activities, or process or control equipment that present a personal
hazard or require special training should be identified. Neither facility staff nor
team members should be placed in danger in conducting the assessment.
Preparation of a facility model with plant processes, production unit operations,
and associated waste management activities is often useful in clarifying the
evaluation strategy. Depending on the scope and objectives of the evaluation and
team experience, this model can be general or very detailed. A useful model form
is a process block flow diagram. This model should represent documented facility
conditions and Standard Operating Procedures (SOPs) that can be evaluated
against actual site conditions and operations during the visual assessment phase.
Exhibit 1-3 provides an example process model (i.e., a process block flow diagram)
with issues to be addressed.
Depending on the assessment objectives and focus, there may be a need for
sample collection. Samples might be needed for determining if a particular waste
stream is a regulated waste, for identifying sources of contamination, or for
demonstrating compliance as part of a specific program reporting requirement. If
deemed necessary, the assessment team should ensure that the proper staff
are available to collect samples and measures are in place for appropriate sample
analysis (e.g., sample plan and quality assurance plan). One distinct advantage that
a facility self-assessment has over regulatory inspections conducted by federal,
state, or local officials is that it is not necessary for sampling/monitoring
opportunities to be identified prior to the on-site assessment. Sampling/monitoring
opportunities can be identified as part of the on-site assessment and then
scheduled at a convenient time.
Finally, as part of assessment plan preparation, the team should determine if an
evaluation checklist is needed for use during the site assessment and records
review. The checklist can be general, used more as a means of tracking specific
topics to address, or it can be detailed, identifying specific requirements and
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. 1 -1 D
-------
Exhibit 1-3. Process Block Flow Diagram
chlo
hi ~
makeup benzene
catalyst
Example Questions:
1 . How often is
2. Can the amoi
thereby reduc
3. Can the spen
a marketable
Other Concerns:
Often, documented
which may be differe
recycled feedstock distillation columns
HCI to scrubber I I
rination | alkylation
1
r r
// ^^V
/ , i ,
!,
benzene recycle water " °
1
phase
separation
mt of acid used for washing product be reduced
ing the amount of spent acid?
acid be recycled back to process? If not, is the spent acid
product?
operating procedures for a given process are different than the procedures identifiec
nt than what is actually occurring. Direct observation of actual procedures may be
washed product
*
T
raw acid
high boilers
>-
*
spent catalyst
by a plant supervisor, both of
warranted in some instances.
process operations and listing information needs (e.g., regulatory thresholds,
control options, or waste discharge standards). A checklist is particularly helpful
where the facility is subject to many different regulations and permits.
1.4 CONDUCTING THE SELF-ASSESSMENT
The initial focus and a
continuing activity throughout a
process-based self-assessment
is obtaining a comprehensive
understanding of how facility
manufacturing processes/facility
activities relate to regulated
wastes/activities and/or
environ-mental issues. Exhibit
1-4 shows the areas of focus
for a process-based evaluation.
The most in-depth application
of this method is preparation of
a material/mass balance for
each production unit. This
Exhibit 1-4. Areas of Focus for a
Process-Based Evaluation
Raw Materials
Unit Production
Operations
Products
By-Products
Routine
Production
Wastes
\
Wastes from start-up,
shut-down, and
maintenance, etc.
Multi-media process-based assessments focus
on a comprehensive understanding of the facility.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-11
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procedure identifies the raw materials entering the production unit and the
products, intermediates, and all environmentally significant wastestreams exiting
from the system. Exhibit 1-5 identifies key points that could be addressed in a
focused assessment.
Process-based evaluations, like most other types of assessment, can be separated
into various onsite evaluation activities, including the following:
> Evaluation of facility processes
* Document review
> Visual assessment.
For simplicity, each of these steps is discussed below individually. However, a
process-based assessment is dynamic, commingling these three elements based on
site-specific considerations best identified during the actual assessment.
Evaluation of Facility Processes
Evaluation of facility processes is usually
accomplished in two steps:
1. In-depth discussion of specific plant
processes with facility engineers (and
other knowledgeable personnel) using
process flow diagrams/P&IDs
2. "Fine tuning" of facility knowledge
throughout the remaining part of the
evaluation through document review, ^^^^^^^~^^^^^^^~
visual assessment, further discussions with facility personnel and assessment
team interaction (for relatively simple facilities these steps can be combined).
Given the amount of interaction
among processes, intermediate
streams, products, and utilities at
organic chemical manufacturers,
the need for effective
communication among
assessment team members is
crucial to a successful pro cess-
based evaluation.
The facility evaluation can be
conducted by a complete team or by
smaller groups, depending on
personnel, assessment objectives,
and available resources. The
assessment team should ensure that
knowledgeable personnel are being
interviewed about plant opertations.
These personnel are usually the
To identify other evaluation
procedures, it may be useful to consult
outside sources of information. For
example, consultation with trade
associations may provide insight into the
latest pollution prevention opportunities
for a given process operation.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-12
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Exhibit 1-5. Key Points an Evaluator Could Verify
for Clean Water Act Compliance
Are the facility's operations properly regulated by a permit?
Are the facility's monitoring results representative of a facility's operations?
> Are the monitoring procedures consistent with 40 CFR Part 136 procedures?
* Have analytical results reported as "Not Detected" been analyzed down to the requisite quantification
level?
Have there been changes in the facility's operations?
* If so, was proper notification given to permitting the authority?
Are the flows reported by the facility reasonable?
* Are the reported process and non-process flows accurate?
> Are sound water conservation practices employed throughout the facility, as applicable?
* Are the flows observed consistent with the values used to calculate permit limits?
Are proper Operations and Maintenance (O&M) practices and good housekeeping practices in place to
ensure compliance and consistent treatment plant performance?
> Do backup systems or procedures exist for the period when system O&M is being conducted?
* Does the facility have adequate staff to operate and maintain the treatment system?
> Do areas that have a high potential for spills or leaks have spill containment?
* Does the facility need a spill prevention, containment, and countermeasure (SPCC) plan?
> If so, is an SPCC plan on file and is it adequate to meet facility needs?
* Does the facility have any other spill or slug control plans?
Has the facility had any spills of oil or other hazardous substances, and if so, have the following questions been
answered:
* What was the material?
> What was the quantity of this material?
* What was the reportable quantity?
> What was the response for containment, cleanup, and notification?
* What were the health and safety issues?
> What is the facility's plan to prevent recurrence?
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. 1 -1 S
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production unit managers, shift supervisors, production engineers, and unit
operators, but they can include environmental staff.
Interview Process. The process evaluation usually begins with interviews of
production unit managers, shift supervisors, production engineers, and unit
operators. The assessment team members may be knowledgeable about certain
areas of the facility and can provide some of the necessary information, but their
knowledge should not preclude the assessment team from questioning production
unit managers and production engineers on their areas of expertise. Often, the
fresh perspective of the assessment team can provide new insight into compliance
assurance programs and pollution prevention opportunities. The information
obtained during the interview process is later verified by documentation review
and visual assessment.
Interview Topics. The initial process interviews are best done in a quiet office or
conference room, not in the noisy process area. Block process flow and/or P&ID
diagrams are reviewed, starting with raw materials received and continuing with
material handling, processing, product/by-product handling, and waste generation
to confirm all information and ensure that no products, by-products, co-products,
residues, or waste streams have been omitted, eliminated, or misidentified. The
generic/specific process information compiled during background information
compilation/evaluation should be used during interviews and plant tours to ensure
that all facets of the process and resulting waste streams are discussed.
Products and wastestreams under assessment should include all emissions to the
atmosphere, liquid discharges, and solid materials generated by or removed from
the production unit operations. Throughout this manual, the terms product, co-
product, by-product, or waste are used to mean all physical states (i.e., gaseous,
liquid, and solid) that apply. This is particularly important to note in discussions on
the significant releases and associated regulations for different production units and
waste treatment operations discussed in Modules 2 and 3. In this manual, "waste"
will be used to describe gaseous, liquid, or solid materials for reuse, treatment, or
disposal.
Itemized below are some often overlooked issues/processes and activities:
> Recyclable material streams might be wastes even though they are not
disposed of.
* Startup, shutdown, or turnaround operations might generate wastestreams or
off-spec products that become wastestreams or off-spec products that become
wastes.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. 1-14
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Process equipment cleaning operations might generate cleaning wastes and
spent unit production components (e.g., distillation column packing materials).
Process upsets could result in different waste characteristics than typical wastes
generated.
Facility support activities, such as maintenance, research facilities, and
laboratories, might not be considered facility processes, but they usually
generate/manage regulated wastes and could be included as part of facility
operations evaluations.
Chemical storage
areas/mixing rooms often
contain many types of
substances/raw materials used
onsite (material safety data
sheets [MSDS] contain
valuable information regarding
chemicals used onsite) and
can be the source of spills and
releases.
Facility utilities, such as
boilers, power generators,
and water treatment systems,
often generate regulated
wastes.
The condition and age of plant sewers are
of environmental interest, especially at
older plants. Leaking sewers can be
contaminating the underlyinggroundwater
and can constitute illegal waste disposal.
Conversely, infiltration/inflow into old
sewers can dilute concentration and
confuse compliance status, increase
treatment costs, and/or reduce
reclamation opportunities. Wastestreams
discharged to non-municipal sewer
systems can be subject to RCRA
hazardous waste and land disposal
restriction determinations. Consequently,
questions should be asked about sewered
wastes, sewer inspection and repair
programs, and inspection/repair records.
* Contractor activities, such as
construction/demolition, or maintenance, can result in
environmental/noncompliance problems.
The interview process can be time consuming, but needs to be sufficiently detailed
and thorough so that all environmentally significant wastestreams are identified
within the objectives and scope of the assessment. When the assessment team
determines that the unit production operations are adequately understood, the
wastestreams have been identified, and waste management practices have been
discussed, it is usually time to proceed to other areas of inquiry.
One activity within a process-based assessment should be to develop waste
worksheets for wastestreams identified during the assessment. Exhibit 1-6
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-15
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provides a sample worksheet. These worksheets can be refined through the
assessment process.
Each wastestream(s) can then be identified on
the model process block flow diagram to
provide a comprehensive depiction of facility
waste generation and management. The
assessment team will need to note that some
wastestreams (e.g., gaseous emissions) can be
treated at the source, while other wastes (e.g.,
liquid discharges) can be collected from sources
throughout the facility for treatment by one
centralized onsite treatment system.
Document Review
Two statutes, EPCRA and
TSCA, are primarily
information reporting and
record keeping laws.
Evaluation of compliance
with these statutes can be
accomplished almost entirely
through the document
review process. Specific
assessment considerations
for organic chemical
manufacturers for EPCRA
and TSCA are identified in
Appendix E and Appendix
G, respectively.
Document review can be used to supplement
process knowledge obtained during the in-depth
evaluation of facility. Through this review, the
assessment team can verify previously provided
information on facility operations and identify actual or potential environmental
problems. More specifically, the assessment team may use the documents to
verify and quantify the following:
* Wastestreams recycled back to process
* Wastestreams released to the environment (e.g., EPCRA data)
* Wastestreams collected for onsite/offsite treatment/disposal (e.g., Discharge
Monitoring Report (DMR))
Document review can also be used to verify compliance with monitoring, record
keeping, and reporting requirements as well as to ensure that the records are
consistent with actual facility operations.
Visual Assessment
Verifying process information generally involves inspecting and further discussing
actual facility operations and waste management areas to ensure nothing has been
overlooked during interviews or omitted from the flow diagrams. For facilities that
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-16
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Exhibit 1-6. Sample Emission Worksheet
EMISSION WORKSHEET NO. 001
1. NAME OF WASTE: Spent aluminum chloride catalyst.
2. TYPE OF WASTE: Liquid waste (by-product sales).
3. PROCESS THAT GENERATED THE WASTE: Alkylation reaction of chlorinated paraffins and benzene.
4. AMOUNT AND FREQUENCY OF WASTE GENERATION: Approximately 6,000 gallons a day,
generated continuously during process operations. There is very little deviation in the volume generated.
5. ONSITE MANAGEMENT PRACTICES FOR THE WASTE: Distillation bottoms are water washed and
then phase separated into aluminum chloride liquor and a hydrocarbon phase. The aluminum chloride
liquor is activated carbon filtered and shipped out to customers in tank trucks. See aluminum chloride
activated carbon emission worksheet (No. XX) for waste description.
Tank truck drivers are instructed to inspect each load of liquor for an oil layer prior to departure. When
identified, these loads are discharged into a 20,000 gallon holding pit and then bled into the plant
wastewater treatment system.
6. OFFSITE MANAGEMENT PRACTICES FOR THE WASTE: Filtered aluminum chloride liquor (32° Be)
is loaded into tank cars and sent to a customer for a component in roofing granules.
7. LENGTH OF TIME THIS WASTE HAS BEEN GENERATED: This waste has been generated since
plant operations began in 1978.
8. CHANGES IN THE GENERATION OF THIS WASTE: In 1988, the washing process was modified to
strengthen the solution to generate a 32° Be aluminum chloride liquor suitable for resale. Prior to that
time, a more diluted liquor was sent to the onsite wastewater treatment system and then discharged to
the local POTW.
9. APPLICABLE REGULATORY REQUIREMENTS FOR THIS WASTE: As a by-product, this stream is
not subject to regulatory requirements. During upsets (i.e., when the liquor contains visible amounts of
oil), this waste is commingled with other plant wastewater and is subject to the wastewater discharge
permit conditions, as issued by the municipal wastewater treatment plant (WWTP). One special permit
condition exists for this waste. Specifically, the WWTP is to be notified in advance, and approval given,
prior to bleeding the aluminum chloride solution into the onsite wastewater treatment system.
10. HOW FACILITY IDENTIFIED APPLICABLE REGULATIONS: The WWTP performed an inspection of
the plant in 1993 and identified this wastestream as an infrequent discharge. The latest permit from the
city, issued in 1995, includes the requirement to notify prior to discharging waste liquor.
11. MONITORING DATA FOR THIS WASTE: The customer that purchases this liquor requires that a
semiannual sample be collected and analyzed for specific gravity, total organic carbon (TOC) and metals.
Results of these analyses are kept in the waste monitoring data files.
12. CONSISTENCY IN APPEARANCE OF THIS WASTE: This waste has a consistent appearance.
Occasionally (i.e., about twice a year), the liquor will have an oily sheen, as discussed in item 5 above.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. 1-17
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manufacture only one or two chemicals, the visual assessment can be performed
starting at raw materials receiving and proceeding to product shipping and waste
treatment/disposal. However, for more complex integrated facilities, the
delineation may not be as simple. In these instances, it is still important to maintain
an organized process for progressing through facility operations, although it may be
specific to a product or product line rather than on a facility-wide basis. Model
process block flow diagrams, developed during the assessment planning phase, are
ideal for guiding the site assessment. The information should be verified and
updated as necessary during the visual assessment. At each specific area, the
evaluation team should verify the flow diagram and the process description and
should be sure that all incoming materials are properly accounted for as products,
intermediates, or wastes (e.g., gas, liquid, solid). Photographs can be valuable for
documenting plant operations, and for use in making comparisons during future
facility evaluations.
Continuous or Routine Process Operations. For each process operation,
gaseous (both vented and fugitive emissions), liquid, and solid waste generation
issues should be evaluated. The assessment team should be alert for operations
not identified on existing documentation. In particular, all wastestream(s) should
be properly identified and characterized. It is possible that wastestreams may have
been inadvertently omitted or mislabeled. This is particularly true for wastes
generated intermittently (e.g., distillation column bottoms or reactor vessel
deanouts). While in the process area, the assessment team should look at each
unit operation shown on process flow diagram(s) to verify or identify points of
wastestream generation, including the location of all pits, sumps, piping, vents, and
stacks.
The site assessment should include an evaluation of ancillary process areas that may
also be subject to environmental regulation or contribute to a environmental
compliance problem. These include plant utilities (e.g., water treatment, boilers,
and cooling towers), research and development operations, pilot plants, laboratory
bench-scale operations, and technical services.
Periodic or Non-routine Process Operations. While in process areas, it is
important for the assessment team to ask operators about the types and frequency
of upsets and how materials are managed in those situations.
Team members need to be constantly alert for operations, processes, materials,
tanks, and waste management activities not previously identified or discussed.
These could also include any unusual, unmarked, or unexplained drums, tanks,
piping, or ventilation, which could reveal process or waste handling activities not
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. 1-18
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previously discussed. If discovered, the function and purpose should be
determined.
Waste Management Operations. All waste treatment systems associated with
process or maintenance wastes (gas, liquid, and solid) should be evaluated.
Treatment system operators should be asked about upsets, influent and upstream
monitoring, alarm locations and types, by-pass capabilities and monitoring, and
notification procedures conducted by production staff during periods of upset or
malfunction. (The degree to which there is effective communication among the
various facility personnel can suggest the likelihood of treatment system upsets.)
Property Line/Storage Areas. The visual assessment should also include a
property line assessment to look for stressed vegetation, potentially unregulated
emissions, sensory concerns (e.g., visual, audible, or olfactory), and emissions from
other facilities that can be affecting the facility under review. Additionally, lagoons,
pits, leaks from piping, and materials storage tanks should be included in the
property line assessment. This information should be evaluated to determine the
applicability of any regulations. Identified below are indicators of potential releases:
* Rusty or deformed drums
> Puddles under and around units
* Leaking valves on tanks
> Strong odors
* Dead vegetation
> Erosion.
Sampling/Monitoring
As with other assessments, sampling
or onsite monitoring concurrent
with the self-assessment can be
useful in correlating information
about facility operations, waste
generation, and waste management
activities. Exhibit 1 -7 lists some of
the results that may be achieved
through sampling and monitoring. The
identification of clear objectives,
adequate design of a sampling plan,
and Quality Assurance/Quality
Control (QA/QC) all are dependent
upon the nature and scope of the
Laboratories should be aware that
each regulatory program specifies
applicable sampling and analysis
procedures such as:
ť RCRA uses "SW846 Methods,"
* CWA uses "methods as specified in
40 CFR Part 136,"
* TSCA uses methods specified in 40
CFR Parts 792-799.
A common phrase on laboratory
analytical reports, "samples analyzed
using EPA approved methods," does
not necessarily demonstrate
compliance.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-19
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assessment. The assessment team should determine if the routine
sampling/monitoring done to fulfill regulatory requirements (i.e., permit
requirements , sample collection, transport, and analyses methods) will be part of
the multi-media, process-based self-assessment and/or if additional
sampling/monitoring will be conducted. While regulatory agencies sometimes
collect samples to evaluate compliance, sampling/monitoring as part of a self-
assessment can be used to gather information for "beyond compliance" activities,
such as to identify sources of contaminants that could lead to process
improvements or activities for pollution prevention opportunities. One
component of proper sampling/monitoring techniques often overlooked is the
calibration of equipment, including documenting the calibration. Monitoring
conducted with uncalibrated equipment is invalid for compliance demonstrations.
Monitoring may also be invalid if it is conducted with calibrated equipment but no
documentation of the calibration exists.
1.5 ASSESSMENT FOLLOW-UP
Similar to regulatory inspectors or a
corporate auditing team, the team
conducting a process-based self-
assessment should prepare a report
documenting the findings of the
assessment. The team should include
as much detail as is reasonably
practicable. The report should be
addressed to facility management and
should also be distributed to
supervisors responsible for the
processes and areas evaluated,
including both unit production
operations and waste treatment
operations.
Exhibit 1-8. Example Tasks
Achieved Through Sampling and
Monitoring
Sampling or monitoring may be necessary
to do the following:
> Identify the source of fugitive emissions
> Document hazardous waste
classifications
> Determine product yield and efficiency
> Identify toxic and hazardous reaction
by-products
> Demonstrate compliance with permit
limitations
> Identify the contents of unmarked
drums and containers
> Identify the makeup of spills and stains
> Classify unpermitted emissions.
The report should include
recommendations that address the
report findings, prioritized for rapid
response to the most urgent needs.
Either as part of the report or as
immediate follow-up to the report, the team leader should get management to
identify a responsible person for each area of concern identified and dates for
resolution of each item. Where possible, the report should also identify the root
cause for any identified problems. This is useful if similar problems are identified by
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-20
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regulatory inspectors who want an immediate explanation. The ability of facility
personnel to provide a ready explanation of the cause of any identified problem
and actions taken to correct the problem may help avert enforcement action by
the regulatory agency.
Upon the resolution of problems, the facility should include documentation of
corrective steps taken, along with the self-assessment report to demonstrate that
the facility addressed identified areas of concern in a timely manner. Resolution of
the problems identified and documentation of this resolution are important.
On December 18, 1995, the EPA Assistant Administrator for Enforcement and
Compliance Assurance signed a policy that affects companies which voluntarily
identify, disclose, and promptly correct violations. For such companies, EPA will
substantially reduce or eliminate the civil penalties it would normally seek (60
Federal Register 66706, December 22, 1995). Effective January 28, 1996, EPA
will not seek gravity-based penalties for violations discovered either through
environmental audits or the use of compliance systems to prevent, detect, and
correct violations provided that all the conditions of the policy are met. This policy
does not apply to violations that:
> involve an imminent and substantial endangerment or serious actual harm to
public health or the environment
> are repeat violations that have occurred over the past 3 years, or
* are a pattern of Federal, State, or local violations that have occurred within
the past 5 years.
EPA reserves the right to collect the economic benefit of noncompliance (i.e., the
amount gained as a result of not complying with environmental requirements). In
instances where the facility cannot fully meet the conditions of the policy, but
where the violations have been voluntarily discovered, promptly disclosed, and
corrected, EPA will reduce the gravity-based penalty by 75 percent. EPA can
assess penalties reflecting the economic benefit gained while in violation.
Additionally, EPA will not recommend criminal prosecution for violations disclosed
through voluntary environmental audits. This policy states that EPA will continue
with its practice of not requesting a voluntary audit report in order to initiate a civil
or criminal investigation.
Finally, when addressing areas of concern, the facility should consider pollution
prevention options to resolve the problem. Pollution prevention solutions may be
identified by facility personnel, or the facility may want to contact trade associations,
industry experts, or state technical assistance provide for assistance. Appendix H
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \-7\
-------
identifies some of the pollution prevention resources applicable to the organic
chemical manufacturing industry.
1.6 ENVIRONMENTAL MANAGEMENT SYSTEM CASE STUDY: CIBA-
GEIGY CORPORATION
Many of the leading businesses, especially within the chemical industry, implement
EMSs as a component of the facility's overall management practices to ensure
compliance with environmental regulations. To foster implementation of
innovative, effective EMSs and to recognize organizations confirmed to be
implementing such systems, EPA announced a new initiative entitled the
Environmental Leadership Program (ELP) in the Federal Register on June 21, 1994.
The first phase of developing and implementing the new program was to conduct
a series of ELP pilot projects, to help define "environmental leadership" and
determine the components of the long-term leadership program. Through the
ELP pilots, EPA, State agencies, and certain facilities have worked together to
demonstrate and evaluate systems used to assure compliance within the existing
regulatory framework, and environmental initiatives which go beyond minimum
requirements. Among the 12 proposals selected for the ELP pilot was one
submitted by the Ciba-Geigy Corporation, St. Gabriel Plant, a manufacturer of
organic chemicals. The Ciba St. Gabriel Plant proposal demonstrates
environmental leadership through environmental management systems including
the use of formal and informal self-assessments.
By studying Ciba St. Gabriel's environmental management systems, multimedia
compliance assurance and community outreach/employee involvement programs,
the ELP Team has worked to identify the essential program elements that
constitute model programs. These models can be adopted and implemented by
other facilities and agencies to assure compliance with regulations and company
policies, and promote continual improvement in overall environmental
performance.
Ciba St. Gabriel's philosophy is that to ensure compliance with regulatory
requirements, a facility must develop internal programs that go beyond
environmental regulations. The Ciba St. Gabriel facility implements both
management systems and multimedia compliance assessments. Formal audits
ensure compliance with environmental requirements as well as reveal
opportunities to go beyond compliance. In addition, Ciba St. Gabriel believes that
to be an "environmental leader," a model facility must maintain periodic and
routine self-assessment, implemented by committed employees. Ciba St.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
Gabriel's compliance assurance system contains multiple self-assessment elements
involving a variety of groups at all levels in the site organization.
The following templates have been developed by Ciba St. Gabriel. These
templates represent a general self-assessment and management and compliance
audit approach that can be applied to a variety of process and activity assessments.
In addition, an example application is also included to demonstrate how the
general template has been applied to a specific Ciba St. Gabriel activity: waste
container inspections.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. ]-?^
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GENERAL SELF-ASSESSMENT TEMPLATE
Introduction
A self assessment system must include the following aspects in order to:
be effective;
ensure compliance; and
go beyond compliance
Reviews and
Inspections
A self-assessment program must consist of both informal & formal reviews & inspection
Of
DATA
PROCESS/OPERATIONS
OFF-SITE STORAGE FIRMS
By
SELF/CO-WORKERS
SUPERVISION
NON-SUPERVISORY STAFF GROUPS
Common
Self-Assessment
Aspects
Elements
Training
Communication
Feedback
Measurement
Tracking
Distribution
Corrective
Action
Accountability
Action Level
Application
Training on regulatory requirements and self-assessment goals &
techniques
Communication of problems and successes and associated
improvements or changes
Feedback to management of problems & incorporation into training
The item(s) being assessed must be measured in a systematic and
quantifiable manner, as applicable
The item(s) being measured must be tracked, usually by a plant-site
expert
Timely distribution of tracking report, including problems, to both
management and users
Immediate correction of problems or development of an action plan
that addresses the problems
Accountability for results and improvement may be tied to
performance process
Setting internal action limits at levels that are more conservative
than regulations require
Application of specific findings among units and across facility
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-24
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EXAMPLE TEMPLATE FOR MANAGEMENT & COMPLIANCE AUDIT
Introduction
To be effective, a management and compliance audit, as opposed to an inspection, must
have some key components.
Key Components
Use a "Fresh
Pair of Eyes"
Systematic
Review
"Root Cause"
Determination
Audit Systems
Action Plan
Apply
Specific
Findings
Broadly
Focus the
Audit
While other self-assessment elements may be done "internally" by
those responsible for compliance, the audit should be "external" from
the direct line of responsibility. Examples are a corporate group, such
as TRAC [Toxicology and Regulatory Auditing and Compliance];
another site within the company, or a third party, such as an
independent ISO [International Standards Organization] auditor.
Review compliance to both environmental regulatory requirements
and corporate policy
Investigate and determine cause of a compliance deficiency and
attempt to isolate the cause (i.e., training, lack of appropriate
management system, unclear responsibilities)
An audit should go further than compliance. It must look at
management systems, including internal policies and procedures.
The audit should verify that:
1) systems are in place,
2) systems are understood,
3) systems are implemented, and
4) internal policies & procedures are being followed
Generate an action plan with dates and responsibilities. The action
plan should be maintained until all items are complete. The action
plan should periodically be reviewed by management.
Most, if not all, specific findings should be applied to similar situations
in the facility. A problem that occurs in one area is likely to occur in
other areas also. For example, if the audit discovers that training
records are not readily accessible in one area, at least three items
should appear on the action plan. First, the area involved should
correct the problem so records are readily accessible. Second, other
similar areas in the plant should review their records to verify they are
accessible. Third, the management system for training records should
be reviewed.
Focus on new areas of regulations, areas with rapidly changing
regulations, or areas of past problems. For example, 1996 may be a
good year to focus on Air with the new Title V regulations coming into
effect, which means systems are being developed, or changed in
order to implement the Title V program.
Results of the audit must be made available not only throughout the
facility, but throughout the corporation, including top management.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-25
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EXAMPLE TEMPLATE APPLIED TO WASTE CONTAINER INSPECTIONS
Introduction
Ciba has a mature waste container inspection program. It includes a formal written
procedure and a weekly inspection of all containers and storage areas in the plant by
waste management specialists.
Informal Reviews and
Inspections
Formal Reviews and
Inspections
Of
CONTAINERS
CONTAINERS
By
SHIFT CO-WORKERS AND SUPERVISORS
(PERIODICALLY)
UNIT WASTE COORDINATOR (DAILY ROUNDS)
ENVIRONMENTAL GROUP (WEEKLY)
Self-Assessment
Aspects for the
Container Management
Program
Element
Training
Communication
Feedback
Measurement
Tracking
Distribution
Corrective
Action
Accountability
Applied to Container Management
Training requirements are covered in the Plant Environmental
Procedure L-7 "Container Management." The purpose of this
management procedure is to ensure compliance with the container
management requirements. This training is required for all St.
Gabriel personnel.
Container management issues are communicated among areas so
all can learn from other events. Some are reviewed in safety
meetings or training sessions as applicable.
Containers are reviewed against a checklist of items. Deficiencies
noted by the Environmental Group are reported by area and by
general cause which may include:
> labeling
> dating
> aisle space
The items measured are tracked by the environmental group using
spreadsheets and graphs, charts, and statistics. The results are
compared between units and to past years' data.
The tracking report is distributed weekly to all areas and plant
supervisory personnel.
Any corrective action required is taken immediately. The
"inspector" notifies the unit which immediately takes actions to
correct the deficiencies. Items that need long-term plans are
tracked to completion.
Reporting of deficiencies throughout the plant plus emphasis
placed by management on inspection results provide individual and
unit accountability. Container management may be added as an
annual performance objective for some people with improvement
measured.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-26
-------
Self-Assessment
Aspects for the
Container Management
Program (Continued)
Element
Action Level
Application
The report itself tracks deficiencies, using an extremely
conservative approach. For example, if a label is fading to the point
where any inspector might question if it is completely legible, it
would be counted as a deficiency. In addition, items that are not
deficiencies but may need attention are listed in the report. For
example, a damaged label, a label that was starting to fade, or a
drum stored for 70 days in a 90 day storage area may be listed in
the report. Including such items in the report will highlight the need
to take action to prevent deficiencies.
Plant wide tracking and communication helps ensure that if a
deficiency occurs in one area, it is communicated to other
areas, so that trends and problem areas can be identified and
preventative measures taken before a deficiency occurs.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
1-27
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MODULE 2. ASSESSMENT TOOL FOR
PRODUCTION UNIT PROCESSES
INTRODUCTION
This section describes production unit processes that are common to the organic
chemical manufacturing industry. Specific unit processes are classified as materials
handling, reactions, heat transfer, or separation operations.
This module includes summaries on the following production unit processes:
2.1 Materials Handling
> Pipes, Valves and Connections
> Pumps, Compressors and Steam
Jet Ejectors
> Storage Tanks, Containers, and
Vessels
> Blending and Milling
2.2 Reactions
> Batch, Continuous and Fluidized
Bed Reactors
2.3 Heat Transfer
> Heat Exchangers
> Condensers
> Evaporators
2.4 Separation
> Distillation
> Ion Exchange
> Filtration
> Drying
> Crystallization
> Centrifugation
> Extraction
Potential significant releases/emissions are identified for each of the common
production unit processes identified above. Potentially applicable environmental
regulations are indicated, by CFR Part and Subpart, for each corresponding
release/emission type. The universe of media-specific regulations potentially
applicable to organic chemical manufacturing facilities are identified in Exhibit 2-1,
the Clean Air Act (CM); Exhibit 2-2, the Clean Water Act (CWA), and Exhibit 2-3,
the Resource Conservation and Recovery Act (RCRA). Note that these potentially
applicable regulations do not specify State requirements that may be applicable
(and more stringent) to an individual facility, nor do they cite the permitting
regulations
under which
EPA or States
issue facility
specific
permits.
Assessment Tool for Production Unit Processes
2.1 Materials Handling 2-5
2.2 Reactions 2-16
2.3 Heat Transfer 2-21
2.4 Separation 2-30
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-1
-------
Exhibit 2-1
Potentially Applicable CAA Regulations
Subpart D
Subpart G
Subpart H
Subpart K
Subpart GG
Subpart W
Subpart III
Subpart NNN
Subpart RRR
Part 61 - Hazard
Subpart F
Subpart ]
Subpart M
Subpart V
Subpart Y
Subpart BB
Subpart F
Part 63 - Source
Subpart F
Subpart G
Subpart H
Subpart I
Subpart Q
Steam Generators
Nitric Acid Plants
Sulfuric Acid Plants
Petroleum Storage Vessels
Stationary Gas Turbines
VOC Equipment Leaks
Air Oxidation Processes VOC Emissions
Distillation Processes VOC Emissions
Reactor Processes VOC Emissions
Vinyl Chloride
Equipment Leaks of Benzene
Asbestos
Equipment Leaks
Benzene Emissions from Benzene Storage Vessels
Benzene Emissions from Benzene Transfers
Benzene Waste Operations
Organic HAPs from Synthetic Organic Chemical Manufacturing Industry
(SOCML)
Organic HAPs from SOCMI Process Vents, Storage Vessels, Transfer
Operations, and Wastewater
Organic HAPs for Equipment Leaks
Organic HAPs for Equipment Leaks for Certain Processes
Regulation)
(Negotiated
HAPs for Industrial Process Cooling Towers
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-2
-------
Facilities should refer to their State environmental agency to identify any differences
between State and Federal program requirements.
Exhibit 2-2
Potentially Applicable CWA Regulations
Effluent Limitations Guidelines and Standards
40 CFR Part 414
40 CFR Part 439
40 CFR Part 454
40 CFR Part 455
Organic Chemicals Plastics and
Synthetic Fibers
Pharmaceuticals
Gum and Wood Chemicals
Pesticide Chemicals
Exhibit 2-3
Potentially Applicable RCRA Regulations
40 CFR Part 261
40 CFR Part 262
40 CFR Part 263
40 CFR Part 264
40 CFR Part 268
40 CFR Part 280
Hazardous Waste Identification
Hazardous Waste Generators
Hazardous Waste Transporters
Hazardous Waste Treatment, Storage,
and Disposal
Land Disposal Restrictions
Underground Storage Tanks
Federal and State permitting regulations and requirements are described in the
following sections of 40 CFR:
Statute
CAA
CWA
RCRA
Permitting Cftation
Parts 70-72
Parts 122-125 and 403
Parts 270-272
Also note that the potentially applicable regulations cited exclude several
regulations that are specific to a very defined subset of the chemical manufacturing
industry (i.e., regulations are based on specific processes or products). (See
Exhibit 2-4.) Facilities that may fit into any of these categories should refer to the
specific regulatory citation to assess specific requirements.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
Exhibit 2-4
Additional Regulations That May Apply
CAA Part 60
Subpart DDD
Standards of Performance for VOC Emissions from the Polymer
Manufacturing Industry
CAA Part 60
Subpart HHH
Standards of Performance for Synthetic Fiber Production Facilities
CAA Part 63
Subpart W
National Emission Standards for Hazardous Air Pollutants for Epoxy Resins
Production and Non-Nylon Polyamides Production
RCRA
Part 266 Subpart H
Part 279
Hazardous Waste Burned in Boilers and Industrial Furnaces
Standards for the Management of Used Oil
CWA
Part 41 5
Part 417
Part 428
Part 443
Part 446
Part 447
Part 457
Part 463
Inorganic Chemicals
Soaps and Detergents
Rubber Manufacturing
Paving and Roofing Materials
Paint Formulating
Ink Formulating
Explosives Manufacturing
Plastics, Molding and Forming
Additional environmental statutes (i.e., the Safe Drinking Water Act (SDWA),
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Emergency Planning
and Community Right-to-Know Act (EPCRA), and Toxic Substances Control Act
(TSCA)) that apply to organic chemical manufacturing facilities are not summarized
or referenced in Module 2 since regulations developed under these statutes are
not unit process or waste treatment type specific. Regulations developed pursuant
to these statutes that may apply to organic chemical manufacturing facilities are
summarized in the Appendices.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-4
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2.1 MATERIALS HANDLING
2.1.1 PIPES, VALVES, AND CONNECTIONS
Toint and Valve Head Leaks
The most common source of leaks of
both gaseous and liquid material occurs at
all joints and at valve heads during routine
movement of gaseous, liquid or even
solid materials. These leaks, particularly
for gases, may be too small, or too
remotely located, for easy location and
repair.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
volatile HAPs
Part 61, Subpart BB for benzene
emissions from benzene transfer
operations
Part 63,Sitt|!patt F for hazardous organic
NESHAPs
Part 63,Sildjpart:t H for hazardous organic
NESHAPs from equipment leaks
Many plant operations have traditionally
accepted "small" leaks as the customary
way of operating. Current thinking is to require routine monitoring, such as with
field meters or even by dogs, to detect leaking equipment/components and to limit
the allowable rate of loss by the use of local secondary containment such as double
glands or housings on valves.
Sampling valves may yield additional waste material (gas, liquid or solid) before and
after sampling as a means of assuring that material is representative or resulting from
pressure changes; the impact of such losses can usually be minimized by
collecting the material for reuse or redesigning the sampling system to minimize or
eliminate the need for such waste.
Leakage due to incipient failure of piping is usually addressed by plant personnel
before it becomes catastrophic, and double walled piping is now required in
certain applications to minimize ground and air contamination. Leaks in pipes, at
flanges, and at valves are most likely to be discovered during the startup or
shutdown of process equipment due to changes in pressure, vibration, and thermal
changes.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-5
-------
Equipment Cleanout
Material trapped in valves and pipes
when dismantling equipment for
maintenance should be removed by
purging and/or decontamination. The use
of air or water to accomplish this purging
can produce airborne streams and wastewater that escape with no control or
contribute to fluctuations in wastewater characteristics.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., Part 414 for
organic chemicals)
Maintenance Operations
Maintenance operations also can generate
gaseous, waterborne and solid emissions
expected from maintenance activities such
as paint stripping, sandblasting, painting,
welding and cutting operations, and
lubrication. Maintenance operations may
result in the disposal of equipment (e.g.,
valves, gaskets, lengths of pipe, etc.);
decontamination is desirable but is often not done since the piece is being
discarded. This results in the item being hazardous or contributing to the
characterization of other wastes as hazardous.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart H for hazardous organic
NESHAPs for equipment leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., Part 414
for organic chemicals)
Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., Part 414
for organic chemicals)
Catastrophic failure of pipes due to
flange/joint failure and corrosive or
erosive failure can produce rapid and
large volume discharge of the contents.
Secondary containment is not usually
present, resulting in secondary contamination of the ground and neighboring
equipment that also must be cleaned. Even where containment exists, rapid
discharge, often under emergency conditions, may overwhelm the capacity of
pretreatment facilities.
Air emissions may be immediately hazardous to the health of workers in the
vicinity, forcing evacuation until properly equipped personnel can shut equipment
and control the problem. Such a delay, which can increase the amount of material
discharged into the environment, can be minimized if automatic shutoff controls or
suppressive equipment are in place.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-6
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2.1.2 PUMPS, COMPRESSORS, AND STEAM JET EJECTORS
Vapor Losses
As normally used, emissions of the volatile
components in the stream being
processed may escape around seals in
pumps and compressors. Over-
pressurization may also cause relief valves
to release. The agitation caused by rapid
movement of liquids may aerate liquids
and "sparge" volatiles into the headspace
of the pump/compressor or the process
vessel. These vapors may then be emitted through relief valves. Certain high
speed pumps may actually cavitate, causing volatile components to vaporize and
escape into the gas stream. If heat generated by a pump/compressor is not
dissipated by some form of heat exchange fluid, the temperature of the fluid may
increase, at least locally, causing vaporization of volatiles.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
volatile HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Liquid Leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., Part 414
for organic chemicals)
In addition to gaseous leaks, liquid leaks
may also occur at seals and ports if not
properly tightened. Lubricant, liquid
seals, and heat exchange fluid may
become contaminated with process liquid
but will usually remain within the pump/compressor until maintenance work is
done. An emulsion stream of lubricant oil and aqueous process liquid may be
removed continuously from compressors for separation in an oil/water separator;
other process chemicals will also be present, at least in the aqueous phase.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-7
-------
Condensate
Part 405-471, effluent guidelines for
process wastewaters (e.g., Part 414
for organic chemicals)
Steam jet ejectors produce condensate
contaminated with volatile components of
the process fluid. This aqueous
wastewater is removed at steam traps and can be collected and treated in a central
facility. The water heated to make steam may be pretreated, or a blowdown may
be removed to minimize scaling, etc. Steam jet ejectors will produce condensate
with low concentrations of process chemicals during startup.
Startup/Shutdown
Leaks of volatiles during startup and
shutdown will usually be small compared
to those generated during normal
operation; such leaks may be found
during startup. Initial or final purging of a
pump/compressor and associated
processing system may produce vapor
emissions from vents and relief valves,
particularly when conditions deviate from
operating conditions.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
volatile HAPs (page A-39)
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Maintenance Operations
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
The first step in servicing pumps and
compressors would usually be a purge
with clean fluid (inert gas, water, etc.) to
remove residual process liquid. These
fluids will become contaminated and
require treatment and disposal. Lubricant fluids drained from pumps and
compressors will usually be contaminated with process fluid and require treatment
and/or disposal.
Just as during normal operation, emulsions of oil and aqueous streams may not
separate fully and may require the addition of emulsion-breakers such as acid, salt,
etc. before the oil can be disposed; if process chemicals are hazardous, the oil may
also be hazardous. The water would be contaminated with the emulsion breakers
as well as aqueous process chemicals. Any gaskets, mechanical seals, etc.
removed during maintenance may require decontamination before they can be
disposed.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-8
-------
Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., Part 414
for organic chemicals)
Failure of pump or compressor seals can
cause the rapid emission of vapors,
usually through relief vents. Loss of
vacuum, as from the failure of a
compressor or a steam jet ejector, could
allow air to mix with process liquid and vapor. If the material is oxygen sensitive,
emission of decomposition products could occur, presumably through relief valves
installed for this purpose. Failure of diaphragms and mechanical seals in pumps can
cause process liquid and lubricant to mix, necessitating disposal of one or both
fluids. Mechanical or electrical failure of pumps or compressors could subject
process fluid to excess heat, resulting in decomposition.
2.1.3 STORAGE TANKS, CONTAINERS, AND VESSELS
Vapor Losses
Part 61, Subpart Y for benzene emissions
from benzene storage vessels
Part 60, Subpart K, K, and Kb for VOC
storage vessels
Part 63, Subpart G for hazardous organic
NESHAPs from storage vessels
The primary environmental impacts under
normal operating conditions would
include volatile organics (VOC) and
inorganic emissions (e.g., hydrogen
chloride, sulfur oxides, etc.). Emissions
may be lost during normal operation by
diurnal "breathing" of tanks. As temperatures (and barometric pressure) change,
liquid contents and the vapors in the tanks will expand/contract. Vapors may be
vented from closed tanks to a collection/treatment system such as a scrubber/
absorber, a flare, or other control device. Recovered vapors may be recycled to
the tank, discarded as liquid or hazardous waste, or destroyed.
Floating roofs used on tanks storing volatile organics have a seal to prevent the loss
of the vapor. Seals are most likely to release vapors through vents or floating roof
seals when contents are added or removed. Air used to maintain a seal or internal
pressure frequently must be pretreated, at least to remove water vapor, which
could then be considered a waste.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-9
-------
Inert Gases
Occasionally, inert gas blankets are used
to prevent contamination of tanks and to
minimize fire/explosion risk.
Part 60, Subpart K, K, Kb for VOC
storage vessels
Part 61, Subpart Y for benzene emissions
from benzene storage vessels
Part 63, Subpart G for hazardous organic
NESHAPs from storage vessels
Leaks/Spills
Liquid wastes are largely limited to tank
contents that may leak or spill into
secondary containment, particularly
during filling or draining of tanks.
Contaminated rainwater collected in
secondary containment is always a disposal problem and usually requires treatment
as contaminated water.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g. 40 CFR Part
414 for organic chemicals)
Solid Waste
Part 262 for listed and characteristic
hazardous waste generators
Solid and/or hazardous wastes may
include contaminated soil from secondary ^^^^^^^^~^^^^^^^^~
containment after a spill or ongoing leaks and, less frequently, vent condensate,
absorber solids, or scrubber solutions that are not recycled.
Tank Filling
During the filling of tanks, etc., as the
uncontaminated gas in the tank space is
replaced by the liquid and vapor, gaseous
losses (both VOCs and inorganics)
through vents and valves can be
significant, particularly immediately following a period of filling as the tank approaches
equilibration. Leaks at valves, flanges, etc. are most likely to be found during these
periods.
Part 61, Subpart Y for benzene emissions
from benzene storage vessels
Part 60, Subpart K, Ka, and Kb for VOC
storage vessels
Part 63, Subpart G for hazardous organic
NESHAPs from storage vessels
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-10
-------
Tank Draining
There is less opportunity for contaminants
to leave the system when tanks are being
drained, except at valves/flanges. One
exception might be the floating roof,
where a residual thin film of liquid may
remain above the descending roof and
might escape if not properly collected
and/or treated. Vent control systems will
also be in flux during filling and draining and would be subject to upset during these
periods.
Part 61, Subpart Y for benzene emissions
from benzene storage vessels
Part 60, Subpart K, Ka, and Kb for VOC
storage vessels
Part 63, Subpart G for hazardous organic
NESHAPs from storage vessels
Part 405-471, effluent guidelines for
process wastewaters (e.g.,40 CFR 414
for organic chemicals)
Venting
During maintenance of tanks, etc.
additional sources of wastes will be
generated. Tanks will require venting
with air or inert gas before entry can be
made safely; these emissions will contain
vapors of the contents and will require collection/treatment. As with other unit
operations, when valves and piping are disconnected, residual contents may
vaporize or leak and require collection/treatment.
Part 61, Subpart Y for benzene emissions
from benzene storage vessels
Part 60, Subpart K, K, and Kb for VOC
storage vessels
Part 63, Subpart G for hazardous organic
NESHAPs from storage vessels
Maintenance Operations
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR Part
414 for organic chemicals)
Sand blasting, paint removal and
repainting will each generate wastes,
specifically blasting media, old paint, metal
from the tank surface, and VOCs from the
new paint. Because of the solvent
properties of many organics that are stored in such tanks, special paints (e.g.,
urethanes) often must be used and will generate different and unique VOC
emissions until new, water-based paints become common. The use of welding
and cutting torches is often necessary to gain access or to assure tank integrity; in
addition to metal oxide fumes, residuals from the tank may volatilize and/or
decompose when in contact with the elevated temperatures.
Because of the special hazards of working inside a tank (confined space entry, etc.),
special personal protective gear is needed during maintenance; this
becomes solid/hazardous waste requiring disposal. Gaskets, packing, piping, etc.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-11
-------
and even sections of the tank walls also may be contaminated and require disposal
as waste that may be hazardous, depending on the nature of the contents. Smaller
tanks (e.g., drums) may have improper or incomplete labeling and require
extensive testing before they can be classified and appropriately disposed.
Tank Bottoms
Removal of "bottoms" and cleaning of the
interior of tanks often requires steam,
water and special detergents/solvents; the
mixture of these and any residual contents
of the tank will require treatment/disposal.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR Part
414 for organic chemicals)
The major emergency situations that can
be experienced with tanks are overfilling,
leaking (usually from unattended valves)
and catastrophic ruptures. Properly
designed secondary containment will
usually minimize the environmental impact of all of these situations, at least in the
immediate vicinity of the tank. Fire and fire suppressants are another source of
potential environmental contamination.
2.1.4 BLENDING AND MILLING
Particulate
Part 262 for listed and characteristic
hazardous waste generators
The major environmental problem usually
associated with milling, mixing and even ^^^^^~^^^^^~
blending is the emission of particulates at all stages of the operation,
particularly when material is transferred from storage piles, bags, or bins and the
solids are "dropped" into a reactor or other form of mixing chamber. With large
operations, the escape of such emissions often can be minimized by the use of
automated delivery conveyances (e.g., screws, closed hoppers, vacuum feed
systems, etc.) and various particulate control/collection systems (e.g., baghouses,
electrostatic precipitators, scrubbers, Venturis, etc.). However, such control
systems are often not practical for small or non-routine operations, and solids may
be transferred manually from bags and boxes with little or no control. Similarly,
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-12
-------
the particulate captured in various environmental control systems, if not recycled,
may have to be discarded as solid or hazardous waste.
Empty Containers
Part 262 for listed and characteristic
hazardous waste generators
Disposal of empty containers also can
create secondary particulate emissions ^^^^^^^~^^^^^^^~
when they are moved to a disposal area and the containers may have to be
disposed of as hazardous waste.
Scrubber Water
If water scrubbing is used, then there are
both wastewater and noise problems from
the crushing and vibrating equipment used
to reduce particle size, separate grades,
etc.; milling wet material can reduce noise
and dust but will increase water pollution
concerns.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471 effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Mists/Vapors
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment
leaks of benzene
Part 61, Subpart V for equipment
leaks of volatile HAPs
Part 63, Subpart F for organic HAPs
Part 63, Subpart G for organic HAPs from
process vents
The mixing of liquids, with other liquids or
with solids, can product mists or vapors,
depending on volatility of the liquids, but the
particulate problem tends to be lessened.
Containers would require conventional
cleanup between uses. Depending on the
nature of the chemistry involved, the mixing
of gases with liquids may be free of
environmental impact, as when the addition is carried out in a closed system under
pressure or vacuum. However, if the system is open to the atmosphere, incomplete
absorption of the gas can result in gaseous emissions as well as mist and vapor of the
liquid material from vents, safety releases, etc.; in rarer cases, fine particulate matter
may also be produced and carried out of the chamber. Milling and mixing
accompanied by heating may increase all of the problems noted above and add the
possibility of decomposition products from material adhering to heated surfaces. Fine,
dry solids have one other unique characteristic that needs to be considered carefully
during these operations: fine particulates can become charged with static electricity.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-13
-------
Static discharges (sparks) can ignite flammable vapors and certain dust clouds can
detonate.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471 effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
One type of mixing that deserves
separate attention is the mixing of solid
(and liquid ingredients) on exposed mixing
rollers such as Brabender rollers. While
the actual mixing and milling usually
creates minimal emissions, material running off the sides of the rollers can become
waste and heating, either intentionally or due to friction, can cause material
decomposition, escape of volatiles, and even fires. Where runaway heating is a
problem, fire suppression systems are usually employed. While these will help to
protect the facility, they may produce additional wastewater and thermally
damaged product usually must be discarded.
Maintenance Operations
Maintenance of milling and mixing
equipment can create significant
environmental needs. Abrasive material
and the resulting dust in the air can
require frequent maintenance.
Replacement of seals, gaskets and
lubricants will usually be required and will
contribute significant solid waste
contaminated with the materials being
processed. When mixing liquids
or gases, the problems should be less
serious, and normal maintenance
requirements probably can be anticipated.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment
leaks of volatile HAPs
Part 63, Subpart F for organic HAPs
Part 63, Subpart G for organic HAPs
from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g.,40 CFR 414
for organic chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-14
-------
Failures
Failure of solid milling and mixing
equipment can result in dispersal of dust
over an area larger than the normal
handling area and require cleanup of
other equipment, particularly where
moving parts (e.g., gears, bearings, etc.)
May have become coated. While this can
adversely affect equipment and can be
visually unattractive, such dusts can usually
be removed from the environment with
little impact. Obviously, the major failure
mode that must be considered is potential
dust explosions, with resulting fire, equipment destruction and widespread
contamination of equipment with decomposed material. Failure of mixing
equipment containing liquids would normally result in spills or leaks in the process
area that should be anticipated with containment and/or cleanup equipment.
Captured material could then be recovered or safely evaluated and properly
discarded.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
volatile HAPs (A-39)
Part 63, Subpart F for organic HAPs
Part 63, Subpart G for organic HAPs
from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g.,40 CFR 414
for organic chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-15
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2.2 REACTIONS
2.2.1 BATCH, CONTINUOUS, AND FLUIDIZED BED REACTORS
Vapor Losses
The primary environmental impacts under
normal operating conditions are the loss
of solvent, reagent, product and
byproduct vapors, both organic and
inorganic. This usually occurs through
controlled vents where necessary
collection/treatment/adsorption of the
vapors can be carried out to protect the
work environment. Fugitive leaks of
these chemicals, as both liquid and gas,
can also occur around head and port seals, stirrer glands, pump and valve packings,
and piping flanges. Although these have been an accepted part of operation and
may even be factored into process calculations, newer facilities have means of
collecting such leaking material and either recirculating them or disposing of them
where there is a risk of contamination. Secondary containment is not widely used
around reactors.
Part 60, Subpart III for VOC emissions
from SOCMI Air Oxidation Unit
Processes
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Leaks
Steam, water, oils and silicone fluids, and
brine solutions may be used to heat or
cool the reactor, either directly (steam) or
indirectly. Leaks into a reactor are rare
(except for steam injection); leaks into
non-contact heating or cooling coils/pipes
are more common. If contaminated,
these streams require treatment before
the heat transfer liquid/gas can be reused
or discarded.
Part 60, Subpart III for VOC emissions
from SOCMI Air Oxidation Unit
Processes
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
volatile HAPs (page A-39)
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g.,40 CFR 414
for organic chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-16
-------
Sampling and Analysis
Discharges can also occur during sampling
and analysis. Liquid waste may be
generated by leaking sampling valves, lines
may need to be drained before and after
sampling to remove holdup, and excess
sample may be collected. Such material
may require disposal if it cannot be
returned to the reactor. Sampling may
also disturb the reactor equilibrium and
cause "breathing" losses as re-equilibration
occurs.
Part 60, Subpart III for VOC emissions
from SOCMI Air Oxidation Unit
Processes
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g.,40 CFR 414
for organic chemicals)
Fluidizing Gas
Continuous reactors, including fluidized
bed reactors, are usually closed systems,
often operating under elevated pressure.
They present minimal sources of vapor or
liquid leaks during operation except for
the fluidizing gas, which may be a process
chemical, air or an inert gas that may
become an emission when discharged.
Part 60, Subpart III for VOC emissions
from SOCMI Air Oxidation Unit
Processes
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Startup
During startup of a batch reactor,
contamination would usually be limited to
emission of volatiles and particulates as
materials are charged and the reaction
mass is heated. Gas streams (air, inert
gas, steam) contaminated with solvent or
reagent vapors may escape while the
reactor is being charged and as
temperature increases. Leaks of liquids
and gases at valves, vents, joints, etc. are
most apt to be discovered during startup;
thermal expansion may create additional leaks.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 60, Subpart III for VOC emissions
from SOCMI Air Oxidation Unit
Processes
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V fpr equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-17
-------
Off-Spec Product
Part 262 for listed and characteristic
hazardous waste generators
Off-spec material (startup and shutdown)
may be reprocessed or discarded as
wastes. With continuous and fluidized bed reactors, the materials initially charged
may not meet product specifications due to incorrect flow ratios, low temperature
or pressure, incorrect pH, etc. and must be recirculated (if possible) or discarded
as startup wastes. Product generated during shutdown of a continuous reactor will
often be off-spec and require reprocessing or disposal.
Liquid and solid spills may occur during
charging; transfer of fine solids from bags
and tote bins is notorious for dust
emissions.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Shutdown
When the use of a batch reactor is
complete (shutdown), additional vapor
losses occur as the reactor is opened or
vented. The physical transfer of liquid
product from a batch reactor may result
in spills and solvent vapor losses, such as
at valves, particularly if the transfer is made
while material is still warm. It is difficult to
capture the vapors in the head space of a
reactor. Residual non-volatile material,
possible containing byproducts (e.g.,
salts), will often remain in the reactor as
"stickage" after the initial draining and ^^^^^^^^^^^^^^^^~
require tedious removal; this material may be added to the transferred material,
discarded as a waste, or incorporated in succeeding batches if compatible.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 60, Subpart III for VOC emissions
from SOCMI Air Oxidation Unit
Processes
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-18
-------
Separation
Part 262 for listed and characteristic
hazardous waste generators
Separation of liquid products from solid
materials (catalysts, salts, filter aids, etc.) ^^^^^^^^"^^^^^^^^
will leave reactant/product-contaminated solids that require further processing
(e.g., solvent extraction), reactivation, or disposal as solid/hazardous wastes.
Reactivation
Ultimately, the material (e.g., catalyst,
sand, glass powder, etc.) in a fluidized
bed becomes contaminated and must be
cleaned or replaced. Thermal
reactivation may release new gaseous
pollutants; chemical reactivation/cleaning may produce a liquid waste stream of
undefined character. Discarded spent media will be a solid waste and may exhibit
hazardous waste characteristics.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Equipment Flushing
Flushing with purge gas, steam, or
aqueous streams (detergents, neutralizing
agents, etc.) may be necessary to facilitate
safe handling or as part of
decontamination. These streams,
contaminated with the contents of the system, will require disposal, usually as
hazardous wastes.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Gaskets. Packing. Piping. Filters, etc.
Gaskets, packing, piping, filters, etc. may
be contaminated and need to be
Part 262 for listed and characteristic
hazardous waste generators
disposed of as waste that may be hazardous.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-19
-------
Maintenance Operations
Operations such as paint stripping,
painting, welding, lubrication, etc. will
generate additional airborne emissions,
liquid contamination, or solid wastes that
must be removed. As a reactor and
associated equipment (e.g., pumps, vents, flanges, piping, stirrers) are dismantled,
vapor and liquid holdup must be captured and disposed of as wastes.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Failures/Malfunctions
Part60,SubpartIIIforVOC
emissions from SOCMI Air
Oxidation Unit Processes
Part 60, Subpart RRR for VOC emissions
from SOCMI Reactor Processes
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Emergency situations may make it
necessary to discard the reaction mixture
at almost any point in the process. It may
be possible to rework off-spec product
generated by incorrect operating
conditions, but disposal as a waste is
another possibility. In the event of "run-
away" conditions or a major failure in a
reactor system, it may be necessary to
"dump" an entire batch of material at any
point in the reaction sequence. Materials
from a runaway reaction are usually not
suitable for reprocessing, although certain ingredients (e.g., catalysts, solvents) may
be recoverable. Various materials also may be used to control ("kill") run-away
reactions; addition of such materials (e.g., water, acid, base, etc.) will usually make
the reaction mixture unsuitable for reuse, thereby generating a larger volume of a
liquid waste of indefinite character. In failure situations there can be sudden and
LARGE releases of steam, volatile organic compounds (e.g., solvents), inorganic
gases or particulates and fluidizing media, and unidentifiable secondary products
(e.g., tars, polymers) from thermal and/or oxidative degradation. Backup into heat
exchange systems (e.g., checkvalve failure, coil failure) could occur and generate
large volumes of contaminated heat exchange fluid. Large-scale contamination of
the area around equipment is also likely to occur during an emergency; with little
or no containment in most cases this is likely to require the use of large quantities
of adsorbent materials and subsequent disposal. In the case of major failures, the
process equipment and the facility may be damaged and require extensive
maintenance or disposal.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-20
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2.3 HEAT TRANSFER
2.3.1 HEAT EXCHANGERS
Blowdown
Part 63, Subpart F for hazardous
organic NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Under normal operating conditions of
most exchangers there is no
contamination of the heat exchange fluid
by the process fluid or visa versa.
Blowdown of heat exchange fluid (water
or steam) to minimize corrosion and/or buildup of solids on the barrier surface
is the only discharge. Where heat exchange liquid is pretreated to reduce
corrosion, fouling, scaling, etc., blowdown of heat exchange fluid could contain
such additives.
Venting
Venting of heat exchange gases (air,
steam, ammonia) may also occur to
control pressure or contaminant buildup.
Part 63, Subpart F for hazardous
organic NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Leaks
Depending on the pressures on the two
sides of the barrier, leaks from corrosion
or erosion can cause either the process
fluid or the heat exchange fluid to flow
across the barrier and contaminate the
other fluid. This could result in gaseous
emissions (air exchangers), contaminated
water (water or steam exchangers) or
water/organic streams where organic heat
transfer fluids are used (e.g., oils, silicones, etc.). In-line sensors can be used to
detect such leaks. Leaks can also occur at flanges, valves, and, particularly, at
compressors used to move process or heat exchange fluid. Even today, organic
heat transfer fluids may still contain hazardous components such as PCBs.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
volatile HAPs (page A-39)
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-21
-------
Cooling Towers
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Cooling towers are a unique form of air
to liquid heat exchangers used primarily to
cool water or certain aqueous solutions.
A major additional wastestream is the vapor and mist discharged to the
atmosphere; it may contain any volatile or dispersible components of the process
fluid, ranging from ammonia (coke plant) and metallic corrosion inhibitors (water
cooling) to bacteria. Another unique impact of cooling towers is the production of
local fog that can affect visibility and safety due to icing. Cooling towers are not
usually suitable for process fluids where hazardous contaminants would be emitted
to the atmosphere.
Startup/Shutdown
During startup and shutdown of a heat
exchanger, potential or very minor leaks
may become exaggerated as a result of
thermal changes in piping and vessels.
Compressors may leak excessively until seals and gaskets seat into place.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Equipment Cleanout
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewater (e.g., 40
CFR Part 414 for organic
chemicals)
During maintenance operations, scale and
other sediments are removed from
the heat exchanger, generating either a
solid waste or a waste sludge containing
metals and other contaminants, such as
carbonized process chemicals. If high pressure water or steam is used to
accomplish this, a wastewater is generated. Cleaning solvents may first be used
to remove organic heat exchange fluids, thus generating either non-aqueous,
emulsion or aqueous waste streams that would require treatment. Organic
cleaning agents (e.g., chelating agents) used in place of or in addition to mechanical
means to remove the solids from heat exchangers will also be present in the
wastewater and require treatment and disposal. These may also change the nature
of the material removed from the exchanger.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-22
-------
Maintenance Operations
Replacement of damaged sections of a
heat exchanger (e.g., tubes) may generate
a waste of flush water containing the
process fluid and/or any chemicals used to
treat the exchange fluid. In addition, plant
maintenance will generate the normal
sand blasting, paint stripping, painting,
welding and cutting emissions
(particulates, VOCs, metallic fumes, etc.) when a unit is refurbished.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Failures/Malfunctions
Part 63, Subpart F for hazardous
organic NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Failure within a heat exchanger can result
in the gross contamination of one fluid
with the other, as opposed to minor
contamination that might occur from small
leaks. If the leak is into a heat exchange
gas, uncontrolled venting to the
atmosphere would probably result since
control or collection systems are not
common. With water as the heat exchange fluid, the facility may be able to contain
the contaminated fluid and gradually feed it into a central treatment system.
Because of their cost, organic fluid systems are often equipped with
separation/recovery systems. Leaks of heat exchange fluid into process fluid may
only dilute the process fluid or may contaminate it or thermally degrade it so that it
is off-grade and must be discarded as waste. Obviously, PCB contamination would
require disposal in accordance with stringent regulations. Failure of any part of a
heat exchanger system (e.g, relief valve) could discharge hot gas or liquid into the
local environment. The impact of venting hot air or steam would be minor unless
significant contamination was present. Similarly, the impact of a aqueous discharge
to the ground surface would be dependent on the hazards of the process
chemicals present.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-23
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2.3.2 CONDENSERS
Heat Exchange Fluids
"Direct" implies that the heat exchange
fluid and the process fluid are in intimate
contact; consequently, any process liquid
will mix with the heat exchange fluid. The
water, steam or other heat exchange
liquid leaving the system will be
contaminated with volatiles from the ^^^^^^^^^^^^^^^^_
process fluid. The cooled heat exchange
fluid will condense and may become part of the bulk process liquid. Where it
cannot be incorporated because of product quality, conditions can be controlled so
that the heat exchange fluid evaporates and is either exhausted to the atmosphere
(e.g., as steam) or is condensed in a secondary heat exchanger. The steam will be
contaminated with process volatiles and/or process liquid mist.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Blowdown
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Any recirculation of the heat exchange
fluid, such as by the use of a secondary
heat exchanger used to recover heat, may
require a blowdown to control
contaminant [and temperature] buildup. The blowdown will be a liquid waste that
may or may not be suitable for recycle.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-24
-------
Leaks
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
"Indirect" contact means that a barrier,
usually a glass or metal tube wall,
separates the two fluids. With an indirect
or "non-contact" condenser, the most
common environmental problem occurs
when vapors from the process fluid are
drawn into leaks in the barrier and are
removed with the heat exchange fluid.
Because gaseous heat exchange is
relatively inefficient, large volumes of air
are normally used, diluting any process
components and making capture and
treatment of any contaminants less
attractive. A monitoring device (e.g., a PID) is often used to alert operators to the
unexpected presence of contaminants in the gas stream. To an extent, the same
problem exists during normal operation when using a liquid heat exchange fluid
such as water. The direction in which leaks will travel is dependent on which side of
the barrier is at higher pressure. If the process fluid cannot tolerate contamination
with the heat exchange fluid, then any leaks would be into the heat exchanger/
condenser. Vapors of the process liquid leak into the heat exchange fluid and
get discharged with the fluid. Monitoring (e.g., PID, pH meter) is often used to
detect such leaks. If heat exchange fluid leaks into the process fluid, it will, at a mini-
mum, dilute the liquid and retard removal of volatiles; at the extreme, unacceptable
contamination of the process liquid could result, requiring disposal of the process
material. In a related sense, where the water is recirculated (e.g., a holding basin
or a cooling tower), the blowdown that would eventually be necessary will be at
least as badly contaminated with any process components, plus any impurities that
were in the incoming water. Any pumps or compressors used to circulate the heat
exchange fluid will experience similar contamination.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-25
-------
Startup/Shutdown
During startup, high flow of the heat
exchange fluid will dilute any
contamination with process fluid.
However, the low concentrations may
make recovery or recycle unattractive;
discharge is often more cost-effective and
simpler. Leaks into the condenser also
may not be easily detectable during
startup because of low concentrations.
Similar conditions will exist at shutdown
as the process fluid temperature is decreased
is maintained.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment
leaks of HAPs
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
if the flow of the heat exchange fluid
Equipment Flushing
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewater (e.g., 40
CFR Part 414 for organic
chemicals)
Gas purging or washing with solvent or
water on the process side of the conden-
ser will usually be carried out to assure
safe handling during maintenance. The
heat exchange fluid side will usually
require decontamination when using fluids other than steam/water (e.g., when
using ammonia, brine, Freons or other organic liquids) and disposal of
contaminated heat exchange fluids may then be necessary. Any pumps or
compressors handling hazardous liquids would also need to be decontaminated,
generating additional emissions or liquid wastes.
Piping. Tubes, etc.
Part 262 for listed and characteristic
hazardous waste generators
Any piping, heat exchanger tubes, or
compressor/pump parts that are being
replaced may need to be disposed of as hazardous waste, particularly if the
process liquid is hazardous.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-26
-------
Failures/Malfunctions
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Sudden failure during operation of pumps,
compressors or heat exchange fluid
piping, valves, etc. can allow relatively
concentrated vapors to escape from the
condenser unless there are appropriate
scrubbers or other secondary collection
systems. Less frequently, a major leak of
heat exchange fluid into the process liquid
will occur. This could make the process liquid unsuitable for further use, requiring
disposal as concentrated liquid waste. Catastrophic failure of the process system
can occur if solids crystallize (e.g., sublimation, decomposition, freezing) and
plug narrow passages. Without proper controls, the pressure within the system
can continue to increase until hot, concentrated vapor is rapidly discharged
through either a pressure relief valve or through a rupture, if it does not first
melt the plugging material. If the plug melts suddenly, excess hot vapors will
suddenly impinge on the condenser. It may simply exceed the cooling capacity
of the condenser and escape through vents, but it also may damage the heat
exchanger and create leaks.
2.3.3 EVAPORATORS
Exit Gases
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
During normal operations, an evaporator
is usually under reduced pressure and the
major loss is VOC (and inorganic)
emissions (and mist) drawn off in the exit
gas. If steam or water jets are used to generate that vacuum, they will become
contaminated with those contaminants and may require treatment; if mechanical
pumps are used, any lubricant or compressor oil also may become contaminated
and require disposal.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-27
-------
Vapor Losses
Ambient pressure evaporation of solvents
will produce relatively large volumes of
gas (e.g., air, inert gas) contaminated with
low concentrations of VOCs. Capture of
these VOCs from the dilute stream tends
to be more difficult and more costly.
Part 60, Subpart V V for equipment leaks
of VOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment
leaks of HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Off-spec Product
Part 262 for listed and characteristic
hazardous waste generators
External heating sources (steam, hot oil,
etc.) would normally leak into an
evacuated evaporator and not create a new contaminated stream; however, the
product may become contaminated if such a leak occurs and require disposal or
reprocessing.
Startup
During startup, volatile components will
be lost, usually at a low rate, into the
exiting gas stream or into ejector steam or
water until operating conditions are
achieved. Transfer pipes, valves, etc. may
leak as material is introduced into the
evaporator if these portions of the system
are not under reduced pressure.
Part 60, Subpart V V for equipment leaks
of VOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 405-471, effluent guidelines for
process wastewater (e.g., 40 CFR Part
414 for organic chemicals)
Inert Gases
When evaporation is complete, inert gas
may be introduced to avoid thermal
decontamination, but this should not
create any emission sources.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-28
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Equipment Flushing
When maintenance is being carried out
on an evaporator system, gas and water
will often be used to purge the system.
These streams will be contaminated with
the process fluids and, depending on the
nature and concentrations, may require
treatment for disposal. With proper
planning, it may be possible to recycle
such wastewaters into future batches.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Maintenance Operations
Normal maintenance wastes could
include sandblast solids, paint strippers,
paints, lubricants, welding and cutting
fumes, etc. in addition to gaskets, pipes,
etc. that are replaced.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Failures/Malfunctions
Emergency situations could arise if an
evaporator were overheated or became
involved in a fire. In either case, thermally
damaged process fluid would probably be
discarded as waste. Particularly with
temperature- or oxygen-sensitive materials, failure of vacuum seals during
operation may require premature shutdown and the need to discard or even
dilute exposed process fluid to minimize further reaction.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-29
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2.4 SEPARATION
2.4.1 DISTILLATION
Cooling/condensation contamination
The primary environmental impacts under
normal operating conditions relate to
cooling and condensation, including
overhead vapor (organic or inorganic)
contamination of contact or non-contact
Part 60, Subpart NNN, for VOC
emissions from distillation operations
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
cooling water and steam jet condensate, water jet discharge, or vacuum pump
discharge where vacuum is used. Water used for cooling or steam heat may also
require pre-treatment and may produce concentrate wastes requiring treatment;
antifoulants, corrosion protection agents, etc. may all be present in these waters.
Leaks
All valves, flanges, sampling points, vents,
and circulating pump seals are also
potential sources of airborne emission of
the liquid and/or vapor components of
the material being distilled. Leaks of
liquids and gases at valves, vents, joints,
etc. are most apt to be discovered during ^^^^^~^^^^^~
startup; thermal expansion may create additional, unanticipated leaks.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart H for hazardous organic
NESHAPS from equipment leaks
Inert Gas
Part 262 for listed and characteristic
hazardous waste generators
Inert gas blankets used for some
distillations may become contaminated
with volatile materials, and vents bearing these materials may require
treatment/control.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-30
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Cooling/Heating During Startup
Contact cooling water may initially
become contaminated with "light ends" of
the chemicals being processed. Excess
steam may condense until process
temperature is attained and may be
contaminated with the chemicals being
processed.
Part 60, Subpart NNN, for VOC
emissions from distillation operations
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Off-Spec Product
Off-spec material (e.g., contaminated
with light ends, cleaning agents, etc.)
may have to be recirculated or discarded as wastes.
Part 262 for listed and characteristic
hazardous waste generators
Heavy Ends/Still Bottoms
During shutdown, heavy ends and still
bottoms will be present, may require
manual discharge, and will frequently
require disposal. These wastes may be
listed or characteristic hazardous wastes
(e.g., still bottoms from distillation of chlorinated organics will be listed hazardous
wastes).
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Equipment Cleanout
Any equipment being dismantled, (e.g.,
pumps, vents, piping) containing gaseous
or liquid material can produce wastes
requiring special handling for
environmental and safety reasons.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-31
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Equipment Flushing
Equipment will also require flushing with
gaseous (purge gas) or aqueous streams
(detergents, neutralizing agents, etc.) to
facilitate handling or as part of
decontamination. These streams,
contaminated with the contents of the system, will require further management.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Gaskets. Packing. Piping, etc.
Gaskets, packing, piping, etc. may be
contaminated and require disposal as
waste that may be hazardous.
Part 262 for listed and characteristic
hazardous waste generators
Maintenance Operations
Maintenance operations such as paint
stripping, painting, welding, lubrication,
etc. will also generate additional airborne
emissions or liquid contamination that
must be removed as part of a final
cleaning or during the re-startup of the distillation operation.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Failures/Malfunctions
In failure or similar situations there can be
sudden and LARGE releases of steam,
volatile organic and/or inorganic materials
being distilled/processed, and even
secondary products from thermal and/or
oxidative degradation of heated materials
in the unit. Without proper check valves,
backup into cooling water systems and
processing equipment could occur and require more extensive control and
cleanup outside the distillation unit. Similarly, contamination of the area around
equipment is likely to occur during an emergency, but may also occur to a smaller
extent during maintenance and even normal operations.
Part 61, Subpart V for equipment leaks of
volatile HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-32
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2.4.2 ION EXCHANGE
Vapor Losses
During routine operation of an ion
exchange system, emissions of VOCs and
inorganic gases are limited to those
escaping from any tank or transfer system.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Liquid Process Wastes
The major discharges are aqueous
streams, including process liquid,
regenerant solution, rinse water, and
backwash water; i.e., those streams
passing through the system during
operation or during the regeneration cycle.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Small amounts of resin fines may also be swept into any of the aqueous streams.
Other, smaller sources of wastewater include leaks at pipe flanges, pump
seals, and valves, that would be present in any containment/transfer operation.
Off-Spec Product
Part 262 for listed and characteristic
hazardous waste generators
Make-up of regenerant solution, often
from stored concentrate (e.g., acid, alkali),
could also produce off-spec or excess regenerant that would require disposal.
Leaks
The transfer of regenerant from storage
would itself be a source of leaks from
pipes, flanges, or valves.
Part 60, Subpart V V for equipment leaks
of VOCs
Part 61, Subpart ] for equipment
leaks of benzene
Part 61, Subpart V for equipment
leaks of HAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-33
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Regeneration
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Depending on the nature of the process
solution being exchanged, the wastewater
from regeneration might require
secondary treatment, such as
neutralization/ precipitation, that would
produce a sludge or solid waste requiring disposal. Changes in the character and
concentration of the process solution undergoing ion exchange usually lead to
more frequent cycling (i.e., more rapid consumption of exchange sites) rather than
a need to discontinue operations and discard the resin; however, increased cycling
will lead to more frequent resin replacement. Powdered resins are something of
an exception in that single use, followed by separation from the treated process
liquid and disposal, is the standard approach. The increase in solids disposal
requirements is compensated for by the elimination of all regenerant
wastewater streams. Wastewater streams generated during ion exchange at a
chemical manufacturing facility are transported to a central facility for
treatment along with other plant-generated wastewaters or are pretreated in
the process area before discharge to the central facility.
Startup
Leaks in pipes, at flanges, valves, and
pumps are most likely to be discovered
during the startup or shutdown of an ion
exchange process due to changes in
pressure, vibration, and thermal changes.
Changes in headspace volume and
pressure as a exchanger vessel is filled or
emptied may produce vapor emissions
for a short duration. Although resins are
usually shipped and used in a water-
wetted state, minor temperature changes
may occur as a result of resin solvation
with solutes in the process solution,
activation, and regeneration. This could
increase volatilization of any VOCs
present in the solution. Resin fines are removed during the initial charging and
startup of an exchanger and these become solid waste if they cannot be
recycled. The fines may be quite slow to settle.
Part 60, Subpart V V for equipment leaks
of VOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-34
-------
Equipment Flushing
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Process and regenerant solutions and
wash water trapped in valves and pipes
when dismantling equipment for
maintenance may be wasted during
shutdown for maintenance. These are
usually diluted with water used to flush the system. All streams are expected
to contain some amount of resin and resin fines. It is during maintenance
operations that resin may be replaced. If this large volume of solid material,
contaminated with process chemicals, cannot be returned to the vendor for
processing it must be discarded. Depending on the characteristics of the resin at
that point, disposal may range from landfilling to incineration. The latter approach
may be used to recover valuable metals or simply to recover the energy value of
the resin.
Maintenance Operations
Maintenance operations also can generate
all of the normal gaseous, waterborne
and solid emissions expected from area
and equipment washdown, paint
stripping, sandblasting, painting, welding
and cutting operations, and lubrication.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Catastrophic failure of ion exchange
vessels and pipes due to flange/joint
failure and corrosive or erosive failure can
produce rapid discharge of large volumes
of the process liquid together with the
resin. Secondary containment is not usually present, resulting in contamination of
the immediate process area. It is common practice to washdown such spills, as
well as more minor leaks, into a central wastewater collection system unless
precluded by specific hazardous aspects. Overfilling and overflow from the ion
exchange vessel, due either to operator inattention or to instrument failure, would
be a source of relatively large volumes of wastewater, although this would be
expected to occur with low frequency.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-35
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2.4.3 FILTRATION
Vapor Losses
Many filtrations are carried out in
essentially open systems, consequently
vapors can be lost to the work
environment. With vacuum filtration, loss
of volatiles into the vacuum stream may be greater.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Liquid Leaks
Many filters, such as filter presses, will leak
around seals, producing a liquid waste.
While this waste may be the same as the
feedstream, it often will be disposed as
waste. Compressor seal fluids and steam
jet ejector condensate will also become
contaminated.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Backflushing
During backflushing of filters to prevent
blinding, the process liquid will become
contaminated with solids; this slurry may
be discarded as waste.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Liquid Process Wastes
If the solid is the desired product, the
liquid filtrate, containing essentially all of
the process chemicals, will be a waste
requiring disposal. Additional
contaminated liquid will usually be
produced while washing the filter cake.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-36
-------
Solid Process Wastes
Part 262 for listed and characteristic
hazardous waste generators
If the filter cake is not the desired product,
it will need to be treated as waste since it
will contain process chemicals and may also contain filter aids. The decision as to
whether to wash the filter cake will depend on the value of the liquid material and
the impact of the liquid on the characterization of the cake.
Startup
During startup volatiles may be lost to the
vacuum system. Liquid passing through
the filter before a proper blanket is
developed may be wasted, although it
often can be recirculated.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Equipment Flushing
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Purging of a filter with air or inert gas or
washing with water or solvent to remove
hazardous (toxic, corrosive, flammable)
vapors or liquids is good practice to
protect workers involved in maintenance.
Pumps, compressors, valves and pipes should be similarly decontaminated before
they are handled.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-37
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Maintenance Operations
In addition to any residual solids in or on
the filter supports, fabrics, blankets or
membranes may be disposed during
maintenance, along with lubricants and
pump or compressor fluids.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Failures/Malfunctions
Fires can occur on filters when air passes
through a filter containing organic liquids.
This usually results in the need to
dispose of all material as waste and may
produce excess, uncontrolled volatile
emissions. In other failures, such as a torn
filter, liquid and solid may enter the
vacuum system, contaminating pump
fluids and steam jet ejector condensate. If the slurry is captured, it usually can be
recycled.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
2.4.4 DRYING
Vapor Losses
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Products and byproducts are often dried
as intermediate or final stages in
processing. Indirect heating (steam or
electric) may be used to remove organic
solvents and/or water during these operations. Vapors exiting the dryer can be
captured by a condenser, absorber, or scrubber. Ambient temperature drying may
be used for temperature-sensitive material; volatiles lost in these operations may
be more difficult to capture because of the low temperature and high air flow.
Freeze drying and vacuum drying are two versions of low temperature drying that
minimize the volume of offgases. Drying with direct heating, such as by radiant
heating (e.g., IR lamps) may also produce dilute VOC/air emissions.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-38
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Liquid Process Wastes
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
The displaced solvent (usually water)
would be discharged as part of the
vacuum system and may contain any
volatile contaminants present in the wet
solid. Where water is the solvent
removed, or steam is used for direct heating, even non-volatile organics may be
distilled or carried over as mist into the exiting gas stream. These emissions can be
captured by condensation.
Solid Process Wastes
Part 262 for listed and characteristic
hazardous waste generators
Solids adhering to the walls of the dryer
may be discarded as waste at the
completion of batch drying operations if they cannot be used in subsequent
batches.
Leaks
Where steam or hot fluid is used to
provide heat indirectly, contamination
with soluble process chemicals could
occur due to leaks, although it is more
likely that leaks would contaminate the
process material being dried.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Particulates
Part 262 for listed and characteristic
hazardous waste generators
Some solids and certain drying
procedures (e.g, spray drying and freeze
drying) produce fine particulates that can become airborne; filters, scrubbers,
Venturis, and precipitators may be used to collect the particulates. They are usually
discarded, along with contaminated filters, bags, etc.; recycling is a waste
minimization possibility.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-39
-------
Off-spec Product
Part 262 for listed and characteristic
hazardous waste generators
Dried solid product also may be discarded
as waste if it becomes contaminated, such
as by falling on the floor during transfer operations. The nature of the solid will
determine whether it is hazardous or not.
Startup
Leaks in pipe flanges, valves, pumps and
dust collection systems are most likely to
be discovered during the startup of a
dryer due to vibration and thermal
changes. Elevated temperature will
increase volatilization of VOCs in the
solids.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Equipment Cleanout
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Cleaning of a dryer usually generates air
or waterborne streams containing the
solids being dried. Depending on the
nature of the solid, these may be blown
out into the air or sluiced to the plant
wastewater treatment facility as solids-contaminated wastewater. Solids trapped at
joints and bends may be manually removed and discarded as solid waste; their
presumed long residence time in the dryer may have altered their properties so
that they are no longer recyclable as product.
Maintenance Operations
Maintenance operations can generate all
of the normal gaseous, waterborne and
solid emissions expected from paint
stripping, sandblasting, painting, welding
and cutting operations, and lubrication.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-40
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Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Fires are one of the more common
causes for catastrophic failure of dryers.
Product remaining is usually unsuitable for recovery and is discarded as solid or
hazardous waste, depending on the characteristics. Decomposition products may
escape into the air during the fire. Water used to extinguish fires would be
contaminated with the solid and its degradation products. Ideally, such water
would be collected and treated on-site. Equipment damaged by fire or
overheating could require disposal f it cannot be reconditioned.
2.4.5 CRYSTALLIZATION
Vapor Losses
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Volatile components of the process liquid
(e.g., volatile organic solvents) will
volatilize into the crystallizer head space
as material is introduced and while the
temperature of the unit is changing, particularly when the crystallization is brought
about by heating to evaporate excess solvent. Where crystallization is caused
by cooling the process liquid, volatilization will be less significant.
Solid Process Wastes
Part 262 for listed and characteristic
hazardous waste generators
When the solid is the desired product,
the major liquid waste generated from a
crystallizer would be the concentrated mother liquor remaining after the desired
solid material has crystallized and been separated. This liquor may be discharged
as a strong waste, but it also may be used in other process sequences or recycled
as saturated solvent for succeeding batches of product.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-41
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Liquid Process Wastes
When the solid material is not the desired
product, decolorizing agents (e.g.,
carbon) and filter aids may be present in
the liquid and be removed at the same
time, producing a solid waste
contaminated with the mother liquor. Solids that become contaminated (e.g., by
falling outside the crystallizer) will be solid waste unless they can be recycled.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Leaks
Leaks into or out of heat exchanger
fluid are possible. Cooling fluids such
as brine or ammonia are corrosive to
heat exchangers and could result in
frequent leaks. When heating or
cooling using an heat exchanger,
cross-contamination of process and
heat exchanger fluids may occur,
depending on the relative pressure
in the heat exchanger.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Startup
During the startup of a crystallizer,
introduction of liquid into a vessel,
evaporation of excess solvent or cooling
of the process fluid from elevated
temperatures will allow vapors to escape
into the head space of the vessel; they will
be vented with any exhaust air moving
through the system for worker or product
safety. Heat exchanger leaks also may be
detected during the startup. Depending
on the heat exchange fluid, such leaks
could require entire batches of product
liquor to be dumped as contaminated.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-42
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Separation
Part 405-471 effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
On completion of the crystallization stage,
separation of the solid from the liquid
is accomplished by settling,
centrifugation, or filtration. Inefficient separation need not generate a waste, since
it should be practical to recycle the material to a succeeding batch or recirculate it
through the separator.
Equipment Flushing
During maintenance the major waste
is washwater (or solvent) used to clean
the crystallizer; however, with good
planning such waste liquids often can be
reused in subsequent runs. Pumps and
compressors used to transfer process
fluid or heat exchange fluid also may need
to be decontaminated, resulting in
additional liquid waste which may not be suitable for reuse. Residual solids
adhering to the walls often are scraped off and, depending on the value, either
recycled or disposed of as waste. As with all heat exchanger applications,
maintenance often includes the removal of scale and the replacement of damaged
or worn tubes, which then become solid or hazardous wastes.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Sudden failures of crystallizer walls, piping,
valves, pumps, etc. certainly can occur
and would allow process liquid to spill
outside the crystallizer, making
cleanup/washdown of the area necessary.
Except for cross-contamination of the process liquid, such as with incompatible
heat exchange fluid, it often is practical to recycle any process liquid that does not
undergo the desired solid/liquid separation. Plugging of ports, valves, or piping
with solids can cause shutdown of a crystallizer until the solids can be melted or
forced out. However, except for upstream damage to the system by pressure
buildup, or the contamination of solids by fluids used to dislodge such plugs (e.g.,
steam), it would normally be possible to recover and recycle the process liquid.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-43
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2.4.6 CENTRIFUGATION
Vapor Losses
High turbulence of liquid streams entering
a centrifuge, coupled with relatively large
and fluctuating headspace, can increase
the loss of volatile materials; these losses
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
can be partially controlled by appropriate capture hoods on or over the centrifuge.
Leaks
Leaks of liquids and gases may also occur
around valves, pumps and piping flanges
due to vibration.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Liquid Process Wastes
If the solid is the product, the liquid
discharged will contain relatively high
levels of suspended solids and all
dissolved species in the liquid. Disposal
or recycling will depend on constituents
present. A wash cycle, commonly used to remove residual solvent and soluble
species from the solid, will produce secondary, more dilute waste liquid.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Solid Process Wastes
If the liquid is the desired product, then
the solid "cake" is a waste and will usually ~
retain significant quantities of the liquid phase.
Part 262 for listed and characteristic
hazardous waste generators
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-44
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Cooling Water/Fluids
Any cooling water or steam will usually be
in the centrifuge jacket and is not likely to
be contaminated, although monitoring of
the discharge may be desirable.
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Cooling Fluids
Fluids may be used to cool bearings, and
these may be contaminated with the
process liquid and will usually be
considered waste because of undefined
contamination.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Startup/Shutdown
During startup and shutdown, liquid
streams may be discharged or recycled
until proper speed or solids blanket are
achieved. The liquid will contain the
soluble ingredients and relatively high
levels of solids. Ideally, this liquid is
recirculated rather than discarded. ^^^^^^^_^^^^^^^_
Washing and removal of the solid cake
will often generate an additional liquid waste containing lower concentrations of
solids and solutes present in the liquid phase. Vibration while coming to speed
may produce leaks of liquids and gases at valves, vents, flanges, etc.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Equipment Dismantling
Minor sources of gaseous or liquid wastes
may be created when equipment is
dismantled, (e.g., housing, pumps, vents,
piping).
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-45
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Equipment Flushing
Flushing with purge gas or aqueous
streams (detergents, neutralizing agents,
etc.) to facilitate handling or as part of
decontamination will produce relatively
minor streams contaminated with the
contents of the system; collection and/or
treatment may be necessary.
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Gaskets. Packing. Piping, etc.
Contaminated gaskets, packing, piping,
etc. will require disposal.
Part 262 for listed and characteristic
hazardous waste generators
Maintenance Operations
Paint stripping, painting, welding,
lubrication, etc. will generate
additional airborne or liquid emissions.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Failures/Malfunctions
In failure situations there can be sudden
and LARGE releases of the material being
centrifuged if it becomes necessary to
stop the centrifuge rapidly. Usually this
material can be reprocessed, although
there often is some discharge until the situation is brought under control.
Damaged parts can usually be decontaminated by washing and then discarded as
scrap.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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2.4.7 EXTRACTION
Vapor Losses
Part 63, Subpart F for hazardous organic
NESHAPs
Part 63, Subpart G for hazardous organic
NESHAPs from process vents
Volatiles, primarily organic vapors, may be
lost during normal extraction operations
from the headspace over an extraction. If
heat is applied, the loss of vapors will
increase, even if a condenser is used. Vapors can be directed through a vent and
captured by a scrubber or adsorbent. Vapors removed during ambient
temperature extraction with air or inert gas, such as to remove dissolved volatile
organics, may be more difficult to control because the vapors are present at low
vapor pressures. When, at some point in the extraction cycle, the pressure is
released, some of the extractant (solvent) may be lost as a gas (e.g., propane,
carbon dioxide) and some of the extract may be lost as mist, leaving a liquid or
solid that may be product or waste.
Liquid Process Wastes
With either water or organic fluids as the
extractant, the extract will become
increasingly rich during processing. If the
extract (aqueous or organic) is not the
desired product or coproduct, then it will
be waste that must be treated as part of disposal.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Solid Process Wastes
Part 262 for listed and characteristic
hazardous waste generators
If the solution of the extracted material is
the product, then the residual material
containing residual extracting solvent and reagents will be a waste liquid or solid
requiring disposal. On completion of an extraction cycle, the non-product phase,
extract or residue (liquid or solid), will contain process chemicals and require
disposal. Recovery and recycling of solvent extractants is commonly practiced
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-47
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Leaks
When using a heat exchanger to provide
or remove heat, leaks into the heat
exchange fluid could make monitoring,
treatment and disposal necessary.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Startup
The initial filling of a vessel with process
material and extractant can allow volatiles
to escape from the headspace through a
vent, an open reactor, or a pressure relief
valve. Valves, pump seals, and pipe
flanges also may leak vapors or liquid.
Part 60, Subpart V V for equipment leaks
ofVOCs
Part 61, Subpart ] for equipment leaks of
benzene
Part 61, Subpart V for equipment leaks of
HAPs
Part 63, Subpart H for hazardous organic
NESHAPs from equipment leaks
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40 CFR
Part 414 for organic chemicals)
Equipment Flushing
A process vessel and associated
equipment (e.g., pipes, pumps, valves)
would normally be purged to remove
volatile materials and washed with water
and/or solvent before maintenance is
undertaken. These streams would be contaminated with both the extractant and
the process chemicals.
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Packings. Seals. Gaskets
Part 262 for listed and characteristic
hazardous waste generators
Valve packings, pump seals and any gasket
material being replaced probably contains
some contamination and proper disposal requires some consideration.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-48
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Failures/Malfunctions
Part 262 for listed and characteristic
hazardous waste generators
Part 405-471, effluent guidelines for
process wastewaters (e.g., 40
CFR Part 414 for organic
chemicals)
Overpressurization or excessive
temperatures might cause pressure relief
valves to activate, discharging vapors or
even liquid. Oxygen or heat sensitive
material may be damaged under such
failures and require disposal as off-spec material. Heat exchanger leaks could result
in contamination of the process fluid that would make it unusable or contamination
of the heat exchange fluid. System parts damaged in a failure need to be
decontaminated (e.g., with steam, water, or solvent) before they are discarded.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
2-49
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MODULE 3. ASSESSMENT TOOL FOR
WASTE TREATMENT OPERATIONS
INTRODUCTION
This section describes waste treatment operations that are common to the organic
chemical manufacturing industry. Specific operations are classified as air, water and
solid waste treatment. Potential significant releases are indicated for each waste
treatment operation and are linked to the applicable regulatory requirements. It
should be noted that these materials do not specify permit requirements that may
be applicable to an individual facility. Nor do they cite the permitting regulations
under which EPA or States issue facility specific permits (e.g., 40 CFR Part 122 for
direct discharges to waters of the U.S.). The information focuses on specific
effluent/emission standards and requirements that would be incorporated, and as
appropriate, tailored in a facility permit.
This module includes summaries on the following operations:
3.1 Air Emission Treatment
Processes/Equipment
> Baghouses
> Wet Scrubbers
> Thermal Incinerators
> Flares
> Adsorption
> Boilers
> Cyclones
> Electrostatic Precipitators
3.2 Wastewater Treatment Residuals and
Applicable Regulations
> Primary Treatment Technologies
> Secondary Treatment
Technologies
> Polishing or Tertiary Treatment
Technologies
3.3 Solid Waste Treatment and Disposal
Processes/Equipment
ť On-Site Solid Waste Landfill
> Sludge Incineratoration
> Halogen Acid Furnace
> Surface Impoundment
Assessment Tool for Waste Treatment Operations
3.1 Air Emission Treatment Processes/ Equipment .... 3-2
3.2 Wastewater Treatment Residuals and Applicable
Regulations 3-21
3.3 Solid Waste Treatment and Disposal Processes/
Equipment 3-45
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-1
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3.1 AIR EMISSION TREATMENT PROCESSES/EQUIPMENT
3.1.1 BAGHOUSES
Process Description
Baghouses, or fabric filters, typically consist of woven or felted fabric in the form of
tubes or bags that are suspended in a supporting structure (baghouse). Particles
are removed from a gas stream by pushing gases through the system (pressurized
baghouse) by an upstream fan, or by pulling gases through the system (induced
draft). Particles are deposited on the fabric and are removed by three major
methods: mechanical shaking, reverse air cleaning, and pulse jet cleaning. The
particles are collected at the bottom of the devices in hoppers, removed by screw
feeders or extracted by pneumatic conveying equipment, and transported to
storage. The operating parameter usually monitored at baghouses is the pressure
drop of the gas stream across the system. Pressure drop across the baghouse is
directly related to the depth of the collected particle cake on the collection filter,
and is used to indicate when the cleaning cycle is initiated. Pressure drop can also
serve as an indication that the bags are not cleaning completely, or that the bags
are not collecting sufficient filter cake because the particles are penetrating through
worn or ruptured fabric. Many baghouses also employ broken bag detectors or
opacity monitors which are optical devices that can detect particles in the exhaust
gas stream. Many facilities have permitted emissions opacity limits.
Applications
This control device is one of the most efficient devices for removing particulate
matter from dry gas streams. Baghouses contain fabric filters capable of maintaining
control efficiencies of >99% for particle sizes down to 0.3 microns. Three
factors that affect the feasibility of using a baghouse to control particulate emissions
are the flue gas temperature, the gas stream composition, and the particle
characteristics. The temperature of the waste stream must be above the dewpoint
of any condensibles in the stream, but below the maximum temperature of the
fabric. Condensible gas stream constituents such as acid gases and moisture will
wet the filter cake and make cleaning difficult. Condensation also contributes to
corrosion of the baghouse structure and attacks the structural integrity of the filter
bag material. Highly adhesive particles are difficult to remove from the bags
through the cleaning mechanisms. The presence of such "sticky" particles will
preclude the use of a baghouse. Baghouses are sometimes highly effective for
removal of heavy metals when used in conjunction with sorbent injection
technology upstream of the baghouse.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o o
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Equipment Description
The basic configuration of a baghouse is either forced draft (positive pressure) or
induced draft (negative pressure). Many types of natural and synthetic fibers are
used in baghouse systems. Natural fibers include cotton and wool, and synthetic
fibers include nylon, acrylic, polyester, polypropylene, fiberglass, and ceramic.
Often filter fabric selection is application-specific; for example, a high temperature
acid or corrosive stream may require ceramic filters. The most common material
used for the housing structure is corrosion resistant steel such as corten steel. In
extremely corrosive applications, anti-corrosive liners or stainless steel is used.
The particles collected on the bags are removed by mechanical cleaning
techniques. Physical shaking devices operated by electric motors and camshafts
are used in older baghouse designs. Large volume gas streams are treated by
reverse air cleaning baghouses. Reverse air baghouses comprise separate
compartments that are closed from the gas stream individually for cleaning.
Treated gas or heated ambient air is forced through the segregated compartments
in the reverse direction of the dirty gas flow, and pushes the collected particles
from the fabric surface. In pulse jet baghouses, a high pressure pulse of air is
blown down the inside of each bag which causes a deflection of the bag to travel
down the length of the bag and shakes the collected material from the filter surface.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o o
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Pollutant
Phase
Type of Emissions'/
Releases
Assessment Considerations
(look at, look for, think about)
Gases/
vapors
Particulate matter,
i.e., ash from
combustion or dust
from process
operations and
uncontrolled
fraction
In pressurized baghouses, visually check for
fugitive leaks.
What is the basic configuration? If the
baghouse is removing a HAP, the
baghouse should be of the negative
pressure type (induced draft).
Using the most recent stack test results,
determine the measured collection
efficiency and emission rate. Does this
information match the permitted values?
Check if pressure drop across the
baghouse is monitored and verify that this
meets the requirements stated in any
applicable permits or equipment vendor
specification.
Review broken bag detector or opacity
monitor measurements to determine if
broken bags have been observed and
repaired, or to determine if emissions
opacity limits have been exceeded.
There are no regulations that are
applied specifically to baghouses;
however, State Implementation
Plan (SIP) requirements, state
regulations, state permit conditions
and Federal regulations may apply
the process or operating unit
governing their emission rates,
monitoring, record keeping,
reporting, operation and
maintenance.
Liquids
Typically none
Solids
Collected solids
Are the collected solids a hazardous or
characteristic waste? This determination is
made based on process knowledge or
laboratory testing as specified in 40 CFR
Part 261.
Reference RCRA and solid waste
regulations (summarized in
Appendix D).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-4
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3.1.2 WET SCRUBBERS
Process Description
Wet scrubbers are collection devices that can remove particles or gases separately
or together. Particle scrubbers introduce water to wet particles and increase their
size and weight in order to remove them from gas streams using their increased
inertia in centrifugal separators. The absorption of gases is achieved by dissolution
in water or chemical reaction with reagent, or scrubbing liquor. An example of
chemical absorption is HC1 reacting with a base to form a salt.
Applications
Wet scrubbing is most widely applied to flue gas treatment for the control of acid
gases, particulate matter, heavy metals and trace organic compounds. The
particulate matter removal efficiency of a wet scrubber is usually not as high as that
of a baghouse or ESP, and is particularly lower for smaller (< 10 micron) particles.
Wet scrubbers are air pollution control devices, however, water usage and
wastewater disposal requirements are two important factors to consider in
evaluation of a scrubber application.
Equipment Description
The major types of wet scrubbers used for pollutant gas removal include 1) spray
scrubbers used primarily for gas absorption, 2) packed tower scrubbers used
primarily for gas absorption, 3) spray drier absorbers (used in conjunction with a
particle control device), and 4) tray scrubbers. Particulate matter wet scrubbers
include 1) venturi scrubbers, and 2) ionizing wet scrubbers. Combinations of gas
and particulate matter wet scrubbers are often used for combined pollutant
treatment and are referred to as hybrid wet scrubbers. The primary design
features of wet scrubbers are the gas stream pressure drop across the device and
the liquid to gas (1/g) ratio. A higher pressure drop usually results in greater
particulate matter removal efficiency, and a higher liquid to gas ratio can cause
increased pollutant gas absorption rate.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o r
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Pollutant
Phase
Type of Emissions/
Releases
Assessment Considerations
(look at, look for, think about)
Gases/
vapors
Cleaned gas streams
Depending on the function of the unit
(control vs. recovery), certain parameters,
such as gas stream flow rate, pressure drop
and temperature, as well as scrubber liquor
pH, solids content, flow rate and pressure
drop, may have to be monitored. Check
requirements against permit requirements.
Continuous emission monitoring system
(CEMS) recordings of pollutant gas
concentration or mass emission rate should
be reviewed for compliance with permit
conditions and to identify conditions which
depart from normal operation.
In wet gas scrubbers, the flue gas
temperature is cooled to its saturation
temperature. This will lower the dispersion
characteristics of the released flue gas and can
result in a visible plume of condensed liquid.
There are no regulation that are
applied specifically to scrubbers;
however, State Implementation
Plan (SIP) requirements, state
regulations, state permit conditions
and Federal regulations may apply
to the process or operating unit
governing emission rates,
monitoring, record keeping,
reporting, operation and
maintenance.
If the scrubber is used as a control
or recovery device for a regulated
unit operation listed in Section 2.5
(e.g., reactor), then regulations
which apply to the unit operation
may have monitoring, record
keeping and reporting
requirements which apply to the
scrubber operations (e.g., 40 CFR
60.613).
Liquids
Scrubbing liquors
Absorbed acid gas may cause the water
leaving the scrubber to have a low pH and
high solids or dissolved metals content which
may require treatment.
NPDES permit requirements or
pretreatment permit and General
Pretreatment Regulations at 40
CFR 403 requirements.
Solids
Particulate matter,
precipitates from
scrubbing liquors
(sludge)
Depending on the component being
scrubbed from the gaseous stream, the liquid
stream exiting the scrubber may have high
solids levels which require additional
treatment such as settling or filtration.
Sodium based scrubbing liquors cause less
scale formation than calcium based scrubbing
liquors. However, sodium based solids are
typically harder to dispose than calcium based
solids because the higher solubility of sodium
salts makes leaching more of a problem from
such waste streams.
Sludges may require characterization to
determine if they are hazardous or solid
wastes.
Reference RCRA and solid waste
regulations (summarized in
Appendix D).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-6
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3.1.3 THERMAL INCINERATORS
Process Description
Thermal incinerators, also known as afterburners, are widely used in the chemical
industry to destroy organic vapors by heating the waste gases to a high
temperature where the organic contaminants are burned in the presence of
oxygen to form carbon dioxide and water. Some chemicals are oxidized at
temperatures much lower than others. Therefore, operating conditions are based
on the chemical(s) being destroyed, residence time, mixing and temperature.
Application
Incineration is considered the ultimate disposal method for most SOCMI vent
streams because contaminants are destroyed rather than collected or transferred
to another medium. Virtually any gaseous organic stream can be incinerated
provided that proper design, installation, operation, and maintenance issues are
addressed. Incineration can be applied to process off gases as well as to
remediation wastes, such as air stripper effluent gases or soil vapor extraction off
gases. Incineration of halogenated VOCs or compounds containing sulfur may
require additional control equipment to remove corrosive combustion products.
Incinerators are best applied to streams with minor fluctuations in flows such as
reactors and distillation operations. Streams subject to excessive fluctuations in
flow (process upsets) may be better handled using flares.
Incinerators are also used for odor control. For example, resin manufacturers
control glycol emissions using incinerators.
Equipment Description
Direct incineration systems include a fuel feed system, open flame burners,
combustion zone, and exhaust system. Fuel feed rate, treated gas stream flow
rate, combustion zone temperature and residence time are usually monitored
continuously. Thermal destruction efficiency can range from 90% to >99%. Fuel
to gas ratio, temperature and residence time are the critical parameters that
influence thermal destruction efficiency.
Catalytic incineration operates at a lower temperature than direct incineration and
has a lower fuel demand. Destruction efficiency usually ranges between 90% and
95%. Catalytic incinerators are sensitive to inlet VOC stream flow conditions, thus
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o j
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reducing their applicability in the SOCMI industry. Some catalysts can be
deactivated by compounds containing sulfur, bismuth, phosphorous, arsenic,
antimony, mercury, lead, zinc, tin, or halogens. Accumulations of particulate
matter, condensed VOC, or polymerized hydrocarbons on the catalyst can reduce
effectiveness. These systems pass the preheated gas stream through a catalyst bed
to oxidize the combustible emissions.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Pollutant
Phase
Gases/
vapors
Type of
Emissions/Releases
Products of
incomplete
combustion of fuels
and process vent gas.
Products of
combustion of other
non-hazardous organic
containing streams.
Particulate matter
emissions.
Assessment Considerations
(look at, look for, think about)
If the incinerator is used to control
organic emissions from a regulated unit
operation as described in Section 2.5,
verify that the following monitoring
devices are used:
- temperature monitoring device with
continuous recorder
- flow indicator which records vent
stream flow
Verify that incineration of process off
gases meets the required destruction
efficiency of 98% or 20 ppmv
compound exit concentration.
Verify that the facility has conducted an
initial performance test which
demonstrates the above compliance
requirements.
Check for air permits. Check for state
record keeping, monitoring, and
reporting requirements.
Are halogenated gases being burned? If
so, how much? The unit may be a
major source of HAP if annual potential
emissions exceed 10 tons of any single
HAP or 25 tons of combined HAPs. Off
gas controls (scrubber) may be
necessary. Do corrosive byproducts
cause a health and safety issue?
Check emission levels against permitted
value.
If the scrubber is used as a control
or recovery device for a regulated
unit operation listed in Section 2.5
(e.g., reactor), then regulations
which apply to the unit operation
may have monitoring, record
keeping and reporting requirements
which apply to the scrubber
operations (e.g., 40 CFR 60.612).
40CFR60.8
Federally unregulated emissions
may be regulated by state rule.
Regulated at state level.
Liquids
Typically none.
However, a scrubber
may be used as a
supplementary control
device. For example,
destruction of
chlorinated organics
would generate HC1
which may require a
scrubber.
See discussion on wet scrubbers.
Solids
Typically none.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-9
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3.1.4 FLARES
Process Description
Open flames used for disposing of waste gases during normal operation and
emergencies are called flares. They are typically applied when gases are not
economical to recover or are the result of intermittent or uncertain process
operations. The most common types of flares are steam-assisted, air-assisted, and
pressure head. Flare operations can be classified as "smokeless," "non-smokeless,"
and "fired."
Application
To destroy organics that are heavier than methane usually requires the use of
steam or air to provide efficient mixing for complete combustion. This type of
flaring is classified as smokeless. Fired flaring requires additional energy to ensure
complete combustion and is used for such waste streams as sulfur tail gas and
ammonia wastes. Flares can be used for almost any VOC stream and can handle
fluctuation in VOC concentration, flow rate, and inert compounds content.
Streams containing high concentrations of halogenated or sulfur containing
compounds are not usually flared due to formation of corrosion causing
compounds or the formation of secondary pollutants such as sulfur dioxide.
Equipment Description
The most common type of flare used in the chemical industry is the elevated flare.
In this system the vent stream is sent to the flare through the collection header. A
knock-out drum is used to remove water or hydrocarbon droplets that could
create problems with combustion. The vent stream is also typically routed
through a water seal to prevent possible flame flashbacks caused when the stream
flow rate is too low. The VOC stream enters at the base of the flame where it is
heated by already burning fuel and pilot burners.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o i n
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Pollutant
Phase
Gases/
vapors
Liquids
Solids
Type of
Emissions/Releases
Combusted gases
None
None
Assessment Considerations
(look at, look for, think about)
The flare must be operated with no visible
emissions and with a flame present. In addition, a
98% destruction efficiency (DE) is required.
If the flare is used as a control device for a
regulated process unit listed in Section 2.5 (e.g.,
reactor vents) , verify that the following
monitoring, devices are present:
- heat sensing device at the pilot fight
- flow indicator which records vent stream flow
Refief gases having heating values less than 300
Btu/scf are not assured of achieving 98% DE;
therefore, the first step in the evaluation of flare
design is to check the heat content of the
emission stream and determine if additional fuel is
needed.
40CFR60.18
If the scrubber is used as a
control or recovery device for
a regulated unit operation
fisted in Section 2.5 (e.g.,
reactor) , then regulations
which apply to the unit
operation may have
monitoring, record keeping
and reporting requirements
which apply to the flare (e.g.,
40 CFR 60.613).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-11
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3.1.5 ADSORPTION
Process Description
Adsorption utilizes a mass transfer operation in which gaseous phase components
are transferred to a solid phase component. Activated carbon is the most widely
used adsorbent encountered in the chemical industry. Carbon can also be used to
remove organics from liquid streams; however, only gaseous phase removal is
discussed in this section. Oxygenated adsorbents, such as silica gels, diatomaceous
earth, and zeolites have a greater affinity for water vapor rather than gases. Thus
their application is of limited use in the high moisture gas streams characteristic of
some SOCMI vents.
Application
Carbon adsorption is an excellent method for recovering some valuable process
chemicals. It is used for recovery of reactor fugitive solvent emissions, such as
toluene, methyl ethyl ketone, tetrahydrofuran, etc. It is not recommended in
streams with high VOC concentrations, compounds with very high or low
molecular weights, or mixtures of high and low boiling point VOCs. Adsorption
units may range in size from 55 gallon drums used to control emissions from
storage tanks to units that can handle greater than 400,000 SCFM units which
recycle up to 10,000 Ibs/hr of solvent.
Carbon adsorption is most effective with homogenous offgas streams rather than
with streams containing mixtures of light and heavy hydrocarbons.
Process Equipment
The design of an adsorption system depends on the physical properties of the
offgas stream (such as temperature, concentration, volumetric flow rate). Process
offgases are typically filtered and cooled before entering the bed. Prefiltering is
conducted to remove unwanted contamination. Adsorption is best accomplished
at temperatures of 130°F or less. When the bed is saturated, it is regenerated
by heating the bed (usually with steam) or by applying a vacuum to remove the
adsorbed gases. The desorbed gases are then condensed, separated from the
condensed steam. The solvent is usually recycled and the water is discharged or
sent to an air stripper which removes residual solvent so the water can also be
reused in the plant. Carbon in regenerative systems has a life ranging from 5 to 20
years. Therefore, few solids are generated using this control or recovery system.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o i o
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In some applications, such as site remediation, carbon is used to remove
contaminants from a waste stream so the gas can be vented to the atmosphere. In
these cases recovery of adsorbed components is not usually cost effective and the
carbon is disposed as waste or sent to a waste hauler for regeneration.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o i o
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Pollutant
Phase
Type of
Emissions/Releases
Assessment Considerations
(look at, look for, think about)
Gases/
vapors
Stripped vent gases
If the carbon absorber is used as a control
device for a regulated process unit listed in
Section 2.5 (e.g., an air oxidation unit), verify
that the following monitoring, devices are
present:
- steam flow rate
- carbon bed temperature
- concentration of organic compound exiting
recovery device
If the carbon absorber is used as a
control or recovery device for a
regulated unit operation listed in
Section 2.5 (e.g., an air oxidation
unit), then regulations which apply
to the unit operation may have
monitoring, record keeping and
reporting requirements which
apply to the flare (e.g., 40 CFR
60.615).
Liquids
Condensed vapors,
regenerated
material
If carbon absorbers are regenerated on site,
check for leaks and spills of collected
regenerant.
If a hazardous substance spills,
Emergency Planning and
Community Right-To-Know Act
requirements apply if a reportable
quantity is released. Reference
EPCRA regulations.
Solids
Spent carbon
Spent carbon will either be solid or
hazardous waste, depending on waste
characteristics. Evaluate how spent carbon is
characterized and documented, the
conditions of removal, and how the carbon is
stored and disposed.
Reference RCRA and solid waste
regulations (summarized in
Appendix D).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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3.1.6 BOILERS
Process Description
Industrial boilers and process heaters can be used to control VOCs by
incorporating the vent stream with the inlet fuel or by feeding the stream into the
boiler or heater through a separate burner.
Application
Effluent gases from reactors and distillation processes can be directed to boilers to
produce steam at high temperature or to raise the temperature of process
streams. Boilers are most applicable to vent streams which have high BTU
contents. Performance could be impacted by the presence of corrosive products
such as halogenated or sulfur-containing products in the vent stream.
Equipment Description
The majority of industrial boilers are of watertube design. Furthermore, more
than half of these boilers use natural gas as a fuel. Other fuels used include refinery
offgases and fuel oil. Refinery gases often contain sulfur compounds, and emissions
of SO2 are a consideration. In a water tube boiler, heat from the combustion of
gases is transferred to the outside of heat transfer tubes, which contain hot water
and steam that is applied to process operations.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o i c
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Pollutant
Phase
Type of
Emissions/Releases
Assessment Considerations
(look at, look for, think about)
Gases/
vapors
Products of
combustion of
gaseous or liquid
wastes
If boilers are used to control organic
emissions for a regulated unit operation
listed in Section 2.5, verify that:
- a flow indicator monitors vent stream flow
- a temperature monitoring device with a
continuous recorder us used (for boilers of
greater than 150 million BTU/hr)
- period of operation records are kept (for
boilers of greater than 150 million BTU/hr).
Verify that the vent stream is introduced into
the unit's flame zone.
Refinery gas hydrogen sulfide monitoring
may be conducted. Review records of
analysis.
If boiler is controlling emissions
from a unit operation listed in
Section 2.5, then regulation
which apply to these unit
operation may have monitoring,
record keeping, reporting
requirements for boiler
operations (e.g., 40 CFR
60.613.).
If boiler is used to destroy
hazardous waste, ensure
compliance with Boiler and
Industrial Furnace Rule, 40 CFR
266 and 279.
Liquids
Boiler blowdown
Blowdown water can contribute to the
solids content of plant wastewater
discharges. Its impact on overall solids
content of a waste stream is dependent
upon the volume percent of the total
effluent that this waste stream represents.
Total dissolved solids in boiler blowdown
can range from 4000 to 5000 mmhos and
pH ranges from 10.5 - 12.
NPDES permit requirements or
pretreatment permit
requirements and General
Pretreatment Standards at 40
CFR Part 403.
Solids
Typically none
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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3.1.7 CYCLONES
Process Description
A cyclone separates particles from a gas stream without the use of moving parts. A
vortex is created by injecting gas into a cylinder equipped with tangential inlets and
inertial separation removes the particles from the gas stream. Most cyclones have
a double vortex path of the gas which expels particles along the cylinder walls and
at the point the vortex changes direction. Particles drop into a hopper for
removal.
Application
Cyclone separators are often used to remove heavier particles before further
treatment. They are widely used collection devices for particles larger than 15
microns.
Equipment Description
The basic configuration for a cyclone is the tangential inlet, axial outlet, and axial
dust outlet type unit. The performance of cyclone separators is primarily
dependent on particle size. The collection efficiency increases with higher pressure
drops. Higher pressure drops can be achieved with higher inlet gas velocities and
unit features such as cyclone body length.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o i 7
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Pollutant
Phase
Gases/
vapors
Liquids
Solids
Type of
Emissions/Releases
Participate matter;
i.e., fugitive dust and
uncontrolled fraction
Typically none
Collected particulate
matter
Assessment Considerations
(look at, look for, think about)
Visually check for fugitive leaks.
What is the collection efficiency?
Does this match the permitted value?
Are the collected solids a hazardous
or characteristic waste? This
determination is made based on
process knowledge or laboratory
testing as described in 40 CFR Part
261.
Regulations with which
Unit/Process Must Comply
There are no regulations that are
applied specifically to baghouses;
however, some states have State
Implementation Plan (SIP)
requirements governing their
operation and maintenance.
Reference RCRA and solid waste
regulations (summarized in
Appendix D).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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3.1.8 ELECTROSTATIC PRECIPITATORS
Process Description
Electrostatic precipitators (ESPs) use an electrostatic field to charge particulate
matter contained in a gas stream. The charged particles then migrate to a
grounded collecting surface. The collected particles are dislodged from the
collection surface by vibrating or rapping the collector surface.
Application
ESPs are capable of >99% collection efficiency for very small particles (1 micron
to 70 micron diameter particles). ESPs can treat dry or wet particles. ESP control
efficiency is sensitive to variable gas stream conditions, such as dust loading, dust
size, flow rate, humidity and temperature. ESP control efficiency is also sensitive to
ESP design and operating parameters such as gas volumetric flow rate to collection
plate surface area ratio, discharge wire to collection plate voltage and current,
collection plate rapping frequency and intensity, and collection plate and wire
alignment.
Equipment Description
ESPs can be classified as single stage and two stage and/or as wet or dry systems.
Plate-wire precipitators are used to treat high volumes of gases. The predominant
type of system in industrial applications is the dry, single stage system. In wet
systems the particles are removed by washing the sides of the ESP with water. A
potential disadvantage to wet ESPs is that the collected waste stream may present a
solids and liquid handling problem. Two stage systems were developed to clean
air in conjunction with institutional, commercial, and industrial air conditioning
systems and are not widely used in the SOCMI.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o i q
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Pollutant
Phase
Type of
Emissions/Releases
Assessment Considerations
(look at, look for, think about)
Gases/
vapors
Participate matter;
i.e., fugitive dust and
uncontrolled
fraction
Visually check for fugitive leaks.
Review recent emission measurement
tests to determine the collection
efficiency and emission rate for
comparison to match the permitted
value?
Compare discharge voltage and current
to conditions during emissions testing
and permitted conditions. Verify that all
discharge transformers are in
operation.
Review opacity monitoring
measurement records (if applicable) for
conformance with permitted limits.
Confirm operation and maintenance of
device. Follow the procedures outlined
in the applicable operation and
maintenance plan.
There are no regulations that are
applied specifically to ESPs; however,
State Implementation Plan (SIP)
requirements, state regulations, state
permit conditions and Federal
regulations may apply to the process
or operating unit governing their
emission rates, monitoring, record
keeping, reporting, operation and
maintenance.
Operation and maintenance plans
may be required by state regulations.
Liquids
Liquids from the
operation of a wet
ESP
Liquids generated by wet ESPs are
typically sent to a separation device
where solids are separated out and the
liquid is then recycled to the ESP.
Typically, no liquid discharges.
Solids
Collected solids
Are the collected solids a hazardous or
characteristic waste? This
determination is made based on
process knowledge or laboratory
testing as described in 40 CFR Part
261.
Reference RCRA and solid waste
regulations (summarized in Appendix
D).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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3.2 WASTEWATER TREATMENT RESIDUALS AND APPLICABLE
REGULATIONS
Treated Effluent
The primary goal of wastewater treatment is to remove unwanted pollutants such
that the treated final effluent complies with wastewater discharge permit limitations.
Federal wastewater regulations (e.g., 40 CFR Part 414 effluent limitations
guidelines and categorical pretreatment standards for organic chemicals, plastics,
and synthetic fibers manufacturers) are not specific to treatment units. That is, all
things being equal, two facilities treating identical wastestreams using different
treatment technologies are both required to meet the same effluent limitations.
Similarly, wastewater regulations do not specify the type of treatment technology
required. It is the facility's responsibility to determine how it will comply with its
discharge limitations. As such, applicable wastewater regulations described here
are independent of the specific wastewater treatment units described later in this
section.
There are local differences in permitting that will alter effluent limitations between
facilities. For discharges to streams, NPDES permits (pursuant to 40 CFR Part 122)
should account for any Federal effluent limitations guidelines (40 CFR Part 414 for
organic chemical manufacturers), water quality concerns for the receiving stream,
and any facility specific conditions not already addressed (i.e., permit writer's best
professional judgement). For discharges to sewers, permits typically include
Federal categorical pretreatment standards (similarly, 40 CFR Part 414 for organic
chemical manufacturers), general and specific prohibitions of the General
Pretreatment Regulations (40 CFR Part 403), and any local discharge limitations
imposed by the sewerage authority as identified in a sewer use ordinance or
similar authority. In some instances, dischargers to local sewer authorities may not
be issued a wastewater discharge permit. These facilities are required to comply
with the applicable categorical pretreatment standards, General Pretreatment
Regulations, and any local sewer use ordinance requirements.
Often, wastewater discharge permits will include multiple requirements for
different wastewater streams and outfalls, even to the point that internal outfalls
may be regulated. The basic premise of this approach is that the complexities and
variations of the requirements for different facility operations (both process and
non-process) often can be simplified by applying the requirements at various
locations throughout the facility. Since 40 CFR Part 414 requirements only apply
to process wastestreams, discharge requirements for outfalls that include both
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o o ^
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process and non-process wastewater must be adjusted to account for these
nonprocess "dilution" streams.
Liquid Residuals
Typically, liquid residuals (other than treated effluent) are generated as a result of
tertiary treatment operations. The primary exception to this is the removal of oil
using separation techniques. Liquid treatment residuals can be characterized as
either aqueous or organic in nature.
Aqueous residuals are typically high solids streams generated as a result of cleaning
or backwashing of treatment units. Two common sources of aqueous residuals
are backwashes from carbon adsorption and filtration units. If discharged,
backwash, as with any other aqueous residual, must meet applicable effluent
limitations. Since the intent of tertiary treatment is to remove these unwanted
pollutants, these streams are not discharged directly. Typically, these streams are
processed further (e.g., settled to remove solids) with the resultant effluent
returned to the treatment process. In some instances, the backwash or cleaning
water may be hauled offsite for treatment or disposal. These wastes, including any
residual solids, must be characterized to determine if hazardous waste regulations
(40 CFR Parts 261-266) or land disposal restrictions (40 CFR Part 268) apply, and
managed accordingly. In addition, state hazardous and solid waste regulations may
further regulate the management and disposal of these wastes.
Organic residuals are generated from two main treatment technologies, oil
separation and steam stripping. These wastes are often incinerated on-site,
recycled, or sent off-site for reprocessing or disposal. Applicability of the
hazardous waste regulations should be made for all organic wastes for both
characteristic (e.g., ignitability) and listed (e.g., spent non-halogenated solvents)
hazardous wastes. A determination of the applicability of the hazardous waste
regulations for recycled streams is also necessary. Note that specific requirements
exist for hazardous wastes burned in boilers and industrial furnaces (40 CFR Part
266, Subpart H). Facilities that use oil separation techniques for wastewater
treatment should determine whether the Part 279 used oil regulations apply,
particularly where used oil is reprocessed or burned on-site for energy recovery.
Additionally, storage of used oil or recovered organic liquids in underground
storage tanks (USTs) may be subject to 40 CFR Part 280 UST requirements.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q oo
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Solids and Sludges
Treatment of wastewater can generate a variety of solid wastes and sludges.
Generation of these solids typically occur for one of two reasons: solids are
generated continuously as a result of the physical separation from the wastewater
as intended by the treatment process (e.g., grit removal and clarification) or solids
accumulate in the treatment unit over time, requiring periodic removal (e.g.,
lagoons and neutralization). In most instances, solid waste is treated onsite to
reduce its volume and render it inoffensive before disposal. Sludge treatment
techniques include thickening, stabilization, conditioning, and dewatering. In any
instance, the facility should assess whether the solid residual is a hazardous waste
as defined in 40 CFR Part 261, and if so, manage accordingly pursuant to 40 CFR
Parts 262-266 and 268. Some of the common solid hazardous wastes generated
from wastewater treatment in the organic chemical industry include metal
hydroxide sludges from chemical precipitation and spent carbon from activated
carbon adsorption.
Air Emissions
Volatile organic compounds are emitted from wastewater beginning at the first
point that wastewater comes in contact with air. Sources of emissions to the air
include flumes, sumps, sewers, junction boxes, open storage tanks, screens,
settling basins, equalization basins, pH adjustment stations, nutrient addition
stations, biological treatment systems, air or steam strippers lacking overhead or
product recovery, and any other units in contact with the air. Air emissions tend to
be greatest where wastewater is turbulent (i.e., aeration, mixing, pumping, and
bends in collection systems).
For facilities that have benzene in its wastes, 40 CFR Part 61, Subpart FF NESHAPs
(National Emission Standards for Benzene Waste Operations) may apply. These
requirements regulate both the design and allowable emissions from various
wastewater treatment units, including surface impoundments, containers, tanks,
individual drain systems (e.g., junction boxes and flumes), and oil-water separators.
In addition, 40 CFR Part 63, Subpart F sets procedural requirements for facilities
that generate maintenance wastewaters (e.g., heat exchanger descaling and reactor
cleaning) containing organic HAPs. These procedures should include a description
of wastewater generation and management activities to control the emissions from
these wastes. The hazardous organic NESHAPs (HON) rule, as codified at 40
CFR Part 63, Subpart F, regulates organic Hazardous Air Pollutants (HAP)
emissions from process wastewaters. Similar to the benzene waste operations,
specific requirements are outlined for wastewater from tanks, surface
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q oo
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impoundments, containers, individual drain systems, oil-water separators,
treatment processes, and control devices. For most organic chemical facilities,
these regulations will be applied through a state-issued permit.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q ?4
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3.2.1 PRIMARY TREATMENT TECHNOLOGIES
Equalization
Process Description: Flow equalization is a preliminary process used to control
the characteristics of wastewater influent through a treatment process. Industrial
operations typically generate a wide variation of wastewater flowrates and
strengths during a work day. Equalization facilities are structures designed to
provide sufficient retention time to allow these fluctuations in wastewater flow and
characteristics to be dampened before subsequent treatment processes.
Application: Depending on the nature of the industrial operation, wastewater
flows may be generated as batches or in cyclical periods during the work day.
Equalization is best suited to facilities that have a high peak flow to average flow
ratio. The peak flows can be high volume or high strength contributions.
Additionally, wastes with potentially toxic or inhibitory compounds are more in
need of equalization prior to biological treatment to minimize negative effects on
subsequent treatment units.
Equipment Description: Equalization is typically performed in either steel or
concrete tanks or lined basins. The size of the unit is based on the variation of the
peak conditions from the average flowrates and characteristics. Equalization
equipment can either be located in-line with or off-line from the other treatment
system components. In-line systems provide a dampening effect on the
instantaneous flows before the component effluent is conveyed to subsequent
components. Off-line units provide storage for excess flows and meter the
wastewater into the treatment system. Equalization units may include mechanical
mixing, aeration, or baffles to keep solids from settling or to prevent wastestreams
from separating. Additionally, facilities for removing solids and oils that tend to
adhere to the walls should be provided.
Types of Releases: Residual solids carried into the equalization system may build
up on the bottom and have to be removed periodically. Solids or oils may cling to
the walls of the unit and have to be physically removed. Also, wastewaters at
elevated temperatures entering the system may emit volatile compounds to the
atmosphere.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q o r
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Assessment Areas: Determine if storm water flows discharge to equalization and,
if so, whether the basin is properly sized to handle these flows.
* Verify equalization is suitable to handle fluctuations in both wastewater flow and
concentration of pollutants of concern.
> Evaluate areas around floating aerators for erosion.
> Evaluate for signs of overlapping of liquids over edge of tank or basin (i.e.,
adequate freeboard).
* Are there septic odors emanating from equalization? If so, determine if unit
receives adequate aeration and mixing.
> Evaluate influent and effluent monitoring data (e.g., pH, flow, and TOC) to
verify effectiveness of equalization.
Neutralization
Process Description: Neutralization involves the addition of an acid or base to
wastewater to alter the pH of a wastewater stream.
Application: Neutralization of highly acidic or basic wastewaters is necessary for
several reasons: 1) to precipitate heavy metals, 2) to prevent corrosion of
subsequent equipment, 3) to improve treatment efficiency, 4) to provide a
recyclable wastestream, and 5) to reduce the detrimental effects on the receiving
stream or collection system. For example, biological treatment systems operate
most effectively at a pH near 7 (neutral). Small deviations from this value can have
large impacts on the treatment effectiveness. As such, acidic or alkaline
wastewaters often have to be neutralized as a preliminary treatment step prior to
biological treatment. Similarly, treated effluents typically are required to meet pH
limitations at the discharge point, often requiring neutralization to comply with
these limits.
Equipment Description: Neutralization typically occurs in a collection tank(s) or
rapid mix tank(s) where a neutralizing agent (commonly sulfuric acid or lime) is
introduced. The process typically occurs in one, two, or three stages (i.e., tanks).
The selection of neutralizing agent is dependent on cost, availability, ease of use,
reaction by-products, reaction rates, and quantities of sludge formed. A pH
controller is installed in the tank to control the rate that the waste is neutralized.
Storage facilities are required for the acids and bases as these are often used in
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q oc
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large quantities. Often, facilities are able to use waste acids or bases to neutralize
other wastestreams.
To maximize pH control, the influent and effluent points should be at opposite
sides of the reaction tank, preferably with one at the top of the tank and one at the
bottom. Also, baffles in the tank can improve mixing and, hence, pH control.
Neutralization can be highly reliable if proper monitoring, control, and pretreat-
ment to control interfering substances (buffering agents) are provided. Additionally,
because of the harsh environment, maintenance of pH equipment is of utmost
importance in consistent neutralization.
Types of Releases: Residual solids carried into the equalization system may build
up on the bottom and have to be removed periodically. Solids or oils may cling to
the walls of the unit and have to be physically removed. Also, wastewaters at
elevated temperatures entering the system may emit volatile compounds to the
atmosphere during mixing. Finally, neutralizing chemicals, such as lime, can
generate dust during handling and mixing activities.
Assessment Areas: Verify that the pH is measured at the influent and effluent of
the neutralizing unit at points representative of the influent and effluent.
> Is the system able to handle all routine discharges, including batch dumps?
> Verify that maintenance/calibration schedules are available and adhered to for
cleaning, replacing, and calibrating pH probes. Are these schedules consistent
with those recommended by the probe manufacturer?
> Does the neutralization process generate solids that must be removed from the
process? If so, what is the process for removing these solids?
Is the final effluent pH monitored continuously and if so, is this consistent with
any permit requirements?
Screening
Process Description: Screening is a preliminary treatment process to remove
large solids from wastewater before subsequent treatment processes. Screenings
are removed at the front end of the treatment train to prevent this material from
clogging or damaging pumping systems, piping, etc.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q 07
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Applications: Screening units are utilized on wastewater streams that contain
coarse organic or inorganic solids.
Equipment Description: Screening units are mechanical drum or disk-type
systems that allow wastewater to pass through selected openings. Objects larger
than the openings (typically 6-20 mm) are retained on the screening unit and
removed by a manual or automatic scraper mechanism. Fine screens may have
openings smaller than 6 mm. Screenings are removed from the liquid through
rotation of the screen and collected in hoppers or tanks for disposal.
Types of Releases: Screened solids are generated from the screening process
that are removed from the process using a water spray. Therefore, these solids
will contain some amount of free liquid. Also, screening of wastewaters containing
VOCs will generate air emissions of these volatile compounds.
Assessment Areas: Are solids/oils building up on the screen that cannot be
removed by the mechanical scraper or spray nozzles?
> Is the solid loading rate to the screening device consistent with the unit design
specifications?
* Are there tears in the screen?
* Are spray nozzles directed at the screens such that the entire screen area is
being cleared of solids?
> Are solids removed from the screening unit hazardous? If so, how are these
solids managed?
Grit Removal
Process Description: Grit removal is a process of separating heavy inorganic solids
from a wastewater stream. Grit removal facilities are in-line units of various size
and shapes designed to slow down the velocity of the wastewater stream to allow
the heavier particles to settle out. Removal of this material enhances the
performance of the remaining treatment components and protects equipment from
damage as a result of abrasion or from formation of heavy deposits within the
system. Grit removal chambers are located at the front of the treatment train with
the screening unit.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o oo
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Application: Grit chambers are used for wastewater streams that convey heavy
inorganic material that may be flushed into the collection system and conveyed to
the treatment process. This is particularly common in older collection systems.
Equipment Description: Grit chambers are typically large concrete tanks designed
to slow the flow of the wastewater to detention time of about 1-3 minutes. The
units should be designed to provide for a uniform cross-sectional velocity. Heavy
inorganic solids are separated from the wastewater by creating a quiescent zone
for the solids to settle or by the addition of air to reduce the buoyancy of the
liquid. Characteristics of the wastewater and the removal goals determine the
configuration of the grit facilities. The units contain hoppers or channels in the
bottom to collect settled solids. Solids are removed by hydrostatic pressure or
mechanical equipment.
Types of Releases: Grit from the bottom of the chamber will contain free liquid.
Air emissions of volatiles will also be generated from the process, although these
emissions are expected to be less than in other treatment operations. There may
be air emissions from subsequent grit washing, if applicable.
Assessment Areas: Does the scraper mechanism cause turbulence in the water as
it rotates through the chamber?
> Is operation of grit collection manual or automatic? If manual, is there a
schedule, with log, documenting grit removal?
* Are chain tensions, scraper flights, guide vanes, etc. inspected and maintained
on a regular basis? Are records available?
Oil Separation
Process Description: An oil separation system is used to remove oils and grease
from wastewater. Oil may be present as free or emulsified oil. The separation of
free oils occurs by gravity and normally occurs by allowing oils to float to the
surface of the water where the oil is skimmed off by mechanical means. Emulsified
oil must first be "broken" using chemicals (typically acid) and/or heat to generate
free oil. The free oil can then be removed using skimming techniques.
Application: Oil separation is used to recover oil for use as a fuel supplement or
for recycle, or to reduce the concentration of oils in the wastewater (either to
comply with effluent limitations or to prevent deleterious effects on the treatment
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o on
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system or environment). Oil removal may also remove toxic organic chemicals
that tend to concentrate in oils and grease.
Equipment Description: The principal design considerations for an oil removal
system include; 1) the amount of oil to be removed, 2) the oil droplet distribution,
3) the presence of emulsifiers, 4) the specific gravity of the oil, 5) wastewater
temperature, and 6) suspended solids concentration.
The separation of free oils and grease typically occur in a concrete holding tank and
allow the oils to float to the surface. The oil is skimmed off the surface
mechanically with a rotating drum- or belt-type skimmer. Typically, emulsified oils
are pretreated with acid and/or polymer at an elevated temperature in an enclosed
steel tank to break the emulsion and free the oil.
API separators and parallel plate interceptors are two of the most common types
of gravity type oil removal systems. API separators allow for retention of oily
wastewater in a tank for a specified period of time to allow the oils to rise to the
surface where they can be skimmed off. Parallel plate interceptors consists of a
series of parallel plates in a tank that act to calm the flow and reduce the distance
that the oil particle has to travel to be removed. Use of plates allow for more
efficient use of space.
Types of Releases: Oil removed from the separator may be able to be
reprocessed, used as a fuel supplement, or disposed of. Vapors (especially for
heated emulsion breaking processes) will be emitted from the oil removal process.
In addition, it is possible that sediment buildup in the separator may have to be
removed periodically.
Assessment Areas: Look for noticeable floating oils discharging from the
separator.
* Determine if recovered oil is considered a hazardous waste and if so, managed
appropriately.
* Evaluate oil separator efficiency during peak flows to verify proper sizing of unit
(i.e., no overflow of oil into the effluent).
> For emulsion breaking oil removal, compare bench scale treatability testing
results with plant processes to verify consistent oil removal.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o on
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> Addition of heat to the emulsion breaking process will likely generate excess
emissions to the atmosphere. Since toxic organics may be dissolved in the oil
phase, the need for emission control should be seriously considered.
Flotation
Process Description: Flotation is the process of removing suspended matter from
wastewater by introducing fine gas bubbles that adhere to the particles, reducing
their specific gravity, and thus carrying these particles to the surface of the
wastewater. Flotation is effective on suspended matter since this material has a
specific gravity comparable to water (i.e., neither floats to the surface or settles to
the bottom). Often chemicals are added to enhance the removal process. The
three most common flotation methods are dissolved air flotation (DAF), air
flotation, and vacuum flotation. By far, DAF is the most frequently used of the
three. DAF operates by injecting air into pressurized wastewater (supersaturated
with air) causing fine bubbles to form as the pressure is reduced. Air flotation
occurs through simple aeration, typically through a diffuser. Vacuum flotation
indicates the process where wastewater is saturated with air prior to application of
a vacuum to the wastewater, causing the release of air bubbles.
Application: Flotation is used to remove suspended solids that have poor settling
characteristics, to remove suspended oils and greases, or to concentrate
wastewater treatment sludges. Flotation is also appropriate for application during
peak loads, such as during storm events.
Equipment Description: Flotation equipment includes an external contact tank
within which air is introduced into the wastewater under pressure. This super-
saturated wastewater then passes through a pressure relief valve where the
pressure dissipates. As the wastewater equalizes to atmospheric, fine air bubbles
form and rise to the surface of the tank. As these bubbles rise, they attach to the
suspended particles and oils, increasing their buoyancy and causing them to rise to
the surface.
In DAF, air is introduced into one of three streams, the total influent, partial
influent, or recycled effluent. Recycled effluent (20-50 percent of total flow) is the
most common with chemical added to the influent stream. This prevents the floe
from being destroyed by the pressurizing and depressurizing of the wastewater.
Mixing of the recycled effluent, chemicals, and influent typically occurs in-line just
prior to being introduced to the inlet well. Multi-cell DAF units are common,
where a portion of final effluent is removed, re-saturated with air, and introduced
into each of a number of serial DAF chambers within the DAF unit. This provides
This manual is intended solely for guidance. No statutory or regulatory
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multiple passes of air through the wastewater, thereby increasing contaminant
removal.
A skimmer at the surface collects the floating oily solids while settled solids are
removed from the bottom of the flotation unit.
A DAF unit thus consists of the following pieces of equipment: a pressurizing
pump, an air-injection system, a saturation vessel, a pressure relief valve, a
chemical addition system, and a flotation chamber.
Types of Releases: Vapors (including odors) are emitted from the flotation
process, and depending on the constituents in the wastewater, these emissions
may have to be controlled. Skimmed aerated sludge from the flotation process is
generated and must be disposed. In addition, solids will settle on the bottom of
the flotation unit and likely must also be managed as a waste.
Assessment Areas: Compare bench scale treatability testing results with plant
processes to verify consistent removals. Overuse and underuse of chemicals can
reduce the effectiveness of the system.
> Evaluate mechanical scrapers and drive mechanisms for wear and replace as
necessary.
* Verify that skimmer is level and removing froth from flotation unit.
* Evaluate flotation unit for signs of short circuiting that may reduce its efficiency.
Chemical Precipitation
Process Description: Chemical precipitation is a chemical process by which
soluble metal ions and certain anions are converted to insoluble form for
subsequent removal. The process is accomplished through pH adjustment of the
wastestream to form metal hydroxides that are relatively insoluble at elevated pH
levels. Chemical precipitation is the primary method for removing metals from
wastewater. Most metals are relatively insoluble as hydroxides, sulfides, and
carbonates, and can be precipitated in one of these forms by chemical addition.
Hydroxide precipitation (through addition of caustic soda or lime) is the most
common of the techniques. By adding the proper amount of chemical to adjust
the pH to the level where metal hydroxides are the least soluble, these metal
hydroxides can be precipitated and removed. Sulfide precipitation, through the
addition of hydrogen sulfide, sodium sulfide, or ferrous sulfide, is also effective for
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q o
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removal of metals from wastewater. Chemical precipitation may be preceded by
cyanide destruction or hexavalent chromium reduction where these pollutants are
also of concern.
Application: Chemical precipitation is a proven technique for removing heavy
metals from wastewater. It is suitable for automatic control and can remove a
large variety of metals down to near trace concentrations. Depending on the
volume and generation rate of the wastestream to be treated, this process can be
either batch or continuous. Chemical precipitation may be limited in the organic
chemical industry because of the presence of chelating agents and complexed
metals ions. In these circumstances, additional pretreatment to destabilize the
complex may be necessary. One of the effective techniques for removal of
complexed metals is sulfide precipitation (using ferrous sulfide).
Equipment Description: Chemical precipitation is typically carried out in four
phases; 1) chemical addition, 2) rapid mixing, 3) slow stirring to promote particle
growth, and 4) clarification to remove the flocculated solid particles. Treatment
chemicals are added to raise pH (along with polymers that promote floe growth) in
a rapid mix tank. Often, pH adjustment occurs in a two stage process to allow for
closer control of pH. In line baffles, blenders, and pumps may be used to improve
mixing. After the rapid mix, the wastewater flows to a darifier (often a lamella
inclined plate type darifier) where the solids are settled and removed.
Types of Releases: Chemical precipitation will generate a hydroxide or sulfide
sludge that must be disposed. Often, this sludge is passed through a filter press to
remove excess water. Filtrate should be returned to the chemical precipitation
process for further treatment. Also, the addition of lime to wastewater can
generate lime dust around the rapid mix tank.
Assessment Areas: Verify that chemical addition occurs in a well mixed
environment.
> Ensure that pH is adjusted to a point that promotes the greatest removal for the
contaminants of concern in the waste.
> For continuous systems, compare fluctuations in flow and concentration (e.g.,
during batch dumps to the system) with actual treatment performance data to
ensure that the system is capable of handling the increased loads.
> Are the acids and bases used in the treatment process stored behind berms or
in locations that will minimize danger from spills or ruptures?
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Are solids overflowing the darifier, indicative of improper design, operation, or
maintenance of the treatment system?
Are laboratory study results available demonstrating appropriate quantities of
polymers to add to improve flocculation?
Are any non-metal bearing wastestreams being treated by chemical precipitation
that could be segregated from this system?
Are pH probes maintained and calibrated on a regular schedule?
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q OA
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3.2.2 SECONDARY TREATMENT TECHNOLOGIES
Activated Sludge
Process Description: The activated sludge process is a biological treatment
process whereby microorganisms use the organic content and oxygen in the
wastewater to grow, leaving an end product of carbon dioxide and water. The
process is characterized by suspended aerobic and facultative microorganisms
maintained in a homogeneous state by mixing (either mechanical or diffused air).
The microorganisms oxidize soluble organics and agglomerate colloidal and
particulate solids in the presence of dissolved oxygen. The aeration process occurs
in an aeration basin that is followed by sedimentation to settle the biological sludge
from the wastewater. The majority of the waste sludge is recycled back to the
head of the activated sludge process where it is mixed with influent and fed back
into the aeration basins. A small percentage of the waste sludge is removed and
sent to sludge processing.
Application: The activated sludge process is extremely versatile and can be
adapted for a wide variety of organic wastewaters. It is the most widely used
biological treatment process for wastewater. The key design variables include
organic loading (i.e., food to microorganism ratio), sludge retention time, hydraulic
or aeration detention time, oxygen content, and a temperature dependent
reaction rate constant (K). Modifications to the process are common and have
been identified by the major characteristics that distinguish their configuration.
These include; conventional, complete mix, tapered aeration, step aeration, high
rate activated sludge, pure oxygen, extended aeration, contact stabilization, and
oxidation ditch activated sludge. Each of these options provide unique
opportunities for maximizing the process efficiency for any given organic
wastewater.
Equipment Description: The conventional activated sludge treatment process
consists of one or more long rectangular concrete tanks with air diffusers on one
side of the tank bottom (for mixing and aeration). Raw wastewater and return
activated sludge (i.e., recycled from the end of the process) enter one end of the
tank and flow in a spiral flow through the tank. More air is added at the head of the
tank where biological activity is greatest. Modifications to the conventional process
affect where raw influent enters the system, where sludge is returned to the
system, and how the wastewater is aerated. In addition, some systems use high-
purity oxygen rather than air, which reduces the size of the tanks necessary for
treatment.
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requirements are in any way altered by any statements) contained herein. Q o r
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Types of Releases: Volatile emissions are generated from the aeration process.
No other emissions will be generated in this process.
Assessment Areas: Is dissolved oxygen maintained at 1-3 mg/1, and preferably at
least 2 mg/1?
> Verify that sludge blanket thickness is consistent with design specifications (e.g.,
less than one-fourth the darifier sidewall water depth).
* Does a microscopic examination of mixed liquor identify undesirable organisms
such as filamentous bacteria?
> Verify that all underwater instrumentation is checked, calibrated, and cleaned on
a regular basis.
> Is foam in activated sludge system a medium colored tan? Too light (mixed
liquor suspended solids too low) or too dark (sludge retention time too long) is
indicative of poorly operated systems.
Lagoons
Process Description: Lagoons are earthen ponds designed for biological
treatment of wastewater. While in the pond, wastewater is biologically degraded
to reduce organics and reduce suspended solids by sedimentation. The biological
process may be aerobic, anaerobic, or both depending on pond design.
Application: Low construction and operating costs make lagoons a common
treatment method in locations where sufficient land is available at a reasonable
cost. Lagoons are used for stabilization of suspended, dissolved, and colloidal
organics and may be aerobic, anaerobic, facultative, or aerated. A pond system
may consist of some combination of these pond types. For example, high strength
wastes may be treated in an anaerobic pond, then a facultative pond, and finally an
aerated pond.
Equipment Design: Lagoons are typically day-lined earthen ponds with a
surrounding earthen dike. Design commonly includes three ponds in series with
effluent discharged to a concrete splash pad. Often, lagoons will be baffled to
separate a single pond into multiple functional units. Lagoon performance is
dependent upon detention time, temperature, and nature of the waste.
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requirements are in any way altered by any statements) contained herein. Q OR
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Aerobic lagoons are shallow ponds (less than 1 foot deep), usually lined, that
contain dissolved oxygen throughout the pond. Organic degradation occurs from
aerobic bacterial oxidation and algal photosynthesis. Aerobic lagoons are most
applicable to wastewaters with a low suspended solids content and are often
used after another type of biological treatment process.
Anaerobic lagoons are relatively deep (up to 20 feet) with steep sides. This
provides for maximum volume to surface area ratio. By maintaining an elevated
organic load in the lagoon, an almost completely deoxygenated environment is
achieved. Floating material on the surface of the pond (e.g., algae) may allow for
more complete anaerobic conditions. Anaerobic lagoons are more resistant to
shock loads and can handle elevated organic and suspended solids loadings.
Typical organic removal rates are in the 70-80 percent range. Typically, anaerobic
lagoons are designed with influent entering the bottom (usually in the center of the
lagoon), where it mixes with the active mass in the sludge blanket. Discharge
occurs out the side through a submerged effluent point. Additional treatment
operations are often performed on the anaerobic lagoon effluent.
Facultative lagoons are the most common type of biological treatment lagoon and
are typically 3-8 feet deep, with a flat bottom, and have a retention time of 50-150
days. These types of lagoons remove about 75-95 percent of the incoming organic
load. Small facultative lagoons may be designed for zero discharge of wastewater,
other than by evaporation. The anaerobic condition of the bottom layer of
facultative ponds provides for digestion of settled solids. Influent enters the center
of the pond and effluent overflows in a corner (windward side). Operating several
ponds in series helps to improve organics removal, most notably by minimizing
short circuiting through the system. Pond levels are typically raised and lowered
with the changing seasons to maximize efficiency and minimize problems (e.g.,
freezing, emergent vegetation).
Aerated lagoons are medium depth (8-12 feet) where oxygen is supplied through
mechanical (e.g., surface aerators) or diffused air units. Aerobic units are designed
to maintain complete mixing; therefore, subsequent solids settling and removal
units are necessary. Overloaded aerated lagoons may become facultative if
inadequate mixing is provided. Similarly, poorly mixed lagoons may also provide
for anaerobic conditions.
Types of Releases: Volatile emissions from ponds may be an odor problem or,
depending on process operations, may emit noxious fumes. These emissions are
greatest in aerated systems and anaerobic systems (producing methane gas).
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Some lagoons may accumulate solids over time and will have to be dredged,
dewatered and disposed.
Assessment Areas: Examine effluent quality for turbidity, algal blooms, etc.
* For aerated lagoons, make certain that all aerators are functioning properly.
* Are there plants growing in the lagoon, indicative of low liquid levels or poor
circulation of wastewater?
> Are there any signs of erosion, burrowing animals, etc. in dikes that may
weaken the structure?
* Are storm flows drained to the lagoons, and if so, do these flows impact the
overall performance of the lagoons?
> Are there offensive odors from aerobic or aerated lagoons that may be
indicative of anaerobic conditions? If so, evaluate mixing and aeration systems
for potential dead spots or short circuiting.
> Evaluate organic loading to lagoon and detention time of wastewater in the
lagoon and compare with expected design criteria to identify potential design
shortcomings.
Secondary Clarification
Process Description: Secondary darifiers follow biological treatment, and in most
instances are intended solely for removal of solids through settling. Secondary
darifiers are very similar in design to primary darifiers, except that secondary
clarification is intended to remove biological solids. For activated sludge systems,
darifiers must also provide a concentrated source of return activated sludge for
process control. These tanks may be designed for natural settling or chemically
aided settling.
Application: Secondary clarification is an integral part of the activated sludge
process. As such, treatment systems utilizing activated sludge typically operate
secondary clarification systems. In addition, biological systems such as lagoons may
also require use of secondary clarification for solids removal.
Equipment Description: Secondary clarification basins are typically circular or
rectangular of concrete construction. They are equipped with scrapers or suction
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requirements are in any way altered by any statements) contained herein. o oo
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type sludge removal units on the bottom of the basin. The scrapers are typically
installed on smaller tanks (less than 50 feet in diameter) while the vacuum systems
are used for larger tanks. Surface skimmers are also used to remove floating solids.
Clarification basins are sized based on the overflow rate, taking into account peak
flows. For secondary clarification following activated sludge, solids loading rate is
also an important design consideration. Also, since secondary darifiers are
sensitive to variations in flow, the use of multispeed pumps for in-plant wastewater
lift stations is often used where flow equalization is inadequate.
Types of Releases: The major release from secondary darifiers is settled sludge.
In settled sludge from darifiers following activated sludge systems, a portion of this
sludge is recycled back to the activated sludge process. Sludge that is not returned
is disposed. Settled solids tend to attract organic constituents that can be emitted
to the atmosphere where the settled sludge is dried prior to disposal. Also, scum
removal from the surface of the darifier must be disposed.
Assessment Areas: Are controls in place to regulate sludge blanket thickness?
> Is a relatively steady flow discharged to the darifier?
> Look for signs of sludge floating to the surface of the darifiers, indicative of
improperly operated system.
* Examine secondary darifier overflow for evidence of pin floe, indicative of
excessive turbulence, toxic shocks, short-circuiting, etc.
> Examine weirs for fouling and verify that a routine cleaning and maintenance
schedule exists and is adhered to.
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3.2.3 POLISHING AND TERTIARY TREATMENT TECHNOLOGIES
Polishing Ponds
Process Description: Polishing ponds are shallow bodies of wastewater (usually 2
to 3 feet deep), used for the removal of residual suspended solids by
sedimentation, typically used as tertiary treatment. Some biodegradation of
organic material also occurs.
Application: Many facilities use ponds as the final treatment step in a series of
operations. Often the ponds are not used as polishing ponds; rather, these
ponds are used as equalization basins, where some level of dilution occurs
prior to discharge, or as reaeration basins, to increase dissolved oxygen
levels.
Equipment Description: Depending on the quality of influent and desired effluent,
polishing systems can consist of one to several units in series. Polishing ponds are
lined or unlined earthen basins with wastewater entering one end and discharging
from the other.
Types of Releases: Some polishing ponds may accumulate solids over time which
will have to be dredged, dewatered and disposed.
Assessment Areas: Examine pond influent and effluent structures for solids
buildup that may act to channel flows through the system.
Determine whether storm water contributions (i.e., runoff) contribute to reduced
retention time (i.e., reduced treatment efficiency) of treated wastewater.
Filtration
Process Description: Filtration is the process of removing suspended solids from
a wastewater stream by passing the water through a granular media filter bed, a
membrane, or, less commonly, through a wire mesh. The removal of solids
occurs as the result of one or more mechanisms, such as straining, sedimentation,
interception, impaction, and adsorption.
Application: Filtration is usually the final treatment step when requirements exist
for consistently low suspended solids or metals levels in the treatment plant
effluent. Filtration may also be used as a pretreatment for suspended solids
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reduction prior to other treatment processes, such as carbon adsorption, that may
be adversely affected by suspended solids.
Equipment Description: Granular media filters consist of various media, such as
sand, garnet, coal, or diatomaceous earth, placed in a contactor which allows the
wastewater to flow through the media. One or more types of granular media may
be used in concert; if more than one type is used, the types may be stratified or
mixed. Flow through the contactor may be up, down, or bi-directional (with the
effluent port in the middle of the contactor and influent introduced at the top and
bottom). Filters may be gravitational- or pressure-driven. Periodic backwashing is
necessary to remove the collected suspended solids. Spent backwash water, high
in suspended solids, is typically routed to a process where settling may occur.
Membrane filters (such as those used in reverse osmosis and ultrafiltration) hare
pore sizes small enough to remove not only suspended solids but also dissolved
organic and inorganic impurities. Wastewater streams must be pretreated by pH
adjustment and for removal of high suspended solids and certain organic and
inorganic compounds to prevent rapid fouling or degradation of the membrane.
Types of Releases: Backwashing of filter media generates a concentrated
wastewater that is approximately 1-5 percent of the volume of wastewater treated.
Typically, this stream is discharged to a settling tank for solids removal with
supernatant returned to the treatment process. Occasionally, all backwash is
recycled back through the treatment process.
Assessment Areas: Examine effluent turbidity for signs of residual solids, which are
indicative of inadequate chemical coagulation or the need for backwashing.
Review head loss of system over time for indication of bed plugging or inoperative
surface wash or air scouring system.
If head loss rapidly increases after backwashing, evaluate adequacy of previous
treatment steps and filter aid addition.
Examine backwash water for signs of filter media being removed from the system,
indicative of excessive backwash flowrates or excessive turbulence in system
causing air bubbles to form in system.
Examine records of length of filter runs to determine past surface clogging or
excessive solids loadings that may be overloading the system.
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Activated Carbon Adsorption
Process Description: Activated carbon adsorption is a physical separation process
in which inorganic and organic materials are adsorbed onto the surface of the
activated carbon media. Activated carbon is a specially prepared media that
contains a very high surface area per unit volume. Carbon adsorption fixed bed
systems also provide a second removal benefit as the result of the filtering effect of
the granular carbon.
Application: Carbon adsorption systems have been shown to be practical and efficient
for treatment of organics in wastewater. Carbon adsorption systems are most
effective because of their ability to remove a large variety of organic chemicals.
Compounds that are readily removed by activated carbon include aromatics,
phenolics, chlorinated hydrocarbons, surfactants, organic dyes, organic acids,
higher molecular weight alcohols, and amines. Activated carbon has also been
effective for the removal of some metals and cyanide.
Equipment Description: There are two forms of activated carbon in widespread
use, granular and powdered. Granular is used most often for wastewater
treatment because of its ease of regeneration. Granular activated carbon is about
0.1 to 1 mm in diameter and is loaded into columns or beds. Wastewater either
flows down or is forced up through the column or bed. There are many different
design configurations of carbon contact columns and beds, including gravity or
pressure flow, fixed or moving beds, and single or multi-stage arrangements.
Typical operations consist of two or more columns in series with a spare column.
As the first column reaches breakthrough (i.e., the concentration of the effluent
exceeds the desired concentration), this column is taken off-line, the partially
exhausted second column becomes the first column and the spare column
becomes the second column. The column taken off-line can be cleaned and
readied for use. When exhausted, carbon must be replenished, either through
replacement or thermal regeneration. Regeneration systems are used at many larger
facilities and consist of multiple-hearth furnaces to burn off organics and make the
interstitial surface sites available for further treatment.
Powdered activated carbon is smaller than granular carbon (50-70 microns) and is
usually mixed with wastewater to be treated. The carbon and wastewater is then
mixed to allow adequate contact, and then settled or filtered. Typically
countercurrent processes are used to maximize carbon efficiency.
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requirements are in any way altered by any statements) contained herein. Q 4?
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Types of Releases: Granular activated carbon systems will produce a spent
carbon that will either have to be hauled offsite for regeneration or disposal or may
be regenerated onsite.
Assessment Areas: Verify that spent carbon is managed appropriately (i.e.,
hazardous waste, if applicable). Document rationale for hazardous waste
determination.
> For granular activated carbon systems, determine procedures for identifying
column breakthrough and verify that procedure ensures column replacement
prior to actual breakthrough concentrations exist.
> For granular activate carbon systems, is pressure head loss monitored
continuously and if so, are there demonstrated losses that may be indicative of
column plugging?
> For powdered activated carbon systems, visually examine effluent for signs of
carbon fines in the effluent that may go untreated.
* Are there indications of solids or oils in the influent stream to the carbon system
that could hinder its performance?
Steam Stripping
Process Description: Steam stripping is a fractional distillation process used to
remove volatile compounds from a wastewater stream. Stripping occurs because
organics vaporize into the steam until its concentration in vapor and liquid is in
equilibrium.
Application: Steam stripping is designed to remove individual volatile pollutants
based on Henry's Law Constants (the higher the constant, the more easily stripped).
The volatile component may be a gas or an organic compound that is soluble in
the wastewater. Additionally, removal of immiscible compounds (chlorinated
hydrocarbons) is performed via steam stripping. Steam stripping can be used as an
in-plant process to recover organics from concentrated aqueous streams or as an
end-of-pipe treatment for removal of organics in dilute wastestreams. Steam
stripping is particularly effective for compounds that are required to meet trace
levels.
Equipment Description: Steam stripping is typically performed in packed towers
or conventional fractionating distillation columns (bubble cap or sieve tray) with
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q AO
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multiple vapor/liquid contact stages. While packed towers are less expensive, tray
towers are typically used in the chemical industry because of increased efficiency
and ease of access for cleaning. Preheated wastewater enters around the top of
the column and flows down through superheated steam rising up from the bottom
of the column. The contact reduces the concentration of VOCs or gases in the
wastewater as it flows down to the bottom of the column. Heat from the treated
wastewater is used to preheat the feed to the top of the column. The height of
the column and the amount of packing material and/or the number of metal trays
along with steam pressure in the column generally determine the amounts of
volatiles that can be removed. Steam exiting the top of the column is condensed
and forms two layers of generally immiscible liquids. The aqueous layer is typically
recycled back to the stripper influent with the volatiles recycled to the process, or
disposed. For soluble organics, the condensed stream will likely have to be
disposed.
Types of Releases: Stripping columns will have similar emissions as those
described for distillation columns. The most obvious emission is the overhead
waste stream of concentrated organic pollutants that have been stripped from the
wastewater (approximately one percent of the volume of the untreated
wastestream). This wastestream must be disposed, often by onsite incineration.
Also, cleaning of the columns (for scaling or fouling problems) will generate waste
solids and liquids.
Assessment Areas: Emission control should be provided for noncondensibles
from the stripper.
> Check column efficiency over time for potential scaling/fouling problems.
> Evaluate temperature/pressure fluctuations over time for potential operational
problems.
* For excessive scaling in column, evaluate pretreatment techniques that may
reduce these problems.
> Determine whether the condensed overhead stream is a hazardous waste.
This manual is intended solely for guidance. No statutory or regulatory
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3.3 SOLID WASTE TREATMENT AND DISPOSAL PROCESSES/
EQUIPMENT
3.3.1 ON-SITE SOLID WASTE LANDFILL
Unit Description
A solid waste landfill is an area of land or an excavation in which unwanted residual
solid or semisolid wastes are placed for permanent disposal, and that is not a land
application unit, surface impoundment, injection well, or waste pile. Solid waste
landfills require a permit to be installed and operated from the state in which they are
located. A landfill is distinguished from an open dump in that an open dump is a
facility for the disposal of solid waste that does not comply with the requirements
of 40 CFR Part 257.
Many states have regulations specific to on-site solid waste landfills that exist
exclusively for disposal of materials from the on-site facility.
Application
Solid waste landfills are used for disposal of solid waste. Solid waste generally
includes any garbage, refuse, sludge and other discarded material, including solid,
semisolid, or contained gaseous material resulting from industrial, commercial,
mining, and agricultural operations. Solid waste generally does not include waste
regulated under the Clean Water Act, such as solid or dissolved materials in
domestic sewage, or solid or dissolved material in irrigation return flows, or
industrial discharges which are point sources subject to NPDES permits. Solid
waste also does not include source, special nuclear, or byproduct material as
defined by the Atomic Energy Act of 1954.
Solid waste is produced by many processes in the Synthetic Organic Chemical
Manufacturing Industry (SOCMI). For example, sludges removed from tank
bottoms during periodic cleaning; spent catalysts discarded as solid wastes
from reactors; scale and settled solids from condensers, evaporators, pipes, valves
and connectors; and filter cakes from the filtration process are all solid waste.
Equipment Description
Solid waste landfills can be natural attenuation type landfills or containment type
landfills. Natural attenuation type landfills are older landfills that were developed
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before implementation of design standards currently established under federal and
state requirements. They have no liner, and minimum design requirements, if any
exist, are usually a minimum allowable thickness of unsaturated zone, a minimum
depth to bedrock, and a minimum distance to the nearest well.
Containment type landfills usually have at least a single liner, leachate collection
system, and extensive geologic location restrictions.
Natural attenuation landfills are currently prohibited from use in many areas by
state or local regulations or geographic restrictions.
Elements of containment type landfills that need to be considered during design
and operation include leachate collection systems, synthetic membranes, berms
and berm design, stormwater routing, stability of waste slope, access to the landill,
landfill cover, gas venting system, and geographic location/restrictions.
This manual is intended solely for guidance. No statutory or regulatory
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Pollutant
Phase
Gas/vapor
Potential Sources of
Emissions/Releases
Methane gas from
decomposition of
organic material;
hazardous air pollutants;
criteria air pollutants;
odor
Assessment Considerations
(look at, look for, think about)
At least quarterly monitoring for
methane gas
State SIP provisions must not be
violated - check monitoring reports
against limits established in individual
permits to operate; open burning is
prohibited - look for signs of open
burning
At least six inches of cover must be
placed over fill daily at a minimum or
at more frequent intervals as
necessary to control odor
40 CFR 258.23 and -.24 - explosive
gas control and air criteria
40 CFR258.21-cover
requirements
Liquid
Surface water run-off
during a storm; leachate
outbreaks; leachate
management;
groundwater migration
Proper operation and maintenance
of landfill to prevent run-on to the
active portion of the facility during
peak discharge from a 25-year
storm
Proper operation and maintenance
of system to collect and control run-
off from active portion of the facility
for the water volume of at least a
24-hour, 25-year storm
That no seeps, liquids, or areas of
soil discoloration are present on
graded or completed surfaces of the
landfill
That run-off is discharged in
accordance with NPDES permit
requirements and Clean Water Act
requirements for wetlands and
water quality management plans
That no liquid waste is placed into
the landfill
Proper operation and maintenance
of finer and leachate collection
system designed to maintain less
than a 30 cm depth of leachate over
the finer (new landfills or as specified
in permit to install or operate)
Proper implementation of
groundwater monitoring
requirements as specified for the
individual facility in its permit or
Ucense
40 CFR 258.26 - surface water run-
on and run-off control
40 CFR 258.28 - Uquids restriction
40CFR258.40(a)(2)-leaschate
collection system
40 CFR 258.40 - finer requirements
40CFRPart258SubpartE-
groundwater monitoring
requirements and corrective action
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-47
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Pollutant
Phase
Solid
Potential Sources of
Emissions/Releases
Litter; disease vectors;
dumping of waste
outside of active portion
of landfill
Assessment Considerations
(look at, look for, think about)
At least six inches of cover must be
placed over fill daily at a minimum or
at more frequent intervals as
necessary to control Utter and
disease vectors
Access is appropriately restricted so
that no illegal dumping can occur
Confirm that procedures are in
place for detecting and preventing
the disposal of regulated hazardous
wastes (assessment records,
training)
Review daily log; assessment
records; training procedures;
notification procedures; gas
monitoring results and any
remediation plans; leachate
arrangements; groundwater
monitoring records and plans as
required; closure and post-closure
plans; evidence of financial
responsibility; and information
demonstrating compliance with
small community exemption
40 CFR258.21 -cover
40 CFR 258.40 - finer requirements
40 CFR258.25-access
requirements
40 CFR 258.20 - procedures for
excluding receipt of hazardous
wastes
40 CFR 258.29 - record keeping
requirements
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-48
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3.3.2 SLUDGE INCINERATION
Process Description
Any of several types of incinerators can be used to treat either RCRA hazardous or
nonhazardous sludge, among which are liquid injection systems, stationary and
mobile rotary kilns, or fluidized-bed thermal oxidizers (circulating-bed
combustors). The basic sludge incineration process is the same for each: sludge
feed is placed into an incinerator, along with air and auxiliary fuel, that then
produces ash and gases and combustion products. Scrubbers may be used to
clean gases formed in the incinerator, generating wastewater that requires
proper treatment and discharge. Baghouses for the reduction of particulates in off
gases from sludge incineration may also be employed. During sludge incineration
the organics are fully oxidized, which is the goal of sludge incineration.
Some drawbacks occur with thermal treatment. Sometimes dangerous gases are
formed, such as hydrochloric acid from polyvinyl chloride plastics. Some materials
only burn at extremely high temperatures. Also, toxic air emissions may create air
quality problems and health concerns.
Application
Use of liquid injection incinerators for sludge incineration is limited to sludge that
can be pumped (properties of sludge and equipment design determine percent
solids content that can be handled by incinerator), although the liquid injection
technology is the most extensively used incineration method. Liquid injection
incinerators are useful for handling various liquid waste streams generated by the
chemical process industries.
Rotary kiln incinerators are more versatile than liquid injection incinerators, in that
rotary kiln incinerators can simultaneously burn liquids, slurries and solid wastes.
The fluidized-bed thermal oxidation process allows gas-solid contact, consistent
temperature control, and control of residence time. It is used extensively for
calcining, catalytic cracking of heavy oils, cooling, coal gasification, drying, and
combustion. This technology also can handle solids, liquids and sludges.
Equipment Description
Generally, for organic waste incineration, waste characteristics determine
incinerator design. Wastes occur in nonaqueous organic, aqueous organic with ash
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o 4 n
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(salt), and aqueous organic without ash forms. Aqueous organic wastes can be
mixed with inorganic wastes. However, inorganics are not destroyed during
incineration. Factors determining whether the organics are oxidized per waste
stream are temperature, time, and atomization or mixing.
Different components of a thermal treatment system are: a system for handling
materials and feeding them into the incinerator, along with controls for fugitive
emissions and spills; a combustor with an emergency vent system; a system for
managing ash, along with fugitive emission controls; a system for cleaning gas that
collects small particles and acids; a wastewater treatment and disposal system; a
process control system; and a continuous emission monitoring system.
Thermal treatment is a two stage process. Solids and other wastes are treated in
the primary stage. Gases produced in the primary stage are treated in the
secondary stage, along with other liquid wastes.
During the primary stage a wide range of operating conditions can be employed.
The primary stage can be performed in an oxidative mode, a pyrolytic mode, or a
desorption mode. The oxidative mode uses excess air conditions to combust the
organics and volatilize the inorganics at 760 to 980 degrees C (1400 to 1800
degrees F). The pyrolytic mode uses a carefully controlled air supply to evaporate
and partially combust the volatiles, and the residuals are thermally decomposed at
500 to 760 degrees C (1000 to 1400 degrees F). The desorption mode supplies heat
to the chamber from an external source, which keeps air from entering the chamber,
reaching 250 to 450 degrees C (500 to 850 degrees F). Combustion does not
occur in this method; volatile constituents are evaporated and separated from the
nonvolatile constituents.
Secondary stage treatment of gases generated in the primary stage depends on
organic content and method used during the primary stage. In the secondary
stage, gases are combined with air and combusted in a separate chamber.
Secondary treatment can also be performed by condensing organic vapors to the
liquid form, then treating them with chemicals rather than heat.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o en
-------
Pollutant
Phase
Potential Sources of
Emissions/Releases
Assessment Considerations
(look at, look for, think about)
Gases/vapors
Particulates and gas
leaks from the
materials handling and
feed system ; dust and
participates from ash
handling system; gas
cleaning system
(scrubbing)
Review documentation for
incinerator - the conditions
specified in the permit to
operate, the daily incinerator
plant log, records for
calibration of pressure and
temperature gauges, stack
testing records, records on
maintenance repair of
incinerator facilities, and the
general correspondence file
on incinerator operations.
Confirm that monitoring
equipment is properly
maintained.
Confirm that incinerator
operations are maintained at
correct temperature
requirements and charging
rates.
Hazardous waste incinerators must
comply with 40 CFR Part 264 Subparts A
through H, Treatment, Storage and
Disposal Facility Standards, and Subpart
O, Incinerators.
Incinerators must meet air emission
requirements for carbon monoxide,
hydrocarbon, and nitrogen oxides.
Liquids
Aqueous portion of
sludges from the
material handling
feed system,
wastewater discharge
from scrubber may
spill or leak;
wastewater from the
scrubber may contain
heavy metals or
suspended solids or
require pH
adjustment
Visually observe equipment
and adjacent soils for evidence
of spills or leaks, or evidence
of previous problems.
Evaluate records of any spill
volumes. If volumes exceed
reportable quantities, request
copy of spill report and
associated correspondence.
Review existing NPDES permit
for requirement of additional
reports such as a Storm Water
Pollution Prevention Plan or
Best Management Plan
Document. Inspect
documents to be sure they are
up to date and assessments
are being conducted as
planned.
Review site maps showing
locations of floor drains and
storm and sanitary sewer
connections to determine
possibility of improper
discharge of process wastes.
Review any Notice of
Violations on wastewater
discharges.
40 CFR Parts 116 and 117, Designation
of Hazardous Substances and
Determination of Reportable Quantities
for Hazardous Substances, designate
hazardous substances and reportable
quantities of those hazardous substances.
See CWA regulations.
If a hazardous substance leaks or spills,
Emergency Planning and Community
Right-to-Know Act (EPCRA) requirements
apply if reportable quantity is released.
See EPCRA regulations.
If scrubber wastewater goes to
wastewater treatment system: NPDES
permit requirements or General
Pretreatment Standards at 40 CFR Part
403. Source effluent limits or categorical
pretreatment standards at 40 CFR 414,
439, 454, or 455 may apply.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-51
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Pollutant
Phase
Potential Sources of
Emissions/Releases
Assessment Considerations
(look at, look for, think about)
Solids
Sludges from
treatment of scrubber
wastewater treatment
and from filtering; ash
as residue from the
thermal stage; salts
from acid gases
produced during
combustion;
particulates from
baghouse operations
Confirm that ash and sludges
are properly characterized as
either hazardous or
nonhazardous, as determined
by whether process materials
are listed under RCRA, by
process knowledge, and by
actual waste characteristics
based on testing. Evaluate
how waste is characterized
and documented.
Observe waste management
procedures and practices for
sludge, salt and baghouse
operations residue; the
conditions and areas of
removal, and how the wastes
are stored and disposed.
Visually observe areas of waste
handling/removal to ensure
wastes have not been spilled.
For hazardous waste facilities,
examine assessment records
for malfunctions or
deterioration of process
equipment that may cause a
release.
If RCRA hazardous waste is generated,
owners/operators must comply with the
generator requirements. See Appendix
E-3-1 and E-3-2. Waste analysis and
record keeping requirements of 40 CFR
Part 268.7 (b) and (c) apply. Treatment,
storage and disposal requirements of 40
CFR Part 264 Subparts A through H
apply. See RCRA regulations.
If the waste tests out to be solid waste, it
must be managed in accordance with
both Federal rules at 40 CFR Part 258
and individual state rules.
If hazardous substance spills, Emergency
Planning and Community Right-to-Know
Act (EPCRA) requirements apply if a
reportable quantity is released. See
EPCRA regulations.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-52
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3.3.3 HALOGEN ACID FURNACE
Process Description
A halogen acid furnace is a type of liquid-injection incineration. In liquid-injection
incineration, aqueous waste material is used as a fuel, which is burned directly in a
combustor or injected into a flame zone or combustion zone of a furnace through
a nozzle. Factors that affect whether the waste stream is properly oxidized are the
method of injecting the liquid into the furnace or combustor, the right combination
of air and liquid in order to obtain maximum combustion with minimum formation
of byproducts such as soot, and the heating or caloric value of the waste fuel. The
method of injecting the liquid into the furnace or combustor is important in that it
disperses the liquid as a mist or vapor in such a way that the fuel is evenly
distributed and has sufficient kinetic energy to burn efficiently, and it controls the
flow of material into the combustor or chamber. When a maximal combination of
air and liquid is attained, the internal heat energy of the system assists in the
combustion, increasing the efficiency of the system. Fuels with solids or ash
content will have a lower caloric value. In addition, these fuels may have solids that
agglomerate, so the system must be designed in a way that prevents or minimizes
agglomeration and allows the particulate matter to pass out with the gas stream or,
as appropriate, allows ash to pass through to the quench zone. Scrubbers may be
used to clean gases formed in the furnace, generating a wastewater that requires
proper treatment and discharge.
In a halogen acid furnace, halogenated waste materials are injected into the
combustor or furnace, where the chlorine content is converted to hydrochloric
acid, which can be recycled. Caloric value of the halogenated wastes depends on
chlorine content, with higher caloric values for materials with greater chlorine
content, such as wastes produced in the vinyl chloride monomer process. These
waste fuels tend to burn at higher temperatures and can therefore be injected
directly into the combustor or burner. Lower caloric value chlorinated waste
materials form significant amounts of soot when combusted. To reduce soot
formation, these fuels are mixed with large amounts of air. Large amounts of air
will cause the temperature to drop, so lower caloric value waste material is often
used with auxiliary fuel.
With higher caloric value wastes, higher temperatures are generated during
combustion, so refractory material must be chosen that will withstand the high
temperatures. Temperature control is often achieved through the use of water
and steam cooling.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q co
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Choice of refractory material is also important when the waste fuel has a high ash
content, as the ash will interact with the refractory material.
Higher caloric value wastes produce more hydrochloric acid, while lower caloric
value wastes produce more soot and free chlorine. More free chlorine requires
greater pollution control capabilities, as the scrubber system must have caustic in
the final tails tower to trap the free chlorine.
Application
Halogen acid furnaces are used to incinerate halogenated waste materials
produced in large volumes in the plastics industry, such as in the vinyl chloride
monomer, polyvinyl chloride, propylene glycol, and chlorinated elastomers
processes. In halogen acid incineration, the goal is to convert as much of the
chlorine content as possible to hydrogen chloride, which is then absorbed in water
and can be recycled. The pharmaceutical industry and the agricultural process
industries that manufacture pesticides and herbicides tend to produce aqueous
waste fuels with high ash (salts) and solids content.
Equipment Description
In general, liquid injection incinerators are composed of a horizontal or vertical
cylindrical chamber lined with refractory material and a primary combustor and
often a secondary combustor or injection nozzle that can atomize the fuel.
The complete incinerator system is comprised of the following equipment as well:
storage tanks, mixers, pumps, control valves, piping, heat recovery, quench system
and air pollution control equipment.
Mixing of the fuel occurs in the storage tank, to prevent waste fuel from layering.
Gases that build up in the tank are usually exhausted to the incinerator chamber.
Sometimes filters are used to filter out inorganic solids from the feed mix before it
enters the incinerator.
Pumps are often used to pump the feed mix through the fuel lines into the
incinerator.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q CA
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Pollutant
Phase
Potential Sources of
Emissions/Outputs
Assessment Considerations
(look at, look for, think about)
Gases/vapors
Particulates and gas
leaks from the
materials handling
and feed system;
dust and particulates
from ash handling
system; gas cleaning
system (scrubbing)
Review documentation for
incinerator: conditions
specified in the permit to
operate, the daily incinerator
plant log, records for
calibration of pressure and
temperature gauges, stack
testing records, records on
maintenance repair of
incinerator facilities, and the
general correspondence file
on incinerator operations.
Confirm that monitoring
equipment is properly
maintained.
Confirm that incinerator
operations are maintained at
correct temperature
requirements and charging
rates to meet applicable
permit or regulatory
requirements.
Hazardous waste incinerators must comply
with 40 CFR Part 264 Subparts B through
H, Treatment, Storage and Disposal Facil-
ity Standards, and Subpart O, Incinerators.
Incinerators must meet air emission
requirements for carbon monoxide,
hydrocarbon, and nitrogen oxides.
Liquids
Wastewater
discharge from
scrubber may spill or
leak; wastewater
from the scrubber
may contain heavy
metals or suspected
solids or adequate
pH adjustment
Visually observe equipment
and adjacent soils for evidence
of spills or leaks, or evidence
of previous problems.
Evaluate records of any spill
volumes. If volumes exceed
reportable quantities, request
copy of spill report and
associated correspondence.
Scrubber wastewater
discharge should be delivered
to plant wastewater
treatment system.
Review existing NPDES
permit for requirement of
additional reports such as a
Best Management Document.
Inspect documents to be sure
they are up to date and
assessments are being
conducted as planned.
40 CFR Parts 116 and 117, Designation of
Hazardous Substances and Determination
of Reportable Q uantities for Hazardous
Substances, designate hazardous
substances and reportable quantities of
those hazardous substances.
If a hazardous substance leaks or spills,
Emergency Planning and Community
Right-to-Know Act (EPCRA) requirements
apply if reportable quantity is released.
Depending on how process wastewater is
managed: NPDES permit requirements or
General Pretreatment Standards at 40 CFR
Part 403 and if applicable, source effluent
limits or categorical pretreatment standards
at 40 CFR 414, 439, 454, or 455.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-55
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Pollutant
Phase
Potential Sources of
Emissions/Outputs
Assessment Considerations
(look at, look for, think about)
Liquids
(continued)
Wastewater
discharge from
scrubber may spill or
leak; wastewater
from the scrubber
that may contain
heavy metals or
suspended solids or
require pH
adjustment
Review site maps showing
locations of floor drains and
sanitary and storm sewer
connections to determine the
possibility of improper
discharge of process waters.
Review any Notice of
Violations on wastewater
discharges
(Note: process wastewater would have to
be treated. It could be treated at the plant
WWTP or it may be able to be discharged
to the POTW to be treated. If treated at
the plant WWTP, it will probably be
discharged to surface water under an
NPDES and must meet source effluent
limits, if they apply. If discharged to a
POTW, it would have to be pretreated to
meet categorical pretreatment standards, if
they apply.)
Solids
Sludges from
treatment of
scrubber
wastewater and
from filtering; ash as
residue from the
thermal stage; salts
from acid gases
produced during
combustion;
particulates from
baghouse operations
Confirm that ash and sludges
are properly characterized as
either hazardous or
nonhazardous, as determined
by whether process materials
are listed under RCRA, by
process knowledge, and by
actual waste characteristics
based on testing. Evaluate
how waste is characterized
and documented.
Observe waste management
procedures and practices for
sludge, salt and baghouse
operations residue; the
conditions and areas of
removal, and how the wastes
are stored and disposed.
Visually observe areas of
waste handling/removal to
ensure wastes have not been
spilled. For hazardous waste
facilities, examine assessment
records for malfunctions or
deterioration of process
equipment that may cause a
release.
If RCRA hazardous waste is generated,
owners/operators must comply with the
generator requirements. Waste analysis
and record keeping requirements of 40
CFR Part 268.7(b) and (c) apply.
Treatment, storage and disposal
requirements of 40 CFR Part 264 Subparts
B through H apply.
If the waste tests out to be solid waste, it
must be managed in accordance with both
Federal rules at 40 CFR Part 258 and
individual state rules.
If hazardous substance spills, Emergency
Planning and Community Right-to-Know
Act (EPCRA) requirements apply if report-
able quantity is released. See EPCRA
regulations.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-56
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3.3.4 SURFACE IMPOUNDMENT
Process Description
A surface impoundment is a natural topographic depression, man-made
excavation, or diked area formed primarily of earthen materials, although it may be
lined with man-made materials. It is designed to hold an accumulation of liquid
wastes or wastes containing free liquids, is exposed to the atmosphere, and
is not an injection well. Examples of surface impoundments are holding,
storage, settling, and aeration pits, ponds, lagoons, open-top tanks, and
wastewater treatment systems.
Surface impoundments may be operated in either a quiescent or an aerated mode.
Aerated mode operation is used for solar evaporation or, more often, biological
treatment. Quiescent mode operations include clarification, settling, equalization,
storage, biological treatment, and disposal.
Air emissions of concern from operating surface impoundments are volatile organic
compounds (VOCs). The emission rate of VOCs from operating surface
impoundments depends on the fate of the hazardous components in the surface
impoundment. Three possible fates for VOCs in the surface impoundment are
volatilization, biological or chemical degradation, and adsorption.
Measuring emissions from surface impoundments is difficult as emissions come
from a wide area and not a point source. Emissions can be controlled by
removing the VOCs before placing the liquids in the impoundment; by special
design or operating conditions, such as lowering the temperature of incoming
liquids or designing a smaller impoundment surface area; by cleaning less
frequently; or by installing covers and vapor barriers.
During closure of surface impoundments, both particulates and VOC emissions are
of concern.
Application
Surface impoundments can be used to treat, store or dispose of liquid hazardous
or nonhazardous waste. Federal and state regulations exist for surface
impoundments managing liquid hazardous waste.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. Q cy
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Equipment Description
Surface impoundments used for disposal of hazardous waste are required to have
two liners with a leachate collection and removal system between the liners. The
liners function to contain the liquid and minimize migration of liquid into the
groundwater. The top liner is required to be a geomembrane, or flexible
membrane liner (FML), while the bottom liner is required to be a composite
system, with a minimum 3-foot thick compacted soil component.
Associated equipment with surface impoundments can include emissions
measuring equipment and covers along with gas treatment systems, if necessary.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. o co
-------
Pollutant
Phase
Potential Sources of
Emissions/Outputs
Assessment Considerations
(look at, look for, think about)
Gases/vapors
Evaporation of VOCs
into atmosphere;
vents in covers;
participates during
closure
Review records to confirm
volatile organic concentration
of waste materials in surface
impoundment.
If applicable, review records
and observe cover to ensure
proper design, construction,
operation and maintenance.
Ensure that the appropriate
cover type is used for the
treatment method.
Confirm that exhaust gases are
properly managed.
Surface impoundments that contain
volatile organic compounds (VOCs) must
comply with 40 CFR Part 264 Subpart
CC, Air Emission Standards for Tanks,
Surface Impoundments, and Containers.
Liquids
Leaks; overflows;
stormwater run-on
and run-off;
groundwater
contamination
If RCRA impoundment, ensure
that design and operation
requirements are met,
including leachate collection
and removal system, leak
detection system and liner
system. Determine if action
leakage rate has ever been
exceeded and if appropriate
response actions have been
taken if exceeded. Determine
if monitoring and weekly and
post storm assessments have
been conducted to examine
for leaks or problems.
Determine if groundwater
monitoring program exists and
is being followed.
Ask for records of any spill or
overflow volumes. If volumes
exceed reportable quantities,
ask for copy of spill report and
associated correspondence.
Observe operating conditions
to ensure that overfilling is not
occurring.
Observe integrity of dikes.
Visually observe for leaks.
Review assessment records to
ensure that weekly
assessments are conducted,
and other assessments as
required.
40 CFR Parts 116 and 117, Designation
of Hazardous Substances and
Determination of Reportable Quantities
for Hazardous Substances, designate
hazardous substances and reportable
quantities of those hazardous substances.
See CWA regulations.
If hazardous substance leaks or spills,
Emergency Planning and Community
Right-to-Know Act (EPCRA) requirements
apply if reportable quantity is released.
See EPCRA regulations.
Hazardous waste surface impoundments
must comply with 40 CFR Part 264
Subpart K, Surface Impoundments. See
Appendix E-3-6. This rule requires
storm water run-on and run-off controls
and prescribes groundwater monitoring
requirements.
If applicable, NPDES storm water permit
requirements at 40 CFR 122.26, Storm
Water Discharges. Storm water permit
requirement for industrial activities
depends on the kind of industry.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-59
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Pollutant
Phase
Potential Sources of
Emissions/Outputs
Assessment Considerations
(look at, look for, think about)
Liquids
(continued)
Leaks; overflows;
stormwater run-on
and run-off;
groundwater
contamination
Review existing NPDES permit
for storm water discharge
requirements. Inspect
documents to be sure they are
up to date and assessments
are being conducted as
planned.
Review site maps showing
locations of storm sewers;
review storm water sampling
results.
Solids
Sludges/solids from
cleaning operations
Sludges/solids will be either
solid waste or hazardous
waste, as determined by
whether waste materials in
surface impoundment are
listed under RCRA, are known
by process knowledge to be
RCRA regulated and/or by
actual waste characteristics
based on testing.
Evaluate how sludge is
characterized and
documented.
Visually observe areas of
sludge handling/removal to
ensure sludge has not been
spilled.
If RCRA hazardous waste is generated,
owners/operators must comply with the
generator requirements. Treatment,
storage and disposal requirements of 40
CFR Part 264 Subparts a through H
apply. Land disposal restrictions of 40
CFR Part 268 may apply.
If the waste tests out to be solid waste, it
must be managed in accordance with
both Federal rules at 40 CFR Part 258
and individual state rules.
If hazardous substance spills, Emergency
Planning and Community Right-to-Know
Act (EPCRA) requirements apply if report-
able quantity is released. See EPCRA
requirements.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
3-60
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Appendix A
Clean Air Act (CAA)
The Clean Air Act (CAA), with its 1990 amendments, sets the framework for air pollution
control as it affects the organic chemical manufacturing industry. This framework has several
elements based upon individual titles in the CAA. The applicable CAA titles and the
regulations and guidelines developed pursuant to the CAA are illustrated in Exhibit A-l and
are discussed below.
Exhibit A-1. CAA Statutes and Regulatory Requirements for Organic
Chemical Facilities
Clean Air Act
Title I Attainment and Maintenance of National Air Ambient Quality Standards
Title III Air Toxics
Title V Permitting of Title I and III Sources
Title VI Stratospheric Ozone Sources
Title 1
40 CFR Part 50 NAAQS
40 CFR Part 60 New Source
Performance Standards
New Source Review (NSR)
Reasonable Available Control
Technology (RACT)
Guidelines
Title III
40CFRPart61NESHAP
40 CFR Part 63 NESHAP
Maximum Achievable
Control Technology
(MACT) Standards
Title V
40 CFR Part 68
Chemical Accident
Prevention Provisions
40 CFR Part 70
or
40 CFR Part 71
Several portions of Title I of the CAA address
requirements for the attainment and
maintenance of National Ambient Air Quality
Standards (NAAQS). The central
components of the regulatory scheme of the
Act may be said to include the following:
> Section 107 pertaining to Air
Quality Control Regions;
Clean Air Act
National Primary and Secondary Ambient Air
Quality Standards A-2
National Emissions Standards for Hazardous
Air Pollutants (NESHAP) and Maximum
Achievable Control Technology (MACT)
Standards A-6
Permitting Program A-7
Chemical Accident Prevention A-9
Stratospheric Ozone Protection A-9
CAA Assessment Considerations A-10
CAA Regulatory Requirements A-12
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-l
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* Section 109 pertaining to National Ambient Air Quality Standards;
* Section 110 pertaining to State Implementation Plans;
> Section 111 pertaining to New Source Performance Standards; and
* Section 112 pertaining to National Emission Standards for Hazardous Air
Pollutants.
Title V Permits will apply to major sources covered under Title I, as well as sources covered
under other Title of the Act.
Title VI of the CAA deals with ozone-depleting chemicals. Several solvents used in the
organic chemical industry are affected by this law. Regulations under Title VI which affect the
organic chemical industry are discussed in a section of the appendix.
Finally, the specific regulatory requirements developed pursuant to the CAA are described in
the last section of this appendix.
National Primary and Secondary Ambient Air Quality Standards
Title I of the CAA establishes the statutory authority for EPA's National Ambient Air Quality
Standards (NAAQS) that are to be applied uniformly throughout regions in the United States.
The Air Quality Act of 1967 required the designation of air quality control regions (AQCRs)
based on "jurisdictional boundaries, urban-industrial concentrations, and other factors including
atmospheric area necessary to provide adequate implementation of air quality standards" [Section
107(a) (1967)]. Today, the United States is divided into 247 AQCRs. Many AQCRs are sub-
divided into smaller areas based on municipal boundaries, latitudes and longitudes, and other
boundaries. A complete list of AQCRs (and their attainment status) is codified at 40 CFR Part
81. An air quality control region is classified as a "nonattainment" area if an NAAQS is violated
anywhere in the region. (In the case of ozone, a violation occurs if the 4th highest reading
over any 24-hour period in the past 3 years exceeds the NAAQS for ozone.) Two types of
NAAQS are set:
(1) Primary standards that define the level of air quality necessary to prevent any
adverse impact on human health, and
(2) Secondary standards that define the level of air quality necessary to protect the
public welfare from any known or anticipated adverse effects of a pollutant.
These standards, promulgated in 40 CFR Part 50, recognize that the severity of the adverse
health effects associated with exposure often depends on the duration of exposure.
Accordingly, "short-term" standards set limits for a 1-hour, an 8-hour, or a 24-hour period,
while "long-term" standards are established on an annual basis.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A _o
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The EPA has set NAAQS for ozone, carbon monoxide, particulate matter of 10 microns or
less (PM-10), sulfur dioxide (SOX), nitrogen dioxide (NOX), and lead. These standards are
used as a foundation for the regulatory framework discussed in this section. Of the six
pollutants, the NAAQS for ozone, NOX, CO, SOX and particulate matter are likely to have a
significant impact on the organic chemicals industry.
Existing Sources of Emissions
Ozone N on-attainment Areas
The "design value" shown in the third column of Exhibit A-2 is compared to the 4th highest
reading taken over any 2 4-hour period during 3 concurrent years in a nonattainment area.
Based on this value, a nonattainment area is classified as Marginal, Moderate, Serious, Severe,
or Extreme. As shown in Exhibit A-2, attainment deadlines are based on a sliding scale that
reflects the severity of the pollution, where the trigger date is the date when an area is
designated as nonattainment.
Exhibit A-2. Classification of Ozone Nonattainment Areas
Classification
Marginal
Moderate
Serious
Severe
Extreme
Deadlines to Attain
(from November 15, 1990)
3 Years
6 Years
9 Years
1 5 Years
17 Years
20 Years
Design Value (ppm)
0.121 -0.138
0.138-0.160
0.160-0.180
0.180-0.190
0.190-0.280
Above 0.280
A major source is defined both by the size of the source's facility-wide emissions and the
category of the nonattainment area. These conditions are presented in Exhibit A-3. In
addition, if a firm has the potential to emit more than 100 tons per year (TPY), it is also
considered to be a major source. The statement "potential to emit" means the maximum
capacity of a stationary source to emit a pollutant under its physical and operational design.
Thus operating below capacity does not exclude a plant from being defined as a major
source. Any physical or operational limitations on the capacity of the source to emit a
pollutant, provided the limitation or its effect on emissions is federally-enforceable, are treated
as part of its design and therefore, could mean exclusion from the major category.
Each State is required to develop a State Implementation Plan (SIP) for all nonattainment
areas. SIPs contain a range of requirements that are designed to decrease ambient ozone
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-3
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concentrations. Part D of Title I of the CAA provides the authority for implementation of
Reasonably Available Control Technology (RACT). A source defined as "major" in a
nonattainment area must install the RACT as prescribed in the applicable SIP.
Exhibit A-3. Major Source Classifications
Category of Nonattainment Area
Extreme
Severe
Serious
Moderate and Marginal
Size of VOC or NOX Sources Affected
(Tons/Year)
10
25
50
100
EPA has defined RACT as the lowest emission limitation that a particular source is capable of
meeting by the application of control technology that is reasonably available considering
technological and economic feasibility. RACT for a particular source is determined on a
case-by-case basis, considering the technological and economic circumstances of the
individual source. Further guidance for RACT is provided in the General Preamble published
on April 16, 1992, in 57 FR 13498-13570.
EPA regulations provide that less stringent emission limitations than those achievable with
RACT are acceptable only if the State plan shows that the less stringent limitations are
sufficient to attain and maintain NAAQS, and show reasonable further progress during the
interim before attainment.
A single ozone transport region exists for eleven states and the District of Columbia (the
northeast ozone transport region). States included in an ozone transport region must submit
SIPs to the EPA with special requirements pertaining to enhanced vehicle inspection and
maintenance programs and implementation of RACT with respect to all sources of volatile
organic compounds in the States. In addition, a stationary source in an ozone transport
region that emits or has the potential to emit at least 50 TPY of VOCs or NOxs is
considered a major source and is subject to the requirements which would be applicable to
major stationary sources if the area were classified as a Moderate nonattainment area.
A determination of the applicable RACT requirements for major sources is usually made by a
State on the basis of a case-by-case review of each facility. In an attempt to issue uniform
source guidelines, EPA issues Control Techniques Guidelines (CTGs) for industrial categories.
The specific CTGs for a source are available through EPA's Technology Transfer Network.
There are several CTGs relevant to Organic Chemical Plants regarding the control of Volatile
Organic Compounds (VOCs) from organic chemical and polymer manufacturing, petroleum
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A _A
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and volatile organic liquid storage, and wastewater operations. Available information on the
specific CTGs in included in Appendix H.
New Source Review
Persons constructing new major stationary sources of air pollution or making modifications to
major stationary sources are required by the Clean Air Act to obtain a permit before
commencing construction. The process is called new source review (NSR) and is required
whether the major source or modification is planned for an area where the NAAQS are
exceeded (nonattainment areas) or an area where air quality is acceptable (attainment and
unclassifiable areas). Permits for sources in attainment areas are referred to as prevention of
significant air quality deterioration (PSD) requirements and include the following:
Installation of Best Available
Control Technology (BACT);
A detailed air quality analysis
showing that there will be no
violation of PSD "increments;"
Prediction of future air quality
standards;
Possible monitoring of air
quality for 1 year prior to the
issuance of the permit; and
EPA determines BACT requirements by:
(1) identifying all control technologies;
(2) eliminating technically infeasible
options; (3) ranking remaining control
options by control effectiveness; (4)
evaluating the most effective controls
and documenting results; and (5)
selecting BACT. See Draft New Source
Review Workshop Manual, U.S. EPA,
Office of Air Quality Planning and
Standards, October 1990.
> Demonstration of standard attainment through the undertaking of an air quality
analysis.
Restrictions in nonattainment areas are more severe. The principal requirements of NSR in
nonattainment areas are:
* Installation of Lowest Achievable Emission Rate (LAER) technology; LAER is
derived from either of the following: (1) the most stringent emission limitation
contained in the implementation plan of any State for such class or category of
source; or (2) the most stringent emission limitation achieved in practice by
such class or category of source. See CAA Part 171 (3).
* Provision for "offsets" representing emission reductions that must be made
from other sources. Emissions offsets are generally obtained from existing
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. AC
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sources located in the vicinity of a proposed source and must (1) offset the
emissions increase from the new source or modification and (2) provide a net
air quality benefit. The emission offset ratio depends on the category of the
nonattainment area and is listed in Exhibit A-4. In general, emission reductions
which have resulted from some other regulatory action are not available as
offsets. Nonattainment area major source permitting provisions are described
in 40 CFR Part 52.24. The PSD permitting provisions are described in 40 CFR
Part 52.21.
Exhibit A-4. Major Source Definitions and Offset Ratios in Ozone
Nonattainment Areas
Category
Marginal
Moderate
Serious
Severe
Extreme
Size of Major Source
(Tons/Year of VOCs and NO,s)
100
100
50
25
10
Offset Ratios
1.1:1
1.15:1
1.2:1
1.3:1
1.5:1
New Source Performance Standards (NSPS)
Major organic chemical industry sources must also comply with certain standards of
performance developed by EPA (promulgated as 40 CFR Part 60), irrespective of its location
in an attainment or nonattainment area. These are technology-based standards and are
commonly referred to as the New Source Performance Standards (NSPS). NSPS affect new
sources that are to be constructed or existing sources that undergo modifications after the
applicable deadlines. NSPS requirements for organic chemical industry sources include
monitoring, recordkeeping, and reporting. Further details on affected processes at major
organic chemical industry sources, dates of applicability and regulatory requirements are
provided later in this appendix.
National Emissions Standards for Hazardous Air Pollutants (NESHAP) and
Maximum Achievable Control Technology (MACT) Standards
The NAAQS apply to five primary pollutants and one secondary pollutant: ozone. Ozone
precursors typically regulated include VOC emissions from organic chemical industry sources
as part of the Part 60 requirements, discussed earlier in this appendix. However, additional
risk-based technology standards were developed by EPA for a few selected hazardous air
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-6
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pollutants prior to enactment of the 1990 Amendments to the CAA. These are commonly
referred to as NESHAP and were promulgated at 40 CFR Part 61. Like NSPS, NESHAP
requirements for organic chemical industry sources include monitoring, recordkeeping, and
reporting. Further details on affected processes at major organic chemical industry sources,
dates of applicability and regulatory are provided in the last section of this appendix.
Section 112 of the 1990 CAA identified 189 hazardous air pollutants (HAP) for which
standards of performance were to be developed based on maximum achievable control
technology rather than risk. Existing NESHAPs for those HAPs on the list of 189 would
however still apply. Accordingly, EPA promulgated the so-called hazardous organic NESHAP
(HON) rule as under 40 CFR Part 63 that sets the MACT standards applicable to the portion
of the organic chemical industry that is the synthetic organic chemical manufacturing industry
(SOCMI). Only major sources under Section 112(d) of the Clean Air Act will be regulated.
The standards codified under Subparts F, G, H and I of 40 CFR Part 63 regulate emissions of
112 of the 189 HAPs listed in the CAA. HON rule requirements for SOCMI sources include
monitoring, recordkeeping, and reporting. Further details on affected processes at major
organic chemical industrial facilities including those regulated as SOCMI sources, dates of
applicability and regulatory requirements are provided in the last section of this appendix.
Permitting Program
The CAA Title V (promulgated as 40 CFR Part 70) defines the minimum standards and
procedures required for State operating permit programs. The permit system is a new
approach established under the Amendments that is designed to consolidate all of a source's
requirements in one document (permit). In addition, State permit fees will generate revenue
to fund implementation of the program.
Any facility defined as a "major source" is required to obtain a permit. Part 70.2 defines a
source as a single point from which emissions are released or as an entire industrial facility that
is under the control of the same person(s), and a major source is defined as any source that
emits or has the potential to emit:
* 10 TPY or more of any hazardous air pollutant;
> 25 TPY or more of any combination of hazardous air pollutants; or
* 100 TPY of any air pollutant.
For ozone nonattainment areas, major sources are defined as sources with the Potential To
Emit (PTE):
> 100 TPY or more of volatile organic compounds (VOCs) or nitrogen oxides
(NOX) in areas defined as marginal or moderate;
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A 7
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> 50 TPY or more of VOCs or NOxs in areas classified as serious;
* 25 TPY or more of VOCs or NOxs in areas classified as severe; and
* 10 TPY or more of VOCs or NOxs in areas classified as extreme.
Other sources requiring permits regardless of source size include:
> NSPS
> NESHAP
> PSD/NSR
> Acid Rain
Calculation of the PTE at batch chemical manufacturing facilities is especially important in that
the maximum capacity of the facility to produce a variety of chemical products is less than the
sum of the capacity of each individual product since operation units may not be dedicated to
the production of a single chemical. EPA issued a guidance memorandum on August 29,
1996 defining the procedure for calculating PTEs at batch chemical facilities for use in
determining the applicability of Title V permitting requirements.
The permit requirement for non-major sources (i.e., area sources) has been deferred for five
years.
By November 15, 1993, each State must submit a design for an operating permit program to
the EPA for approval. The EPA must either approve or disapprove the State's program within
1 year after submission. Once approved, the State program goes into effect.
Major sources, as well as the other sources identified above, must then develop and submit
their permit applications to the State within 1 year (this will take place near the end of 1995).
Once a source submits an application, it may continue to operate until the permit is issued.
This may take years because permit processing allows time for terms and conditions to be
presented to and reviewed by the public and neighboring States, as well as by the EPA.
When issued, the permit will include all air requirements applicable to the facility. Among
these are compliance schedules, emissions monitoring, emergency provisions, self-reporting
responsibilities, and emissions limitations. Five years is the maximum permit term.
As established in Title V (40 CFR Part 70), the States are required to develop fee schedules to
ensure the collection and retention of revenues sufficient to cover permit program costs.
CAA sets a presumptive fee of $25 per ton for all regulated pollutants (except carbon
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A _o
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monoxide), but States can set higher or lower fees so long as they collect sufficient revenues
to cover program costs.
Chemical Accident Prevention
Title V of the CAA Amendments requires implementation of measures to prevent accidental
releases to the air to mitigate the consequences of such releases by focusing prevention
measures on chemicals that pose the greatest risk to the public and to the environment. In
response to this requirement, EPA promulgated 40 CFR Part 68 Chemical Accident
Prevention Provisions that outline requirements for stationary sources with processes that
contain more than a threshold quantity of a regulated substance. Specific program
requirements will be dependent on the likelihood of accidental releases from subject
processes with the less likely subject to streamlined prevention requirements. All sources are
required to prepare a risk management plan based on the risk management programs
established at the source with plans submitted to EPA by June 21, 1999, or later as identified
in §68.150, and available to the public. The goal of these regulations is to encourage sources
to reduce the probability of accidental releases of substances that have the potential to cause
immediate harm to public health and the environment and stimulate dialogue between
industry and the public.
Stratospheric Ozone Protection (40 CFR Part 82)
The CAA Amendments provide for a phase-out of the production and consumption of
chlorofluorocarbons (CFCs) and other chemicals that are causing the destruction of the
stratospheric ozone layer. Requirements apply to any individual, corporate, or government
entity that produces, transforms, imports, or exports these controlled substances.
Section 602 of the Clean Air Act identifies ozone-depleting substances and divides them into
two classes. Class I substances are divided into five groups. Section 604 of the Clean Air Act
calls for a complete phase-out of Class I substances by January 1, 2000 (January 1, 2002 for
methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are
generally seen as interim substitutes for Class I CFCs.
Class II substances consist of 33 HCFCs. The law calls for a complete phase-out of Class II
substances by January 1, 2030. The schedule for the HCFC phase-out has not yet been
finalized; however, EPA has proposed to begin phase-out of some HCFCs by 2002, with a
complete phase-out of all HCFCs to take place by 2030. This same proposal would
phase-out CFCs, carbon tetrachloride, hydrobromofluorocarbons, and methyl chloroform by
January 1, 1996.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A _n
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On February 11,1993, EPA issued a rule under Section 611 of the CAA that, effective May
15, 1993, requires both domestically produced and imported goods containing or
manufactured with Class I chemicals to carry a warning label. The rule covers items whose
manufacture involves the use of Class I chemicals, even if the final product does not contain
such chemicals.
Exports are exempt from this rule's labeling requirements, as are products that do not have
direct contact with these chemicals. In addition, if direct contact occurs but is non-routine and
intermittent (e.g., spot-cleaning of textiles), no labeling is required. Moreover, if a second
manufacturer incorporates a product made with an ozone-depleting chemical into another
item, the final product need not carry a label.
Section 608 of the CAA established the National Recycling and Emissions Reduction Program.
Effective July 1, 1992, EPA prohibited the venting of ozone-depleting compounds used as
refrigerants into the atmosphere during maintenance, service, repair, or disposal of air-
conditioning or refrigeration equipment. EPA also promulgated regulations at 40 CFR Part
82, Subpart F. Under 40 CFR Part 82, Subpart F on May 14, 1993 which establish standards
for service and disposal practices and to require leak repair. Under these regulations,
technicians servicing air-conditioning and refrigeration equipment must evacuate refrigerant
according to the prescribed guidelines. In addition, recovery and/or recycling equipment
used must be certified and all persons who maintain, service, repair, or dispose of appliances
must be certified.
Owners of industrial process refrigeration equipment (those with charges greater than 50
pounds) are required to repair substantial leaks. A 35 percent annual leak rate is established
for the industrial process and commercial refrigeration sectors as the trigger for requiring leak
repairs. Leak repair is required within 30 days of discovery or a 1-year retrofit or retirement
plan must be developed for the leaking equipment.
CAA Assessment Considerations
Under Title V of the 1990 Amendments, many CAA requirements have been summarized
into one comprehensive permit (risk management is an exception). In general, Title V
requirements (40 CFR Part 70 or 71) are the same as compliance provisions previously
required under the CAA. The facility's compliance assessorŽ should consider reviewing
data derived from previous facility self-assessments or when determining compliance with
Title V requirements. The regulatory inspection forms are generally organized around
process equipment (called emission units) and stacks or vents (called emission points).
The facility assessor should develop an assessment format where any enforceable limits and
the underlying regulatory requirements applying to the emission unit or the emission point
are listed so that they can be confirmed during the assessment.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-1 D
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In general, not all of the applicable requirements can be verified during a single self-
assessment and each assessment represents a "snapshot" of compliance. In recognition of
the fact that a facility assessor can not always be in place to detect violations, "baseline"
assessment techniques stress the importance of maintenance plans to ensure proper
operation and maintenance of equipment. Baseline assessment techniques also emphasize
tracking of operating parameters (such as incinerator temperatures) during assessments for
future use in accessing equipment performance. This focus on self-monitoring and self-
reporting was reinforced under Title V with requirements for enhanced monitoring, periodic
monitoring, compliance plans and programs and maintenance plans. The facility self-assessor
can rely upon baseline techniques to ensure that the systems and programs established for
self-monitoring and self reporting are appropriately designed and successfully implemented.
The draft Compliance Assurance Monitoring (CAM) Rule will supplant enhanced and periodic
monitoring requirements and focuses on the same type of monitoring of equipment
performance or other parameters that indicate compliance with applicable requirements. As
an example, a emission unit that controls emissions of volatile organic compounds (VOCs)
through exhaust gas incineration might have a lower allowable operating temperature of
1800°F. Using baseline assessment techniques, the assessor routinely records this operating
temperature. If this unit had traditionally operated at 2000°F, and now operated at 1825°F,
this would not constitute a violation of the 1800°F limit, but might indicate a potential for
violation and a need for follow-up actions. Under the CAM Rule, the facility might choose to
record and report this temperature to demonstrate continued compliance with applicable
requirements. However, the facility assessor should also initiate appropriate follow-up actions
to investigate the existence of a problem that might result in a violation of the requirement,
and pursue proactive compliance assurance measures.
The applicable CAA regulations for an organic chemical manufacturing facility will vary with
location. Those facilities located near urban areas are much more likely to be subject to
nonattainment provisions. Ozone nonattainment areas have RACT requirements on all major
sources of VOCs and NOX. RACT requirements vary with location and severity on
nonattainment; however, organic chemical manufacturing facilities would generally have
RACT requirements on reactors, distillation units, storage tanks, pumps and valves (see
Appendix E). NSPS requirements are based on the capacity of and on the age of regulated
units, but apply nationally to conforming units. NSR requirements generally contain the most
stringent emissions or performance limits and apply to new units as they are constructed.
BACT applies under the PSD program in areas that meet NAAQS; LAER applies under NSR
permits issued in nonattainment areas. MACT standards apply nationally based on magnitude
of emissions of 189 HAPs. Units that are subject to these requirements would receive
priority in an air quality inspection.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-1 1
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As discussed in the Overview, the process oriented self-assessment approach focuses on
following a process from start to finish and developing process flow diagrams to identify key
points for inspection. Previous facility assessment techniques generally focused more on
individual emission units and emission points without as much attention to understanding the
process. This type of approach is also more compatible with a multimedia self-assessment
technique in that the process diagrams could contain information on other items such as
wastewater discharge or pollution prevention activities.
Title V (or Part 70) permits will present new challenges to the compliance self-assessment.
One of these challenges will be inclusion of plantwide emissions limits or caps. Plantwide
caps offer operational flexibility to the permittee because changes in use of different processes
can occur and as long as overall emissions remain under the limits, no permit terms are
violated. The assessor will need to sum emissions from multiple processes in order to
determine compliance. Alternative operating scenarios are another example of Part 70
permit conditions that offer operational flexibility. Alternative operating scenarios describe
different methods of operation for process equipment; these scenarios will contain different
emissions limits based on different production modes. Confirmation of different limits on one
process substantially complicates the self-assessment. One other aspect of the Part 70 permit
is the permit-as-shield. If a facility is operating within the limits of the Part 70 permit, then the
permit shields the facility against charges of noncompliance for those activities.
As mentioned in the description of baseline inspection techniques, self-monitoring and self-
reporting activities are important to maintaining compliance. Part 70 requires compliance
programs for units operating out of compliance with applicable regulations. Maintenance and
compliance plans are required for all facilities. These programs would be used to document
efforts to maintain control equipment and replace parts prior to break-downs that could result
in excess emissions. The investigator should attempt to verify through evaluation of records
the adequacy of these programs.
CAA Regulatory Requirements
The following sections provide summaries of the principal regulations developed pursuant to
the CAA that may apply to the organic chemical industry. The section includes:
> 40CFRPart60
- Subparts Da, Db, Dc Standards of Performance for Steam Generating Units
- Subpart G Standards of Performance for Nitric Acid Plants
- Subpart H Standards of Performance for Sulfuric Acid Plants
- Subpart Kb Standards of Performance for VOC Storage Vessels
- Subpart GG Standards of Performance for Stationary Gas Turbines
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-1 ?
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- SubpartVV
- Subpart III
- Subpart NNN
- Subpart RRR
40CFRPart61
- Subpart F
- Subpart J
- Subpart M
- Subpart V
- Subpart Y
- Subpart BB
- Subpart FF
40CFRPart63
- Subpart F
- Subpart G
- Subpart G
- Subpart G
- Subpart G
- Subpart H
- Subpart I
- Subpart Q
Standards of Performance for Equipment Leaks of VOC from
SOCMI
Standards of Performance for VOC Emissions from SOCMI
Air Oxidation
Standards of Performance for VOC Emissions from Distillation
Unit Processes
Standards of Performance for VOC Emissions from SOCMI
Reactor Processes
National Emission Standards for Vinyl Chloride
National Emission Standards for Equipment Leaks (Benzene)
National Emission Standards for Asbestos
National Emission Standards for Equipment Leaks (Fugitive
Emission Sources)
National Emission Standards for Benzene Emissions from
Benzene Storage Vessels
National Emission Standards for from Benzene Transfer
Operations
National Emission Standards for Waste Operations
National Emission Standards for Organic Hazardous Air
Pollutants from SOCMI
National Emission Standards for Organic Hazardous Air
Pollutants from SOCMI for Process Vents
National Emission Standards for Organic Hazardous Air
Pollutants from SOCMI for Storage Vessels
National Emission Standards for Organic Hazardous Air
Pollutants from SOCMI for Transfer Operations
National Emission Standards for Organic Hazardous Air
Pollutants from SOCMI for Wastewater
National Emission Standards for Organic Hazardous Air
Pollutants from SOCMI for Equipment Leaks
National Emission Standards for Organic Hazardous Air
Pollutants for Certain Processes Subject to The Negotiated
Regulation for Equipment Leaks
National Emission Standards for Hazardous Air Pollutants for
Industrial Cooling Towers
40 CFR Part 68 Chemical Accident Prevention Provisions
40 CFR Part 82 Protection of Stratospheric Ozone
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Preceeding Page Blank
Applicability:
Electric utility steam
generating units capable of
combusting >73MW(250
million BTU/hr) heat input
alone, or in combination
with other fossil fuels.
Electric utility combined
cycle gas turbines capable
of combusting >73 MW
(250 million BTU/hr) heat
input of fossil fuel.
40 CFR Part 60 - Subpart Da
Standards of Performance for Electric Utility
Steam Generating Units for which
construction is commenced after September
18, 1978.
-Standards for:, particulate matter 60.42a, sulfur
dioxide 60.43a, nitrogen oxides 60.44a
-Test Methods 60.48a
-Monitoring 60.47a
-Reporting and record keeping 60.49a
Date of Applicability:
Sources constructed, reconstructed, or modified after September 18, 1978.
Affected Processes:
Emission standards for all affected facilities for:
Particulate Matter (PM) of 13 ng/J (0.03 Ib/mmBtu) heat input from the combustion of
solid, liquid or gaseous fuel; 1% of the potential combustion concentration (99%
reduction) when combusting solid fuel, 30% of the potential combustion concentration
(70% reduction) when combusting liquid fuel.
Opacity of 20%, averaged over 6 minutes, except for one 6 min. period per hour of
27% opacity.
SO2 when combusting solid or solid-derived fuels: 520 ng/J (1.20 Ib/mmBtu) heat input
and 90% reduction; or 70% reduction when emissions are < 260 ng/J (0.60 Ib/mmBtu
heat input).
SO2 when combusting liquid or gaseous fuels: 340 ng/J (0.80 Ib/mmBtu) heat input and
90% reduction; or 0% reduction when emissions are < 86 ng/J (0.20 Ib/mmBtu heat
input). All limits and percent reduction requirements are based on a 30-day rolling avg.
t;
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Alternative limits for SO2 apply if facility meets one of the following criteria
combusts solid solvent refined coal (SRC-I) (60.43a(c))
combusts 100% anthracite (60.43a(d)(l))
is classified as a resource recovery facility (60.43a(d)(2))
is located in a noncontinental area and combusts solid or solid-derived fuel
(60.43a(d)(3))
is located in a noncontinental area and combusts liquid or gaseous fuel
(60.43a(e))
combusts different fuels simultaneously (60.43a(h))
Nox (NO2) of various limits in ng/J (Ib/mmBtu) heat input depending on fuel type, based a
30-day rolling avg. If two or more fuels are combusted simultaneously, the formula in
60.44a(c) should be used.
Exemptions:
Subpart Da refers to emissions from fossil fuels only. Gas turbine emissions are subject to
Subpart GG.
Changes to existing fossil fuel-fired steam generating units to allow for the use of
combustible materials, other than fossil fuels.
Changes to existing fossil fuel-fired steam generating units from its original design of
gaseous or liquid fossil fuels to accommodate the use of any other fossil or nonfossil fuel.
Partial Exemptions:
Emissions reduction requirements for SO2 do not apply if facility is operated under an SO2
commercial demonstration permit issued by the Administrator under the provisions of
60.45a.
Emissions levels for NOX do not apply if unit is combusting coal-derived liquid fuel and is
operating under a commercial demonstration permit issued by the Administrator under the
provisions of 60.45a.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ i rj
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Monitoring Requirements:
1) Maintenance and operation of continuous emission monitoring system (CEMS), for
monitoring opacity according to 60.47a(a),(h) and (j) except where only gaseous fuel is
combusted.
2) Maintenance and operation of continuous emission monitoring system (CEMS), for
monitoring SO2 except where only natural gas is combusted. SO2 is to be monitored at
the sulphur dioxide control device inlet and outlet, unless subject to 68.47a(b)(2) or (3).
3) Maintenance and operation of continuous emission monitoring system (CEMS), for
monitoring NOX emissions according to 60.47a(c).
4) Maintenance and operation of continuous emission monitoring system (CEMS) for
monitoring O2 or CO2 content of flue gases at each location where SO2 or NOX is
monitored.
Reporting Requirements:
1) Initial performance test data and CEMS performance evaluation data for SO2, NOX and
PM.
2) Quarterly reports including:
- the information collected for 30 successive boiler operating days as specified in
60.49a(b) for sulfur dioxide and nitrogen oxides. If the minimum quantity of data is
outlined n 60.49a(c) and/or is information is not collected over 30 days or the data is
not available, then the information to be reported is outlined in 60.49a(c) and/or
60.49a(l)
- the information in 60.49a(d) if standards are exceeded during emergency conditions
because of control system malfunction
- the information in 60.49a(e) if SO2 fuel pretreatment is claimed
- signed statement in 60.49a(g)
- excess emission reports as under 60.7
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ i j
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ i o
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40 CFR Part 60 - Subpart Db
Standards of Performance for Industrial,
Commercial, Institutional Steam Generating
Units
-Standards for: sulfur dioxide 60.42b, particulate matter 60.43b,
nitrogen oxides 60.44b
-Test Methods 60.45b,60.46b
-Monitoring 60.47b, 60.48b
-Reporting and record keeping 60.49b
Applicability:
Steam generating units with a
heat input capacity from fuels
combusted in the steam
generating unit >29 MW (100
million BTU/hr).
Date of Applicability:
Sources constructed,
reconstructed, or modified
after June 19, 1984.
Sources meeting applicability and constructed after June 19, 1984 but before June 19,
1986 are subject to standards outlined in Subpart Db 60.40b(b)(l-4).
Affected Processes:
For all affected facilities which combust coal, oil, wood or municipal waste (alone, or in
combination with other fuels):
Emission standards for:
Particulate Matter (PM) of 22 ng/J (0.05 Ib/mmBtu) to 86 ng/J (0.20 Ib/mmBtu) depending
on fuel type and other factors, over 6 hr period
Opacity of 20%, averaged over 6 minutes, except for one 6 min. period per hour of
27% opacity
SO2 of various limits in ng/J (Ib/mmBtu) heat input depending on fuel type and other
factors, based on a 30-day rolling average unless unit has Federally enforceable low
capacity factor for oil (10% or less), combusts only very low sulphur oil, and does not
combust other fuels.
Nox (NO2) of various limits in ng/J (Ib/mmBtu) heat input depending on fuel type based a
30-day rolling avg., unless unit has a Federally enforceable low capacity factor, or low
nitrogen fuels. In this case, compliance determined based on performance tests
(specified in 60.44b(j)(l)-(3)).
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-19
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Exemptions:
Steam generating units meeting Subpart DC applicability (i.e. having maximum design heat
input capacity >2.9 MW but <29 MW) or Subpart Da (electric utility steam generating
units) are not subject to Subpart Db.
Existing steam generating units modified for the sole purpose of combusting gases
containing TRS as defined under 60.28.
Partial Exemptions:
Steam generating units at petroleum refineries subject to 40 CFR Part 60, Subpart J or
incinerators subject to 40 CFR Part 60, Subpart E are subject to Subpart Db only for PM and
NOx.
Steam generators subject to Subpart J who have a heat input capacity of <73 MW (260
mmBtu/hr) are not subject to NOX emissions standards.
Percent reduction requirements not applicable to affected facilities
for SO2 if one of the following criteria apply:
annual capacity for coal and oil < 30% (subject to Federal enforceable permit
limiting operation to annual capacity factor < 30%)
located in noncontinental areas
facility is combusting coal or oil in a duct burner and> 70% of the heat input is
from exhaust gases entering the duct burner.
burning very low sulfur oil.
Monitoring Requirements:
1) If subject to SO2 standard in 60.42(b), maintenance and operation of inlet/outlet
continuous emission monitoring system (CEMS), for monitoring SO2 concentrations and
either O2 or CO2. Or, measurement of SO2 emissions according to 60.47b(l)-(4). If
burning low sulfur oil, may use fuel supplier certification.
2) If subject to opacity standard under 60.43(b) maintenance and operation of continuous
monitoring system (COMS) to measure opacity of emissions.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ on
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3) If subject to the nitrous oxides standards of 60.44b, maintenance and operation of COMS
to measure NOX emissions not required for duct burners used in combined cycle system
or low capacity nitrogen fuel facilities that are subject to the performance test emission
standards.
Record keeping Requirements (2 years):
1) All opacity data
2) Amount of each fuel combusted daily with recorded calculation of annual capacity factors,
maintained on a quarterly basis
3) Performance test data and initial performance test data
4) Nitrogen content of residual oil combusted in affected facility.
5) For facility subject to nitrous oxide standards: daily records of steam generating unit
operations (60.49b(g)(l)-(10))
Reporting Requirements:
1) Excess emission reports (EER) quarterly for each applicable pollutant (PM, NOX and SO2)
; semi-annually if no exceedances.
2) Quarterly report of information specified in 60.49b(g) for nitrous oxide if subject to
COMs requirement under 60.48b(b).
3) Plan for NOX monitoring operating conditions, if applicable.
4) Quarterly report for sulfur dioxide as described in 60.49b(j)-(m).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ o<
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A
-------
Applicability:
Steam generating unit with
maximum design heat input
capacity of < 29 MW (100
mmBtu/hr) but > 2.9 MW (10
mmBtu/hr).
Date of Applicability:
Sources constructed,
reconstructed, or modified
after June 19, 1989.
Sources meeting applicability and constructed after June 19, 1984 but before June 19,
1986 are subject to standards outlined in Subpart Db 60.40(b)(l)-(4).
Affected Processes:
40 CFR Part 60 - Subpart Dc
Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating
Units
-Standards for: sulfur dioxide 60.42c and particulate matter
60.43c
-Test Methods 60.44c,60.45c
-Monitoring 60.46c, 60.47c
-Reporting and Record keeping 60.48c
Emission standards for:
SO2 of various levels of ng/J (Ib/mmBtu), depending on fuel type and other factors.
Based on a 30-day rolling average unless facility listed in 60.43c(h)(l), (2), or (3); then
compliance with emission limits or fuel oil sulphur limits may be determined based on
certification from fuel supplier as in 60.48c(f)(l), (2), or (3).
Particulate Matter (PM) of 22 ng/J (0.05 Ib/mmBtu) to 130 ng/J (0.30 Ib/mmBtu)
depending on fuel type and other factors
Opacity of 20% for facilities with heat input capacity > 8.7 MW and combusting coal,
wood, or oil, averaged over 6 minutes, except for on 6 minute period per hour of 27%
opacity.
Exemptions:
Percent reduction for SO2 not applicable to facilities that combust coal (alone or in
combination with other fuels) that meet the following criteria:
- heat input capacity<22MW
- annual capacity factor for coal<55% or Federally enforceable low capacity factor
located in noncontinental areas
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
\ oo
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- facility is combusting coal or oil in a duct burner and > 70% of the heat input is from
exhaust gases entering the duct burner.
Percent reduction for SO2 not applicable to facilities that combust oil as in 60.42c(d).
Monitoring Requirements:
If subject to SO2 standard, maintenance and operation of outlet continuous emission
monitoring system (CEMS) for monitoring SO2 and either O2 or CO2. Inlet CEMs for
SO2 and either O2 or CO2 if % reduction requirements apply. Or, measurement of SO2
emissions according to 60.46c(d)(l)-(3).
Facilities with heat input capacity> 8.7 MW may also obtain fuel supplier certifications.
Facilities subject to 60.42c(h)(l), (2), or (3) that demonstrate compliance with SO2
standards based on fuel supplier certification.
For PM: Maintenance of continuous monitoring system (COMS) for opacity if combust
coal, wood or residual oil (alone or in combination with other fuels).
Record keeping Requirements (2 years):
1) All SO2 monitor data as described in 60.46c(f)
2) Fuel supplier certification records (specified 60.48c(f)(l)-(3)).
3) Amounts of each fuel combusted during each day
4) If subject to a Federally enforceable low-capacity factor, calculation of annual capacity
factor for each fuel combusted.
Reporting Requirements:
1) Notification of date of construction, reconstruction, anticipated and actual startup as in
60.48c(a)(l-4).
2) Initial and subsequent performance tests
3) Excess emission reports (EER) quarterly for opacity; semi-annually if no exceedances.
4) Quarterly report for SO2 emissions/monitoring data (specified in 60.48c(e)(l)-(l 1)).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ y.
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Applicability:
40 CFR Part 60 - Subpart G
Nitric acid production c* j j m r t M-* A A
, . v Standards ol Performance tor Nitric Acid
plants
F Plants
The discharge of gases is
prohibited which:
- Monitoring 60.73
- Test methods 60.74
- Contain NO2 in excess of 1.5 kg per metric ton acid produced
- Exhibit 10% opacity or greater
Date of Applicability:
Sources constructed or modified after August 17, 1971
Exemptions:
None
Monitoring/ Record Keeping Requirements:
1) Continuous monitoring of nitrogen oxides
2) Conversions of monitoring data to units of applicable standard
3) Record daily production rate and hours of operation
4) Monitor flares as required in 60.18
Reporting Requirements:
1) Semiannual report of excess emissions and monitoring system performance
I
This manual is intended solely for guidance. No statutory or regulatory >P
requirements are in any way altered by any statements) contained herein. \ or
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ oc
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Applicability:
40 CFR Part 60 - Subpart H
Sulfuric acid production cvjj mr r o ir A -j
, . * Standards ol Perlormance lor Sullunc Acid
plants
F Plants
The discharge of gases is
prohibited which:
- Monitoring 60.84
- Test methods 60.85
- Contain sulfur dioxide in
excess of 2 kg per metric ton of acid produced
- Contain H2SO4 in excess of 0.075 kg per metric ton of acid produced
- Exhibit 10% opacity or greater
Date of Applicability:
Sources constructed or modified after August 17, 1971
Exemptions:
None
Monitoring/ Record Keeping Requirements:
1) Continuous monitoring of sulfur dioxide or applicable alternative
2) Conversion of monitoring data into units of applicable standard
3) Record all conversion factors and computed values
Reporting Requirements:
1) Semiannual report of excess emissions and monitoring system performance
I
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A ?7
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ oo
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Applicability:
Storage vessels with design
capacity > 151m3,
containing a VOL with TVP
> 5.2 kPa but less than
76.6 kPa
40 CFR Part 60 - Subpart
Standards of Performance for VOC Storage
Vessels
- Monitoring 60.116b
- Record keeping and Reporting 60.115b
-Testmethods 60.113b
Storage vessels with design
capacity > 75m3, but < 151m3, containing VOL with TVP > 27.6 kPa but less than 76.6
kPa
Storage vessels with design capacity > 75m3 and TVP > 76.6 kPa
40 CFR PART 60 - SUBPART KR
AFFECTED PROCESSES
REGULATORY THRESHOLD
Storage vessel must be equipped with either:
Fixed roof with internal floating roof meeting the
specifications in 60.112b(a)(l)
External floating roof meeting the specifications in
60.112b(a)(2)
Closed vent system and control device meeting the
specifications in 60.112b(a)(3)
If detectible emissions > 500 ppm
above background:
Reduce VOC emissions by 95%
or greater or
Flares must meet requirements of
60.18
Vessels with design capacity > 75m3 and TVP > 76.6kPa
must be equipped with a closed vent system and control
device, or equivalen system
Date of Applicability:
Sources constructed, reconstructed or modified after July 23, 1984.
Exemptions:
Coke oven by-product plants
Pressure vessels designed to operate in excess of 204.9 kPa
Vessels permanently attached to mobile vehicle
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-29
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Vessels with design capacity < 1,589.874 m3 used for petroleum or condensate stored,
processed, or treated prior to transfer
Vessels at bulk gasoline plants
Storage vessels at gasoline service stations
Vessels to storage beverage alcohol
Monitoring Requirements:
1) Visual inspections of vessels and fixed roof and internal floating roof as described in
60.113b(a) and of vessels with external floating roofs as described in 60.113b(a) and of
vessels with external floating roofs as described in 60.113b(b)(6)
2) Determine gap areas and maximum gap widths of vessels with external floating roofs as
described in 60.113b(b).
3) Monitor parameters of closed vent system and control device in accordance to operating
plan
4) Monitor flares as required in 60.18
Record Keeping Requirements (at least 2 years):
1) Visual inspection data
2) Storage vessel dimensions and capacity
3) VOL storage information as applicable under 60.116b(c)
4) Gap measurements if floating roof
5) Storage vessels with design capacity > 40m3, must keep records of vessel dimension and
capacity
Reporting Requirements:
1) Notification to the Administrator 30 days prior to filling storage vessel required to be
inspected under 60.113b(a)(l), 60.113b(a)(4), or 60.113b(b)(6) or required to
determine gap measurements required under 60.113b(b)(l)
2) Operating plan for closed vent system and control device as in 60.113b(c) (1)
3) Initial report describing control equipment and certification, and required measurements
4) Report any defects within 30 days
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \
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Applicability:
Stationary gas turbines with heat
input at peak load>l0.7
gigajoules/ hour, based on
lower heating value of the fuel
firecj -Test Methods 60.335
-Reporting and record keeping 60.334
Date of Applicability:
40 CFR Part 60 - Subpart GG
Standards of Performance for Stationary Gas
Turbines
-Standards for: nitrogen oxides 60.332, sulfur dioxide 60.333
-Monitoring 60.334
Sources constructed, reconstructed, or modified after October 3, 1977, except as provided
in 60. 332 (e) and (j).
Affected Processes:
Emission standards for:
NOX according to the standard (STD) equation outlined in 60.332(a)(l) or (2), as
directed in 60.332(b),(c), and (d)
Gases with SO2 in excess of < 0.01 5% by volume at 1 5% O2 on a dry basis. In addition,
no fuel shall be burned which contains sulfur in excess of 0.8% by weight.
Exemptions:
Standards for NOX are not applicable for gas turbines outlined in 60. 332 (e) - (I).
Monitoring Requirements:
For units using water injection to control NOX, continuous monitoring system to monitor rK
and record the fuel consumption and ratio of water to fuel being fired in the turbine,
within 5% accuracy
Monitoring of fuel sulfur and nitrogen content as specified in 60.334(b)(l)-(2).
Reporting Requirements:
Quarterly reports as required under 60.7, including reports of excess emissions data. The
periods of excess emissions to be reported are outlined in 60.334 (c)(l)-(4). The calculation
of emissions rates are outlined in 60.335.
s
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ o i
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A
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Applicability:
Design Capacity of Facility to
produce as a final product or
intermediate 1,000 Mg/Year or
more of any of the chemicals
identified
40 CFR Part 60 - Subpart V V
Standards of Performance for Equipment
Leaks of VOC from SOCMI
- Monitoring 60.485
- Record keeping 60.486
- Reporting 60.486
-Standards 60.482, 60.483
40 CFR PART 60 - SUBPART V V
AFFECTED PROCESSES
REGULATORY THRESHOLD
Pumps in light liquid service
Compressors
Pressure relief devices in gas/vapor service
Sampling connection systems
Open-ended valves or lines
Valves in gas/vapor service in light liquid service
Pumps and valves in heavy liquid service
Pressure relief devices in light or heave liquid
service
Flanges and other connectors
Closed vent systems and control devices
If measured leak > 10,000 ppm, or detection
of leak
If detectable emissions > 500 ppm above
background
If detectable emissions > 500 ppm above
background
Zero emissions except when an in-situ sampling
systems are used
Zero emissions except when a double block-
and-bleed valve is used
If measured leak > 10,000 ppm, or detection
of leak
If measured leak > 10,000 ppm, or detection
of leak
If measured leak > 10,000 ppm, or detection
of leak
If measured leak > 10,000 ppm, or detection
of leak
If detectable emissions > 500 ppm above
background, or detection of leak
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-33
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Date of Applicability:
Sources constructed or modified after January 5, 1981
Exemptions:
Beverage alcohol
Facilities with no equipment in VOC service
Monitoring Requirements:
1) Inspections
2) Monitoring specified for each process as per 60.482
3) Utilization of Method 21 to determine the presence of leaking sources and background
levels
Record Keeping Requirements:
1) Tagging leaking equipment with ID# until repaired as ID# on valves may be removed
after two successive months with no detected leaks
2) Log for each detected leak (retained for 2 years) including information required under
60.486(c)(l-9)
3) Maintenance of control equipment design information
4) Maintenance of monitoring data
5) Maintenance of operating data
6) Maintenance of equipment data
Reporting Requirements:
1) Submittal of semiannual reports beginning 6-months after the start-up date containing the
information outlined in 60.487(b) and (c)
2) Notification of the Administrator of the alternative standard selected 90 days before
implementing one of the three alternative standards for valves
3) Reporting of the performance test results to the Administrator
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ ^,
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Applicability:
Each affected facility that
produces any of the chemicals
listed in 60.617 as a product,
co-product, by-product, or
intermediate
40 CFR Part 60 - Subpart III
Standards of Performance for VOC Emissions
from SOCMI Air Oxidation Unit Processes
- Monitoring 60.613
-Testmethods 60.614
- Reporting and Record keeping 60.615
Affected Processes:
Each vent stream from any affected facility shall comply with one of the following:
40 CFR 60.612(a): Reduce emissions of TOC (less methane and ethane) by 98
weight percent or to a TOC (less methane and ethane) 20 ppmv on a dry basis
corrected to 3 percent oxygen whichever is less stringent; or
40 CFR 60.612(b): Combustion emissions in a flare that meets the requirements of
§60.18; or
40 CFR 60.612(c): Maintain a TRE index value greater than 1.0 without use of VOC
emissions control device
Note: Any vent stream subject to the requirements of this subpart shall be in
compliance on or after the date on which the initial performance test as required
under §§60.8, 60.18, and 60.614 is completed, but not later than 60 days after
maximum production rate or 180 days after initial startup, which ever date comes
first.
Date of Applicability:
Sources constructed, reconstructed or modified after October 21, 1983
Exemptions:
Affected facility with TRE index value greater than 4.0 are only required to follow the
requirements specified in §§60.612, 60.614(0, 60.615(h), and 60.615(1).
Monitoring Requirements:
1) Incinerators
F^
Firebox temperature/temperature upstream and downstream of bed (for catalytic p^n
incinerators) ^O
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A o r
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Vent stream flow to the incinerator
2) Boilers or process heaters
Firebox temperature (if design heat input < 44 MW)
Periods of operation (if design heat input > 44 MW)
Vent stream flow to the boiler/process heater
3) Flares
Continuous presence of pilot flame (thermocouple or other similar device)
Vent stream flow to the flare
4) Demonstrate compliance with TRE index value using a recovery device of recovery
system
Absorber
Scrubbing liquid temperature
Specific gravity
Concentration of organic compounds exiting recovery device
Condenser
Concentration of organic compounds exiting recovery device
Exit temperature (product site)
Carbon adsorber
Steam flow
Carbon bed temperature
Concentration of organic compounds exiting recovery device
5) Alternative control devices or recovery device
As specified in §60.613(e)
Record Keeping Requirements: (Applicable to all affected facilities)
1) Performance test data as specified in 60.615(b) for each control device, flare or recovery
device.
2) Continuous records specified for each control device, flare, or recovery device 60.615(c)
- (h) including:
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \
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Equipment operating parameters specified to be monitored; and
Periods of operation in which parameter boundaries are exceeded [as defined in
60.615(c)];and
Flow indication; and
Periods when vent stream is diverted from control device or has no flow rate
Reporting Requirements: (Applicable to all affected facilities)
1) Notification to the Administrator of the specific provision (control device, flare, TRE)
selected to comply.
2) Notification to the Administrator 90 days before implementation of a change to use an
alternative provision.
3) Initial performance test report as per §60.8 and 60.615.
4) Semiannual reports containing the information outlined in 60.615(j)
Testing Requirements:
All performance tests to be conducted in conformance with §60.8. 60.18 (flares), and
60.614.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ oo
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Applicability:
Each affected facility that
produces any of the chemicals
listed in 60.667 as a product,
co-product, by-product, or
intermediate - Test methods 60.664
- Reporting and Record keeping 60.665
Affected Processes:
40 CFR Part 60 - Subpart NNN
Standards of Performance for VOC Emissions
from SOCMI Distillation Operations
- Monitoring 60.663
Each vent stream from any affected facility shall comply with one of the following:
40 CFR 60.662(a): Reduce emissions of TOC (less methane and ethane) by 98 weight
percent or to a TOC concentration; of 20 ppmv on a dry basis corrected to 3 percent
oxygen, whichever is less stringent, or
40 CFR 60.662 (b): Combust emissions in a flare that meets the requirements of
60.18; or
40 CFR 60.662(c): Maintain a TRE index value greater than 1.0 without use of VOC
emissions control device
Note: Any vent stream subject to the requirements of this subpart shall be in
compliance on or after the date on which the initial performance test as required
under §§60.8, 60.18 and 60.664 is completed, but not later than 60 days after
maximum production rate or 180 days after initial startup, which date comes first.
Date of Applicability: g
Sources constructed, reconstructed or modified after December 30, 1983. ^
Exemptions:
Coal tar or beverage alcohol producing processes or affected facilities that use, contain or
produce no VOC
Polymer manufacturers (subject to Subpart ODD)
Distillation units operated as a batch processes
Partial Exemptions:
F^
Affected facility with TRE index value greater than 8.0 are only required to follow the p^n
requirements specified in §§60.662, 60.664(d), (e), and (f); and 60.665(h) and (1). O
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A QQ
/\~OJ
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Affected facility with a total design capacity for all chemicals produced is less than 1
Gg/year are only required to follow the record keeping and reporting requirements in
§60.665(j), 0(6).
Affected facility operated with a vent stream flow rate less than 0.008 scm/minute are
only required to follow the test method and procedure and the record keeping and
reporting requirements in §60.664(g) and §60.665(!),(!)(5) and (o).
Monitoring Requirements:
1) Incinerators
Firebox temperature/temperature upstream and downstream of bed (for catalytic
incinerators)
Vent stream flow to the incinerator
2) Boilers or process heaters
Firebox temperature (if design heat input < 4 MW)
Periods of operation (if design heat input > 44 MW)
Vent stream flow to the boiler/process heater
3) Flares
Continuous presence of pilot flame (thermocouple or other similar device)
Vent stream flow to the flare
4) Demonstrate Compliance with TRE index value using a recovery device or recovery
systems
Absorber
Scrubbing liquid temperature
Specific gravity
Concentration of organic compounds exiting recovery device
Condenser
Exit temperature
Concentration of organic compounds exiting recovery device
Carbon adsorber
Steam flow
Carbon bed temperature
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /, > n
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Concentration of organic compounds exiting recovery device
5) Alternate control devices or recovery device
As specified in §60.663(e)
Record Keeping Requirements (Applicable to all affected facilities)
1) Performance test data as specified in §60.665(b) for each control device, flare, or
recovery device
2) Continuous records specified for each control device, flare, or recovery device as per
60.665(c) - (j) including:
Equipment operating parameters specified to be monitored; and
Periods of operation in which parameter boundaries are exceeded [as defined in
60.665(c)];and
Flow indication; and
Periods when vent stream is diverted from control device or has no flow rate.
Reporting Requirements (applicable to all affected facilities):
1) Notification to the Administrator of the specific provisions (control device, flare, or TRE)
selected to comply.
2) Notification to the Administrator 90 days before implementation of a change to use an
alternative provision.
3) Initial performance test report as per §§60.8 and 60.665.
4) Initial and semiannual reports containing the information in 60.665(1), (n), and (o).
Testing Requirements
All performance tests to be conducted in conformance with §§60.8, 60.18 (flares), and
60.664.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ , i
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A 4?
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Applicability:
Each affected facility that
produces any of the chemicals
listed in 60.707 as a product,
co-product, by-product, or
intermediate. - Test methods 60.704
- Reporting and Record keeping 60.705
Affected Processes:
40 CFR Part 60 - Subpart RRR
Standards of Performance for VOC Emissions
from SOCMI Reactor Processes
- Monitoring 60.703
Each vent stream from any affected facility shall comply with one of the following:
40 CFR 60.702(a): Reduce emissions of TOC (less methane and ethane) by 98 weight
percent or to a TOC concentration; of 20 ppmv on a dry basis corrected to 3 percent
oxygen, whichever is less stringent; or
40 CFR 60.702 (b): Combust the emissions in a flare that meets the requirements of
60.18; or
40 CFR 60.702(c): Maintain a TRE index value greater than 1.0 without use of VOC
emissions control device
Note: Any vent stream subject to the requirements of this subpart shall be in
compliance on or after the date on which the initial performance test as required
under §§60.8, 60.18 and 60.704 is completed, but not later than 60 days after
maximum production rate or 180 days after initial startup, whichever date comes
first.
Date of Applicability:
Sources constructed, reconstructed or modified after June 29, 1990.
Exemptions:
Reactor process designed and operated as a batch operation
Process unit produces beverage alcohols or which uses, contains, and produces no VOC
Reactor process subject to subpart ODD
Partial Exemptions:
Affected facility with TRE index value greater than 8.0 only required to follow the
requirements specified in §§60.702(c); 60.704(d), (e), and (f); 60.705(g), (1), and (t). CŁJ
&
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A /I Q
/\~T:O
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Affected facility with a total design capacity for all chemicals produced is less than 1
Gg/year are only required to follow the record keeping and reporting requirements
under §60.705(1), (1)(6) and (n).
Affected facility operated with a vent stream flow rate less than 0.011 scm/min are only
required to follow the test method and procedure and the record keeping and reporting
under §60.704(g) and 60.705(h), (1)(5), and (o).
Vent stream is routed to a distillation unit subject to Subpart NNN is only required to
follow §60.705.
Affected facility operated with TOC concentration (less methane and ethane) in the vent
stream less than 300 ppmv (Method 18) or 150 ppmv (Method 2 5A) is only required to
follow the test method and procedure and the reporting and record Keeping
Requirements in §§60.704(h) and 60.705(j), (1)(8) and (p).
Monitoring Requirements:
1) Incinerators
Firebox (or immediately downstream of the firebox) temperature or temperature
upstream and downstream of bed (for catalytic incinerators);
Vent stream flow diverted from being routed to the incinerator;
Install monitor of the entrance to any by-pass line; or
Car-seal/lock-and-key type configuration with month visual check.
2) Boilers or process heaters
Firebox temperature (if design heat input < 44 MW);
Periods of operation (if design heat input > 44 MW);
Vent stream flow diverted from being routed to the boiler/process heater;
Install monitor of the entrance to any by-pass line; or
Car-seal/lock-and-key type configuration with month visual check.
3) Flares
Continuous presence of pilot flame (thermocouple or other similar device);
Vent stream flow diverted from being routed to the flare;
Install monitor of the entrance to any by-pass line; or
Car-seal/lock-and-key type configuration with month visual check.
4) Demonstrate compliance with TRE index value using a recovery device or recovery
system
Absorber
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ ,,
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Scrubbing liquid temperature
Specific gravity
Concentration of organic compounds exiting recovery device
Condenser
Exit temperature
Concentration of organic compounds exiting recovery device
Carbon adsorber
Steam flow
Carbon bed temperature
Concentration of organic compounds exiting recovery device
5) Alternative control devices or recovery devices
As specified in §60.703(e) by the Administrator
Record Keeping Requirements (Applicable to all affected facilities)
1) Performance test data as specified in §60.705(b) for each control device, flare, or
recovery device
2) Continuous records specified for each control device, flare, or recovery device as per
60.705(c) - (j) including:
Equipment operating parameters specified to be monitored; and
Periods of operation in which parameter boundaries are exceeded [as defined in
60.705(c)];and
Flow indication; and
Periods when vent stream is diverted from control device or has no flow rate.
Reporting Requirements (Applicable to all affected facilities)
1) Notification to the Administrator of the specific provisions (control device, flare, or TRE)
selected to comply.
2) Notification to the Administrator 90 days before implementation of a change to use on
alternative provision.
3) Initial performance test report as per §§60.8 and 60.705
4) Initial and semiannual reports containing the information in 60.705(1), (n)-(p), and (r)-(t).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ ,r
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Testing Requirements
All performance tests to be completed in conformance with §§60.8, 60.18 (flares), and
60.704.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ ,r.
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Applicability:
40 CFR Part 61 - Subpart F
Plants producing: AT ,. , ^ . . c. , , , w. ,
* b National Emissions Standards lor Vinyl
1) Ethylene dichloride by Chloride
- Monitoring 61.67, 61.68
- Record keeping 61.71
- Reporting 61.69, 61.70Standards of Performance for VOC
Storage Vessels
reaction of oxygen and
hydrogen chloride with
ethylene.
2) Vinyl chloride by any
process, and/or
3) One or more polymers containing any fraction of polymerized vinyl chloride.
Affected Processes:
Emission standards for:
Ethylene dichloride plants
- ethylene dichloride purification [61.62 (a)]
- oxychlorination reactor [61.62(b)]
Vinyl chloride plants
- vinyl chloride formation and purification [61.63(a)]
Polyvinyl chloride plants
- reactor [61.64(a)]
- stripper [61.64(b)]
- mixing, weighing, and holding containers [61.64(c)]
- monomer recovery system [61.64(d)]
- sources following stripper [61.64(e)]
- reactor used as stripper [61.64(1)]
All ethylene dichloride, vinyl chloride, and polyvinyl chloride plants
- relief valve discharge [61.6 5 (a) ] (^
- fugitive emissions [61.6 5 (b) ] tin
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-47
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Date of Applicability:
All existing sources.
Exemptions:
Equipment used in research and development if reactor used to polymerize the vinyl
chloride has a capacity of less than 0.19 m3 (50 gal)
Equipment used in research and development with reactor (used to polymerize the vinyl
chloride) > 0.19 m3 and < 4.17 m3 (1,100 gal) are subject to 61.64(a)(l), (b), (c), and
(d); 61.67; 61.68; 61.69; 61.70; and 61.71
Monitoring Requirements:
1) Monitoring program to detect and identify major leaks [61.65 (b) (8)]
2) Monitoring of flares in accordance with 60.18(d) and 60.18(1) (2)
3) Emission tests (with prior notification to the Administrator) as required under 61.67.
4) Continuous monitoring system for vinyl chloride as described under 61.68.
Reporting Requirements:
1) Reports to the Administrator from polyvinyl chloride plants on any discharge from manual vent
valves [61.64(a)(3)], from all affected facilities on any relief valve discharges [61.65(a)].
2) Submission of monitoring program to detect, identify, and repair major leaks [61.65(b) (8)].
3) Reports concerning flare design and operation as required under 61.65(d) (2).
4) Notification to the Administrator 30 days prior to performing emission test.
5) Initial report as described in 61.69.
6) Quarterly reports containing the information described in 61.70 (c).
Record Keeping Requirements (at least 2 years):
1) Visual inspection data
2) Storage vessel dimensions and capacity
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-
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3) VOL storage information as applicable under 60.116b(c)
4) Gap measurements if floating roof
5) Storage vessels with design capacity > 40 ni must keep records of vessel dimension and
capacity.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-4Q
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Applicability: i. !
40CFRPart61 - Subpart J
Sources intended to ^ .. , ^ . . c. , , , ^ . .
. . , . National Emission Standard lor Equipment
operate in benzene service ^ r
including pumps Leaks (Fugitive Emission Sources ol Benzene)
compressors, pressure ^^^^^^^^^^^^^^"^^^^^^^^^^^^^~
relief devices, sampling
connections, systems, open-ended valves or lines, valve flanges and other connectors,
product accumulator vessels, and control devices.
Required to comply with Part 61, Subpart V
Date of Applicability:
All existing sources.
Exemptions:
Sources located in coke by-product plants
Plant sites designed to produce or use less than 1,000 mg/year
Any process unit that has no equipment in benzene service
Monitoring Requirements:
Requirements in Part 61, Subpart V
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A _ c i
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Applicability:
"40CFRPart61 -SubpartM
National Emission Standard for Asbestos
- Standard for Demolition and Renovation 61.145
- Standard for Spraying 61.146
- Standard for Insulating Materials 61.148
- Standard for Waste Disposal for Manufacturing,
Fabricating, Demolition, Renovation, and Spraying
Operations
61.145 is applicable to
owners or operators of a
demolition or renovation
activity
61.146 is applicable to
owners or operators of an
operation in which
asbestos-containing materials are spray applied.
Affected Processes:
For demolition, requirements in 61.145(b) and (c) apply if the combined amount of
Regulated Asbestos-Containing Material (RACM) meets criteria listed in 61.145(a)(1)(I) or
00
For renovation, requirements in 61.145(b) (and (c) apply if the combined amount of
RACM to be stripped, removed, dislodged, cut, drilled, or disturbed meets the criteria in
61.145(4)0) or (ii)
All RACM must be removed from a facility being demolished or renovated before any
activity begins that would break up, dislodge, or disturb the material or preclude access to
the material for removal
When a facility component that contains, is covered with, or is coated with RACM is
being taken out of the facility as a unit or in sections, the procedures in 61.145(c) (2) must
be followed; and when RACM is stripped from a facility component while it remains in
place at the facility, procedures in 61.145(c)(3) must be met
After a facility component covered with, coated, with, or containing RACM is taken out of
the facility, it must be handled according to the procedures in 61.145(c)(4). Large '
components such as reactor vessels, large tanks, and steam generators must be handled
according to procedures in 61.145(c)(5)
All RACM must be handled according to procedures in 61.145(c)(6)
No RACM can be stripped, removed, or otherwise handled or disturbed at a facility
unless at least one onsite representative is trained in compliance with the regulations
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. \ j.
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Under 61. 146, material that contains more than 1% asbestos cannot be used for spray
application on buildings, structures, pipes, and conduits
Under 61. 148, no owner or operator may install or reinstall on a facility component any
insulating materials that contain commercial asbestos if the materials are either molded
and friable or wet-applied and friable after drying; and this does not apply to spray-
applied insulating materials regulated under 61.146
Under 61.150, each owner or operator of any source covered under 61. 145 or 61. 146
must:
- Discharge no visible emissions to the outside air during the collection, processing,
packaging, or transporting any asbestos-containing waste material generated by the
source, or use one of the emission control and waste treatment methods specified in
6 1.1 50 (a) ((1) through (4)
- Dispose of all asbestos-containing waste material as soon as practical at sites as listed in
61.150(b)
- Mark vehicles used to transport asbestos-containing waste material as in 6 1 . 1 50 (c)
Exemptions:
If the facility is being demolished under State or local government order because the
facility is structurally unsound or in danger of imminent collapse, only 61.145(b)(l), (b)(2),
b(3)(iii), (b)(4) (except (b) (4) (VIII)) , (b)(5), and (c)(4) through (c)(9)
RACM does not need to be removed before demolition if it meets the criteria in
Spray-on application of materials is not subject to 6 1 . 1 46 when the asbestos fibers in the
materials are encapsulated with a bituminous or resinous binder during spraying and the
materials are not friable after drying
Owners and operators of sources subject to 6 1 . 1 46 are exempt from the requirements
of 61.05(a), 61.07, and 61.09.
Requirements in 6 1 . 1 50 (a) do not apply to demolition and renovation for Category I
nonfriable ACM waste and Category II nonfriable ACM waste that did not become
crumbled, pulverized, or reduced to powder
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-
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Reporting and Record Keeping Requirements
Owner or operator of demolition or renovation activity must submit and update written
notice containing the information in 61.145(b)(4)(I) through (xvii)
Spray-on application of materials that contain more than 1% asbestos on equipment and
machinery are subject to the notification and procedural requirements in 61.146(b)(l)
and (2)
Waste shipment records must be maintained for all asbestos-containing waste as
described in 61.150(d)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A _ c c
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-'ifi
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Applicability:
Sources intended to operate in
VHAP service including pumps,
compressors, pressure relief
devices, sampling connection
systems, open-ended valves or
lines, valves, flanges and other
connectors, product
accumulator vessels, and control devices.
40 CFR Part 61 - Subpart V
National Emission Standard for Equipment
Leaks (Fugitive Emission Sources)
-Monitoring 61.242, 61.245
-Reporting 61.247
- Recordkeeping 61.246
40 CFR PART 61 - SUBPART V
AFFECTED PROCESSES
REGULATORY THRESHOLD
Pumps
Compressors
Valves
Pressure relief devices in gas/vapor service
Presssure relief devices in liquid service and flanges and other
connectors
Closed-Vent Systems
Control devices
If measured leak 10,000 ppm or
more, or if indication of liquids
dripping from pump seal.
Facility required to determine a
criterion that indicates failure of the
seal system and/or barrier fluid
system.
If measured leak 10,000 ppm or
more. Alternative standards 1 and
2, leak is detected if more than 2%
of valves emitting 10,000 ppm or
more.
If detectable emissions greater than
500 ppm above background.
If measured leak 10,000 ppm or
more.
Leak is detected if detectable
emissions greater than 500 ppm.
Vapor recovery systems must
recover vapors with 95% efficiency
or greater. Combustion devices
must recover vapors with 95%
efficiency or greater and must
provide a minimum residence time
of 0.5 seconds at minimum
temperature of 760°C.
^h
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-57
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Date of Applicability:
After date of promulgation of specific Subpart in Part 61.
Exemptions:
None
Monitoring Requirements:
1) PumpsWeekly visual inspection (not required if pump within boundary of unmanned
plant site) and monthly instrumental monitoring using RM 21. Instrumental monitoring of
pumps equipped with a dual mechanical seal system is required only if indication of liquid
drippings from pump seal. Instrumental monitoring of pumps designated for no
detectable emission is required annually.
2) CompressorsDaily check of sensor or equip sensor with audible alarm. If compressor
is equipped with closed vent system capable of capturing and transporting leak to control
device, annual monitoring using RM 21.
3) ValvesMonthly instrumental monitoring using RM 21 (unless leak not detected for 2
successive months, then quarterly monitoring) or implementation of Alternative 1 or 2.
4) Pressure relief devices in gas/vapor serviceMonitoring using RM 21 within 5 days of
pressure release.
5) Pressure relief devices in liquid service and flanges and other connectorsMonitoring
using RM 21 within 5 days of detecting potential leak.
6) Closed vent systemsInitial and annual monitoring.
Reporting Requirements:
1) Initial notification that requirement is being implemented as required under 61.247(a).
2) Semiannual report (including information on leaks and repairs) as required under
61.247(b).
Record Keeping Requirements:
1) Tagging leaking equipment with ID# until after 2 successive months with no detected
leaks.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-W
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2) Information on leaking equipment and repairs as required under 61.246(c), kept for 2
years.
3) Equipment design information for closed-vent systems and control devices as described
in61.246(d).
4) Information on equipment to which a standard applies as described in 61.246(e).
5) Information on valves as required under 61.246(1) and (g).
6) Design criterion as described in 61.246(h).
7) Information related to exemptions as described in 61.246(i) and (j).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-'SQ
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-fifl
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Applicability:
" 40 CFR Part 61 - Subpart Y
All benzene storage vessels
with a design capacity >38 ni
(10,000 gal)
Affected Processes:
National Emission Standard for Benzene
Emissions from Benzene Storage Vessels
- Monitoring 61.272
- Record keeping 61.276
- Reporting 61.274 & 61.275
Storage vessels storing benzene
having specific gravities as indicated in 61.270(a)
Storage vessel must be equipped with either:
1) Fixed roof and internal floating roof, meeting the specifications in 61.271 (a), or
2) External floating roof meeting the specifications in 61.271 (b), or
3) Closed vent system and control device meeting the specifications in 61.271 (c). Operated
with emissions < 500 ppm above background and a control device to reduce benzene
emissions by 95% or greater
Date of Applicability:
All existing sources.
Exemptions:
Vessels at coke-byproduct facilities ^
Vessels permanently attached to trucks, rails cars, barges or ships ^S-
Pressure vessels designed to operate in excess of 204.9 kPa and without emissions to the ^
atmosphere '
*-H
If also subject to 40 CFR Part 60, subparts K, Ka, Kb, must comply only with the subpart
with the most stringent standards. tŤ,
Ł
|
This manual is intended solely for guidance. No statutory or regulatory >P
requirements are in any way altered by any statements) contained herein. A-fi 1
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Monitoring Requirements:
1) Visual inspections of vessels with fixed roof and internal floating roof as described in
61.272 (a)
2) Determine gap areas and widths between primary and secondary seals and the vessel
wall as in 61.272(b), and conduct visual inspections of each time a vessel with external
floating roof is emptied and degassed as in 61.272(b)(6)
3) Monitor parameters of closed vent systems and control devices in accordance with
operating plan
4) Monitor flares as required in 60.18
Record Keeping Requirements:
1) Maintain records showing dimensions of storage vessel and analysis of capacity as long as
vessel is in operation. This requirement is also applicable to storage vessels with a design
capacity < 38rrr
2) Records related to vessels equipped with closed vent systems with control devices as
described in 61.276(c) (maintain for at least 2 years)
Reporting Requirements:
1) Vessels with fixed roofs and internal floating roofs, and vessels with external roofs:
Notification to the Administrator 30 days prior to filling storage vessel required to be
inspected under 61.272(a)(l), (a)(3), or b(6).
2) Operating plan for closed vent system and control device that meets the requirements of
61.272(c)(l)
3) Initial report describing control equipment and other information as required under
61.274 (a) and (b) (all affected storage vessels)
4) Periodic reports describing inspection results of vessels with fixed roof and internal
floating roofs [61.275(a), (b) and (c)], and describing results of seal gap measurements of
vessels with external floating roofs [61.275(d)]
5) Quarterly reports of each occurrence that results in excess emissions for vessels
equipped with closed vent systems with control devices [61.275(e)]
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-fi?
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Applicability:
r .,.,.,,., . National Emission Standard for Benzene
Facilities loading benzene onto
tank trucks, rail cars or marine
vessels at each benzene
- Record keeping 61.304
production facility and bulk Reporting 61 3(]5
terminal.
40 CFR Part 61 - Subpart BB
Emissions from Benzene Transfer Operations
-Monitoring 61.303
Affected Processes:
Loading Racks:
Each loading rack must be equipped with a vapor collection system
Control devices must be installed that reduce benzene emissions through it by 98 weight
percent
Benzene loading must be done in accordance to procedures and criteria outlined in 61.302
Date of Applicability:
All existing sources.
Exemptions:
Facilities loading benzene-laden waste, gasoline, crude oil, natural gas, liquids, petroleum QQ
distillates or benzen-laden liquid from coke by-product recovery plants DQ
Facilities with annual benzene loading less than 1.3 million liters of 70 weight-percent or more
benzene.
Facilities that load only liquid containing less than 70 weight percent benzene
Monitoring Requirements:
1) Inspect vapor collection system and control device for detectable emissions
2) Incinerator
- Temperature (continuous) ^
- Percent reduction of benzene achieved (performance test) ^j
- Duration of loading cycle (performance test)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-63
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3) Flares
- Heat sensing device
- Visible emission readings, flow rate measurements, maximum permitted velocity calculations,
exit velocity, and heat content (performance test)
- Flare pilot flame monitoring, loading cycle duration, loading cycles where pilot flame is absent
(performance test)
4) Process heater or steam generating unit
- Temperature (units < 44 MW design)
- Periods of operation (units > 44 MW design)
- Description of location at which vent stream is introduced (performance test)
- Duration of loading cycle (performance test)
5) Control Devices: Carbon Adsorption System
- Concentration of organic compounds in outlet gas (continuous)
- Control efficiency, R, of system and all supporting performance test data and calculations
6) Records of equipment operating parameters specified to be monitored and records of
periods of operation during which parameter boundaries are exceeded
7) Records relating to vent systems with valves that could divert emission from control
device
8) Vapor tightness documentation
Reporting Requirements:
1) Initial performance test and engineering report including data required under 61.30 5 (a)
2) Quarterly reports of the information required under 61.30 5 (f)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-fi4
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Applicability:
All existing sources and facilities
handling benzene wastes
including: chemical
manufacturing plant, coke by-
product recovery plants,
petroleum refineries and
hazardous waste treatment
storage and disposal facilities.
40 CFR Part 61 - Subpart FF
National Emissions Standard for Benzene
Waste Operations
- Monitoring 61.354
- Record keeping 61.356
-Reporting 61.357
40 CFR PART 61 - SUBPART FF
AFFECTED PROCESSES
REGULATORY THRESHOLD
Tanks
Surface impoundments
Containers
Oil-water separators
Treatment processes
Individual drain systems
Fixed-roof and closed-vent system with control device so
that detectable emissions < 500 ppmv above background
meeting the specifications in 61.343.
Cover and closed-vent system with control device
designed such that detectable emissions are no greater
than 500 ppmv above background meeting the
specifications in 61.344.
Cover (or cover and closed-vent system for treatment)
designed such that detectable emissions are no greater
than 500 ppmv above background meeting the
specifications in 61.345.
Fixed-roof and closed-vent system with control device
meeting the specifications in 61.347 designed such that
detectable emissions are no greater than 500 ppmv
above background.
Treatment process meeting the specifications in 61.348
that either removes benzene from waste stream to <
10 ppmw on a flow-weighted basis, 99% on a mass basis
or 99% destruction efficiency by combustion.
Cover and closed-vent system meeting the specifications
in 61.346 with control device designed such that
detectable emissions are no greater than 500 ppmv
above background.
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-65
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40 CFR PART 61 - SUBPART FF
AFFECTED PROCESSES
REGULATORY THRESHOLD
Closed-vent systems and control
devices
Closed-vent systems meeting the specifications in 61.349
designed such that detectable emissions are no greater
than 500 ppmv above background
Control devices designed so that:
Enclosed combustion device either reduces organic
emissions by 95 weight-percent or greater; achieves
a total organic concentration of 20 ppmv on a dry
basis corrected to 3% oxygen; or provides minimum
residence time of 0.5 seconds at minimum
temperature of 760°C.
Flares must comply with 60.18.
Vapor recovery system recovers or controls organic
emissions with an efficiency of 95 weight-percent or
greater or controls benzene emissions with 98
percent efficiency.
Flare complies with requirements of 60.18.
Date of Applicability:
All existing sources.
Exemptions:
Waste gases or vapors from process fluids
Waste in segregated storm water sewer
Facilities with a total annual benzene quantity of less than 10 mg/year [calculated in
accordance with 61.342(a)].
Monitoring Requirements:
1) Conduct initial and annual monitoring of detectable emissions from tanks, surface
impoundments, containers, oil/water separators, drain systems, and closed-vent systems
and control devices.
2) Visually inspect tanks, surface impoundments, containers, oil/water separators, and
closed-vent systems and control devices initially and quarterly thereafter.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-66
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3) Monitor each treatment process or wastewater treatment system unit in accordance with
61.354(a)or(b).
4) Continuously monitor control device operation in accordance with 61.354(c).
5) Monitor carbon adsorption systems that do not regenerate carbon onsite in accordance
with61.354(d).
6) Inspect bypass line valves and flow readings from closed-vent bypass lines that could
divert vent streams from control devices in accordance with 61.354(1).
7) Determine annual benzene quantity from facility waste using the procedure specified in
61.355.
Record Keeping Requirements:
1) Records identifying each waste stream and the information required under 61.356(b).
2) Documentation for each offsite waste shipment for treatment, including information in
61.356(c).
3) Engineering design documentation for control equipment (for life of equipment).
4) Records of treatment processes as required under 61.3 5 6 (e).
5) Records of closed-vent systems and control devices as required under 61.356(1).
6) Records of visual inspections conducted as described under 61.3 5 6 (g).
7) Records of tests for no detectable emissions as described under 61.356(h).
8) Information on operation of each treatment process as described in 61.356(i).
9) Information on operation of each control device as described in 61.356(j).
Control devices designed so that:
Enclosed combustion device either reduces organic emissions by 95 weight-percent
or greater; achieves a total organic concentration of 20 ppmv on a dry basis corrected
to 3% oxygen; or provides minimum residence time of 0.5 seconds at minimum
temperature of 760°C.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-fi7
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Flares must comply with 60.18.
Vapor recovery system recovers or controls organic emissions with an efficiency of 95
weight-percent or greater or controls benzene emissions with 98 percent efficiency.
Flare complies with requirements of 60.18.
Reporting Requirements:
1) Initial reports containing information as in 61.357(a) and (d)(l).
2) Annual reports in accordance with 61.3 5 7 (d) (2) - (5) and 61.3 5 7 (d) (8).
3) Quarterly reports required in 61.357(d)(6) and (7).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Applicability:
40 CFR Part 63 - Subpart F
SOCMI facility that meets all of ^ .. , ^ . . c. , , , r^
,, f n . National Emission Standard tor Organic
the following: °
Hazardous Air Pollutants Irom the Synthetic
1) Manufactures as a
primary product one or
more of the chemicals
listed in Table 1,
Organic Chemical Manufacturing Industry
-Monitoring 63.103
- Reporting and Record keeping 63.103
2) Uses as reactant or manufacture as a product, by-product, or co-product, one or
more of the organic HAPs listed in Table 2, and
3) Is located at a plant site that emits more than 10 tpy of any individual HAP or more
than 25 tpy of any combination of HAP in any 12 month period
Affected Processes:
Must limit emissions from all sources (process vents, storage vessels, transfer operations,
wastewater streams, equipment leaks) according to provisions in Subpart G and H.
Date of Applicability:
Sources constructed or modified after December 31, 1982, shall be in compliance with
subparts F, G and H upon initial start-up or April 24, 1994
Existing sources must comply with subparts F and G no later than 3 years from April 22, 1994 j>
Existing sources must comply with subpart H shall comply according to their Table 1 Groups b^
(I-V) and schedules specified in 63.100(k)(3)-(7) 5^
Exemptions: <5?
i
If facility satisfies 1) and 2) above and has a federally enforceable exemption proving 3) is OO
not satisfied ^O
5-H
If facility satisfies 1) and 3) above but does not use or produce any organic HAP listed in CX3
Table 2 °H
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-fiQ
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Monitoring Requirements:
Initial performance tests and initial compliance determinance as specified in Subpart G and H
Record Keeping Requirements:
Facilities subject to subparts F, G and H to keep all applicable reports and records as required
for 5 years (recent 2 at facility and remaining 3 off-site) or as specified in subpart
Reporting Requirements:
1) Initial reports required under subparts F, G and H, and Part 70 or Part 71 operating
permits
2) Notification to the Administrator 30 days prior to conducting performance test
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-7D
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Applicability:
Affects all Group 1 and Group 2
process vents (defined in
63.111) at affected facilities as
determined under subpart F.
40 CFR Part 63 - Subpart G
National Emissions Standards for Organic
Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry for
Process Vents
- Monitoring 63.114
-Record keeping 63.117, 63.118
-Reporting 63.118
40 CFR PART 63 - SUBPART G - PROCESS VENTS
AFFECTED PROCESSES
REGULATORY THRESHOLD
All affected facilities
Group 1 process vents (63.113(a))
Halogenated Group 1 process vent
(63.113(c))
Group 2 process vent (63.113(d))
Must control organic HAP emissions according to
equations provided in 63.112(a) or comply with the
other requirements set forth in 63.112
Reduce organic HAP emissions using a flare
Reduce emissions of total organic HAP by 98 weight
percent or 20 ppmv on a dry basis corrected to 3
percent oxygen whichever is less stringent
Maintain a TRE index value greater than 1.0 at
outlet to recovery device
Reduce overall emissions of hydrogen halides and
halogens by 99 percent or reduce the outlet mass
of total hydrogen halides and halogens to less than
0.45 kg/h whichever is less stringent
Comply with requirements set forth in 63.113(d)-
(g)
I
Date of Applicability:
Dates are specified in Subpart F (63.100(k))
Exemptions:
Overlap with other regulations for process vents must be examined in 63.110(d)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
00
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Monitoring Requirements:
Monitoring requirements for each control device are specified in 63.114; monitoring devices
requires continuous emissions monitoring. Performance tests as required under 63.116.
Record Keeping Requirements:
Logs containing up-to-date records of monitoring; notification of compliance; performance
tests
General reporting requirements as per 63.152:
Initial notification; implementation plan; notification of compliance status; periodic reports
submitted semiannually
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-7?
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Applicability:
Affects all Group 1 and Group 2
storage vessels (defined in
63.111) at affected facilities as
determined under subpart F.
40 CFR Part 63- Subpart G
National Emissions Standards for Organic
Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry for
Storage Vessels
- Monitoring 61.119
- Record keeping 63.123
-Reporting 63.122
40 CFR PART 63 - SUBPART G - STORAGE VESSELS
AFFECTED PROCESSES
REGULATORY THRESHOLD
All affected facilities
Group 1 storage vessels (63.119(a))
Group 2 storage vessels
Must control organic HAP emissions according to
equations provided in 63.112(a) or comply with the
other requirements set forth in 63.112
If stored liquid emits a HAP and has a maximum
true vapor pressure less than 76.6 kPA, then it must
install a control device which complies with the
requirements 63.119(b)-(d)
If stored liquid emits a HAP and has a maximum
true vapor pressure greater than 76.6 kPA, then it
must install a closed vent system that vents to
control device and complies with the requirements
63.119(e)
Must verify emissions average using directions in
63.150 and determine compliance provisions to be
used
Date of Applicability:
Dates are specified in Subpart F (63.100(k)).
Exemptions:
Overlap with other regulations for process vents must be examined in 63.110(b)
00
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-73
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Monitoring Requirements:
Visual inspections of gaps and seals; monitoring requirements for each control device is
specified in 63.119; monitoring devices requires continuous emissions monitoring
Record Keeping Requirements:
Logs containing up-to-date records of monitoring; notification of compliance; design
evaluation; performance tests
Reporting Requirements as per 63.152:
Initial notification; implementation plan; notification of compliance status; periodic reports
submitted semiannually
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-74
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Applicability:
Affects all Group 1 and Group 2
transfer operations (defined in
63.111) at affected facilities as
determined under subpart F.
40 CFR Part 63- Subpart G
National Emissions Standards for Organic
Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry for
Transfer Operations
-Monitoring 63.127
- Reporting and Record Keeping 63.129
40 CFR PART 63 - SUBPART G - TRANSFER OPERATION
AFFECTED PROCESSES
All affected facilities
Group 1 transfer operations (63.125)
Group 2 transfer rack
REGULATORY THRESHOLD
Must control organic HAP emissions according to
equations provided in 63.112(a) or comply with the
other requirements set forth in 63.112
Reduce organic HAP (except halogenated) emissions
using a flare
Reduce emissions of total organic HAP by 98 weight
percent or 20 ppmv on a dry basis corrected to 3
percent oxygen whichever is less stringent
Use a vapor balancing system to collect and recirculate
vapors to storage tanks
Only record keeping required and no other thresholds
apply
Date of Applicability:
Dates are specified in Subpart F (63.100(k))
Exemptions:
Overlap with other regulations for process vents must be examined in 63.110(c)
Monitoring Requirements:
Monitoring requirements for each control device is specified as 63.127; monitoring devices
requires continuous emissions monitoring
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
§
-C3
I
<§
00
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Record Keeping Requirements:
Logs containing up-to-date records of monitoring; notification of compliance; design
evaluation; performance tests.
Reporting Requirements (as per 63.152):
Initial notification; implementation plan, notification of compliance status; periodic reports
submitted semiannually.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-7fi
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Applicability:
Affects all Group 1 and Group 2
process wastewater (defined in
63.11 land 63.132 (d)) at
affected facilities as determined
under subpart F.
40 CFR Part 63- Subpart G
National Emissions Standards for Organic
Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry for
Wastewater
-Monitoring 63.143
- Record keeping 63.147
-Reporting 63.146
40 CFR PART 63 - SUBPART G - WASTEWATER
AFFECTED PROCESSES
REGULATORY THRESHOLD
All affected facilities
Wastewater tanks (Group 1 waste
stream) (63.133)
Surface impoundments (Group 1 waste
stream) (63.134)
Containers (Group 1 waste stream)
(63.135)
Individual drains (Group 1 waste stream)
(63.136)
Oil-water separators (Group 1 waste
stream) (63.137)
Treatment processes (63.138)
Must control organic HAP emissions according to
equations provided in 63.112(a) or comply with the
other requirements set forth in 63.112
A fixed roof required unless the wastewater tank is used
for mixing, heating or treating with exothermic reaction
in which case provisions in 63.133(a) (2) through (h)
apply
Must comply with requirements in paragraphs (b), (c),
and (d).
Must comply with requirements in paragraphs (b)
through (f).
Must comply with requirements in paragraphs (b)
through (d) or (e) through (g).
Must comply with requirements in paragraphs (c) and
(d).
New sources must comply with requirements in
paragraph (a)(l) and existing sources must comply with
requirements in paragraph (a) (2)
Date of Applicability:
Dates are specified in Subpart F (63.100(k))
Exemptions:
Overlap with other regulations for process vents must be examined in 63.110(e)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
00
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Monitoring Requirements:
Comply with inspection requirements in Table 11; monitor appropriate parameters to
demonstrate proper operation of selected treatment
Record keeping Requirements:
Logs containing up-to-date records of monitoring; notification of compliance; design
evaluation; performance tests; periodic reports
Reporting Requirements (as per 63.152):
Initial notification; implementation plan; notification of compliance status; periodic reports
submitted semiannually.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-78
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Applicability:
Applies to pumps,
compressors, agitators,
pressure relief devices,
sampling connection systems,
open-ended valves or lines,
valves, connectors, surge
control vessels, bottoms
receivers, instrumentation
systems, and control devices or
systems used to operate an organic HAP for 300 hours or more during a calendar year
40 CFR Part 63- Subpart H
National Emissions Standards for Organic
Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry for
Equipment Leaks
-Monitoring 63.180
- Record keeping 63.181
-Reporting 63.182
40 CFR PART 63 - SUBPART H
AFFECTED PROCESSES
REGULATORY THRESHOLD
Pumps in light liquid service
Compressors
Pressure relief devices in
gas/vapor service
Sampling connection systems
Valves in gas/vapor service and in
light liquid service
Pumps, valves, connectors, and
agitators in heavy liquid service;
instrumentation systems; and
pressure relief devices in liquid
service
Surge control vessels and
bottoms receivers
Closed-vent system and control
devices
Agitators in gas/vapor and light
liquid service
Connectors in gas/vapor and light
liquid service
Must determine Phase (I, II, or III) as per provisions in 63.163
and the applicable threshold for leak detection
Must be equipped with a seal system that prevents leakage to
atmosphere and complies with provisions in 63.164
Must have detectable emissions < 500 ppm above background
and must comply with other provisions in 63.165
Must be equipped with a closed-vent system that returns the
purge to the process and complies with provisions in 63.166
Must determine Phase (I, II, or III) as per provisions in 63.168
and the applicable threshold for leak detection
Must report leaks detected by visual, olfactory, audible or any
other method must be repaired by methods specified in 63.180
If not routed back to the process and meets conditions specified
in Table 2 or 3 must be equipped with closed-vent system
Must comply with requirements as per 63.172
Must be monitored monthly to detect leaks as per 63.173 and
comply with all provisions therein
Must be monitored to detect leaks as per 63.174 and comply
with all provisions therein
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-79
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Date of Applicability:
Dates are specified in Subpart F (63.100(k))
Exemptions:
Lines and equipment not containing process fluids
Monitoring Requirements:
Compliance with Method 21 of 40 CFR 60, App. A, and other provisions in 63.180(b)
Record Keeping Requirements:
Only one record keeping system must be maintained for all process units at one plant.
Information must be maintained as described in 63.181(b)-(k) including: identification numbers
for all affected process units; initial and periodic reports, delay of repair records; design
specifications and performance demonstration activities; documentation for all quality
assurance programs implemented; notifications of compliance status
Reporting Requirements:
1) Initial notification as described in 63.182(b)
2) Notification of compliance status as described in 63.182(c)
3) Semiannual reports as described in 63.182(d)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-8D
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40 CFR Part 63 - Subpart I
National Emission Standards for Organic
Hazardous Air Pollutants Certain processes
Subject to the Negotiated Regulation for
Equipment Leaks
Applicability:
Major sources (including
pumps, compressors,
agitators, pressure relief
devices, sampling connection
systems, open-ended valves
or lines, valves, connectors,
surge control vessels, bottoms receivers, and instrumentation systems that are intended to
operate in organic hazardous air pollutant services for 300 hours or more during the calendar
year)
Affected Processes:
Emissions of designated organic HAPs from the following processes: styrene-butadiene
rubber production, polybutadiene rubber production, agricultural chemicals as identified in
§63.190(b)(3), polymers/resins or other chemical products listed in §63.190(b)(4),
pharmaceutical production processes using carbon tetrachloride or methylene chloride, and
processes producing the polymers/resins or other chemical products listed in §63.190(b)(6).
Date of Application:
Variable dates, but not later than April 22, 1997
Exemptions:
Temporary exemption, provided that notification and certification is provided, for facilities that
emit less than 10 tons per year of any individual HAP, and less than 25 tons per year of any
combination of HAPs.
Requirements:
Owners and operators of subject sources must comply with the requirements of Subpart H
for the processes and designated organic HAPs and certain provisions of Subpart A, as
identified in §63.192(b). Also, all facilities subject to this subpart must receive a permit under
40 CFR Part 70 or 71.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-81
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Record Keeping:
All records required in Subpart H and in §63.192(1) (2) for at least two years, except as
otherwise specified in Subpart H.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Applicability:
" 40 CFR Part 63 - Subpart Q
National Emission Standards for Hazardous
Air Pollutants for Industrial Process Cooling
All new and existing industrial
process cooling towers (IPCTs)
which use chromium-based mi ruuu
water treatment chemicals and Towers
are either a major source or are
integral parts of a facility which
is a major source (defined in 64.401).
Date of Applicability:
Existing IPCTs must comply with subpart Q no later than 18 months from September 8,
1994. New IPCTs that have initial startup before September 8, 1994, must comply by
September 8, 1994. New IPCTs that have initial startup on or after September 8, 1994,
must comply upon initial startup.
Affected Processes:
No owner/operator of an IPCT shall use chromium-based water treatment chemicals in any
affected IPCT (63.402).
Monitoring Requirements:
No monitoring is required unless there is evidence to indicate that the IPCT is not in
compliance with the requirements of 63.402.
Record Keeping:
Copies of initial notification and notification of compliance status are required to be kept onsite
for at least 5 years as specified in 63.405(a).
Reporting Requirements (as per 63.405):
Initial notification, notification of compliance status (in accordance with Part 63, subpart A): OO
Table 1 of Subpart Q indicates general provisions applicability. ^O
I
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A oo
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. A-84
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40 CFR Part 68
Chemical Accident Prevention Provision
Applicability:
Owners or operators of
stationary sources that have
more than a threshold
quantity of a regulated substance in a process, as determined under §68.115.
Date of Applicability:
The latest of the following dates:
- June 21, 1999
Three years after the date on which a regulated substance is first listed
The date on which a regulated substance is first present above a threshold quantity
Applicable Program:
Program 1 - For five years prior to submission of the RMP, the process has not had an
accidental release of a regulated substance that led to death, injury, or response or restoration
activities for exposure to an environmental receptor, and the distance to a toxic or flammable
endpoint for a worst-case release assessment is less than the distance to any public receptor,
and emergency response procedures have been coordinated between the stationary source
and local emergency planning and response organizations.
Program 2 - A covered process not subject to Program 1 or Program 3
Program 3 - A covered process, not subject to Program 1 and either; the process is in SIC
code 2611, 2812, 1821, 2865, 2869, 2873, 2879, or 2911, or, the process is subject to the
OSHA process safety management standard 29 CFR §1910.119.
General Requirements:
Submit a Risk Management Plan (RMP) with a registration that includes all covered processes.
Risk Management Plan Requirements: RMPs shall include:
- an executive summary describing elements of the RMP
- a single registration form covering all regulated substances
- worst-case release scenario information
- five-year accident history information
^ This manual is intended solely for guidance. No statutory or regulatory >P
requirements are in any way altered by any statements) contained herein. A-R^i
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- emergency response program information
- certification statement
- regular review and updates to the RMP
- additional Programs 2 and 3 information.
Other Requirements:
- Maintain records for five years
- Information available to the public
- Additional permit requirements for facilities permitted pursuant to Parts 70 or 71.
- Provide access to implementing agency for RMP audits.
Additional Program 1 Requirements:
- Analyze worst-case release scenarios, document public receptor is beyond endpoint, and
submit
- Complete five year accident history for the process and submit
- Ensure that response actions coordinated with local agencies
- Certify as specified in §68.12(b)(4).
Additional Program 2 Requirements:
- Develop and implement a management system, assigning a qualified person with the overall
responsibility for the program
- Conduct a hazard assessment
- Implement a Program 2 or Program 3 Prevention Program
- Develop and implement an emergency response program
- Submit the data on prevention program elements for Program 2 processes.
Additional Program 3 Requirements:
- Develop and implement a management system, assigning a qualified person with the overall
responsibility for the program
- Conduct a hazard assessment
- Implement a Program 3 Prevention Program
- Develop and implement an emergency response program
- Submit the data on prevention program elements for Program 3 processes.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
Applicability:
Any individual, corporate or
government entity that
produces, transforms, imports,
or exports these controlled
substances.
40 CFR Part 82
Protection of Stratospheric Ozone
Subpart A: Production and Consumption Controls
Subpart E: The Labeling of Products Using Ozone-Depleting
Substances
Subpart F: Recycling and Emissions Reduction
40 CFR PART 82
REQUIREMENTS
EFFECTIVE DATE
Subpart A: Production and Consumption Controls
Prohibition on the production and consumption of any Class
I substance in annual quantities greater than the relevant
percentage specified in the regulations (based on quantity of
substance produced in the baseline year).
Prohibition on the production of all Class I substances.
Prohibition on the production of all Class II substances.
Reporting Requirements:
Reports on production, imports, and exports of Class I and
II substances.
Subpart E: The Labeling of Products Using Ozone-
Depleting Substances
Containers in which Class I and II refrigerants are stored or
transported are required to be labeled with a warning
stating that it contains a substance which harms public health
and environment by destroying ozone in the upper
atmosphere.
Subpart F: Recycling and Emissions Reduction
Prohibition on knowingly venting ozone-depleting
compounds used as refrigerants into the atmosphere during
maintenance, service, repair, or disposal or air-conditioning
or refrigeration equipment.
Technicians servicing air-conditioning and refrigeration
equipment are required to evacuate refrigerant in the line
according to prescribed guidelines.
January 1 of each year specified in
the regulations.
January 1, 2000 flanuary 1, 2002, for
methyl chloroform)
January 1,2030
Quarterly
Julyl, 1992
July 13, 1993
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-87
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40 CFR PART 82
REQUIREMENTS
EFFECTIVE DATE
Recovery and/or recycling equipment must be tested by an
EPA-approved third-party testing organization.
Require repair of substantial leaks in industrial process
refrigeration equipment (charge greater than 50 pounds).
All persons who maintain, service, repair, or dispose of
appliances are required to be certified.
Persons servicing or disposing of air-conditioning and
refrigeration equipment are required to certify that certified
recovery and recycling equipment has been acquired and
they are complying with the applicable requirements of 40
CFRPart82.SubpartF.
All equipment sold after November
15, 1993. Equipment manufactured
prior to this date is grandfathered.
Within 30 days of recovery
November 14, 1994
August 12, 1993
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A-88
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Appendix B
Safe Drinking
Water Act (SDWA)
The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect
human health from contaminants in drinking water. The law authorizes EPA to develop
national drinking water standards and to create a joint Federal/State system to ensure
compliance with these standards. The SDWA also directs EPA to protect underground
sources of drinking water through the control of underground injection of liquid wastes. The
Public Water System Program (i.e., the National Primary and Secondary Drinking Water
Regulations) and the Underground Injection Control (UIC) Program are two components of
the SDWA that may be applicable to chemical facilities. The requirements of the programs
are summarized below.
Public Water System Program
Under the SDWA, EPA has established primary and secondary drinking water regulations
designed to protect the public health. The primary drinking water regulations cover
contaminants that have been determined to have adverse effects on human health or are
enforceable by EPA or a State. The secondary drinking water regulations cover contaminants
that affect the aesthetic quality of drinking water and are intended as guidelines that are not
enforceable by EPA but a State can choose to enforce some or all of the secondary drinking
water regulations. Most of the States have "primacy" for the program; that is, they have
adopted the primary drinking water regulations and are responsible for implementing and
enforcing the regulations. The States can develop regulations more stringent than the national
drinking water regulations. The national drinking water regulations apply to public water
systems. A public water system is defined as a system that either (1) has at least 15 service
connections or (2) regularly serves an average of at least 25 individuals daily at least 60 days
out of the year. There are three types of public water systems: community water systems,
non-transient non-community water systems and transient non-community water systems.
Facilities employing at least 25 people and regularly providing potable water from its private
well, lake, river or reservoir to these same employees for over 6 months of the year would
be classified as a non-transient non-
community public water system.
National Primary Drinking Water Regulations
have been established for 78 contaminants:
50 organics, 18 inorganics, 2 radionudides,
Safe Drinking Water Act
Public Water Supply Program B-l
Underground Injection Control Program . . . B-2
SDWA Assessment Considerations B-3
SDWA Regulatory Requirements B-4
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-l
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and 8 microbiologicals. For each contaminant, the national primary drinking water regulations
establish Maximum Contaminant Level Goals (MCLGs) and Maximum Contaminant Levels
(MCLs) or treatment techniques.
The National Primary Drinking Water Regulations also establish testing procedures,
monitoring requirements such as minimum monitoring frequencies, record-keeping
requirements, public notification requirements and requirements for routine reporting to the
State or EPA. Specific analytical methods must be used and the analyses must be conducted
by laboratories certified by EPA or the State. Some state programs require that the analyses
be conducted by the State laboratory.
Monitoring requirements vary by contaminant, by source of supply, and by system size. The
State customizes the sampling frequency to the local circumstances and may even waive
sampling requirements for specific contaminants.
Underground Injection Control Program
The SDWA UIC program (40 CFR Parts 144-148) is a permit program that protects
underground sources of drinking water through regulation of five different classes of injection
wells. A "well" is defined at 40 CFR §144.3 as a bored, drilled, or driven shaft, or a dug hole,
whose depth is greater than the largest surface dimension. The five well classes are as
follows:
Class I: Technologically sophisticated wells that inject large volumes of
hazardous and non-hazardous wastes into deep isolated rock formations
that are separated from the lowermost underground source of drinking
water (USDW) by many layers of impermeable clay and rock.
Class II: Wells that inject fluids associated with oil and natural gas production.
Most of the injected fluid is brine that is produced when oil and gas are
extracted from the earth (about 10 barrels for every barrel of oil).
Class III: Wells that inject super-hot steam or water into mineral formations,
which are then pumped to the surface and extracted. Generally, the
fluid is treated and reinjected into the same formation. More than 50
percent of the salt and 80 percent of the uranium extraction in the
United States is produced this way.
Class IV: Wells that inject hazardous or radioactive wastes into or above
underground sources of drinking water. These wells are banned under
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. R-?
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the UIC program because they directly threaten the quality of
underground sources of drinking water.
Class V: Wells that use injection practices not included in the other classes.
Some Class V wells are technologically advanced wastewater disposal
systems used by chemical facilities, but most are "low-tech" holes in the
ground. Generally, these wells are shallow and depend upon gravity to
drain or "inject" liquid waste into the ground. Their simple construction
provides little or no protection against possible ground water
contamination, so it is important to control what goes into them.
Class I and V UIC permitting programs are of significance to chemical facilities. The UIC
permit program is primarily state-run, since EPA has delegated authority to all but a few states.
In some instances, the UIC program may consist of a state-administered program applicable
to some classes of wells and an EPA-administered program applicable to other classes of
wells. UIC permits include design, operating, inspection, and monitoring requirements.
Operation of injection wells may also be authorized by rule (i.e., permit by rule). Wells used
to inject hazardous waste must also comply with RCRA corrective action standards and must
meet applicable RCRA LDR standards.
Any underground injection is unlawful unless authorized by a permit or a rule. Additionally,
the construction of any well required to have a permit is also prohibited until issuance of that
permit. All owners or operators are required to apply for a permit, even if authorized by
rule, unless the authorization was for the life of the well.
Currently, there are no specific Federal requirements for the injection into Class V wells.
However, if injection into these wells could cause the water in the receiving USDW to violate
primary drinking water regulations, then EPA or an authorized state could require the issuance
of a permit that could include the substantive requirements of the UIC program (40 CFR
§144.12(c)).
SDWA Assessment Considerations
Compliance evaluations should determine whether the facility has its own potable water
supply and if so, whether the facility regularly provides this potable water to at least 25 of the
same people at least six months of the year. If it is determined that the facility is subject to the
national drinking water regulations, then the inspection team should evaluate whether the
facility has conducted monitoring of required contaminants at required frequency. The
inspector should verify that the facility is using an approved laboratory and approved tests and
is maintaining the required records. The inspectors should confirm that the facility has notified
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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employees of violations through continuous posting in conspicuous places in the workplace or
through hand delivered or mailed written notices.
Compliance evaluations should determine if wastes are being injected at the site, and if so, if
the facility is operating under a permit or by rule. If permitted, the inspection team should
verify that all terms of the permit are being met. The inspection team should confirm that
wastes being injected are identified in the permit and no unpermitted wastes are injected.
Also, the inspectors should evaluate well records and verify that the volume of waste being
injected is within the limitations of the permit. If operating under rule, inspectors should verify
that a permit application has been submitted in accordance with the Federal or State
requirements unless the facility is authorized by rule to inject during the life of the well. If
operating under permit by rule conditions, the inspectors should verify that the facility is
complying with applicable regulations identified in 40 CFR Part 144, Subpart C.
SDWA Regulatory Requirements
The following section provides a summary of the principal regulations developed pursuant to
the SDWA that may apply to the organic chemical industry: 40 CFR Part 141 - National
Primary Drinking Water Regulations; 40 CFR Part 143 - National Secondary Drinking Water
Regulations; and 40 CFR Part 144 - Underground Injection Control Program.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. R-4
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Applicable Subparts:
Public water systems
classifications applicable to
organic chemical manufacturers:
40 CFR Part 141
National Primary Drinking Water Regulations
Community water system - A public water system which serves at least 15 service
connections used by year round residents or regularly serves at least 25 year-round
residents.
Non-transient non-community water system - A public water system that is not a
community water system and that regularly serves at least 25 of the same persons over 6
months per year.
40 CFR PART 141
REQUIREMENTS
EFFECTIVE DATE
Maximum Containment Levels Subpart B, G
Maximum Containment Level Goals Subpart F
Monitoring and Analytical Requirements Subpart C, H,
Reporting, Public Notification and Record Keeping
Subpart D, H, I
All regulations in effect
Required Sampling and Testing Frequencies, §141.21
TESTS
Inorganics
Organics: except THMs
Organics: THMs
FREQUENCY
(COMMUNITY SYSTEM)
Systems using surface water:
every year
Systems using groundwater only:
every 3 years
Systems using surface water:
every 3 years
Systems using groundwater only:
state option
Systems serving populations of
10,000 or more: 4 samples per
quarter per plant
FREQUENCY
(NON-COMMUNITY)
State option except for nitrate*
State option
State option
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-5
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TESTS
FREQUENCY
(COMMUNITY SYSTEM)
FREQUENCY
(NON-COMMUNITY)
Coliform bacteria*
Radiochemicals: natural
Radiochemicals:
man-made
Dependent on number of
people served by the water
system
Systems using surface water:
every 4 years
Systems using groundwater only:
every 4 years
System using surface water
serving population greater than
100 000: every 4 years. All other
systems: state option
Systems using surface and/or
groundwater: 1 per quarter (for each
quarter water is served to public)
State option
System using surface and/or
groundwater: state option
* Although routine nitrate monitoring is established at state option, the initial monitoring is required and
should have been completed by June 1979.
** Repeat sampling required if routine sampling is total coliform-positive.
Special Monitoring Requirements for Sodium and Corrosion
(Community systems only)*
TEST
FREQUENCY
Sodium
Corrosivity includes those characteristics known to
indicate corrosivity:
pH
Calcium hardness
Total dissolved solids (TDS)
Temperature
Langelier Index
Systems using surface water: annually
Systems using groundwater only: every 3 years
Once unless additional monitoring required by state or
EPA
First analyses must have been completed by February 1983.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-6
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Record-Keeping Requirements [§§141.33 and 141.91]
RECORDS PERTAINING TO
TIME PERIOD
Bacteriological analyses
Chemical analyses
Actions taken to correct violations
Sanitary survey reports
Variances or exemptions
Lead and copper control
At least 5 years
At least 10 years
At least 3 years after last action taken
At least 10 years
At least 5 years following expiration
At least 12 years
Lab Reports Summary Requirements^ 141.33]
SAMPLING INFORMATION
ANALYSIS INFORMATION
Date, place, and time of sampling
Name of sample collector
Identification of sample:
Routine or check sample
Raw or treated water
Date of analysis
Laboratory conducting analysis
Name of person responsible for analysis
Analytical method used
Analysis results
Reporting Requirements for Check Sampling
CONTAMINANT
CHECK-SAMPLE REPORTING
Microbiological
Nitrate
All others
Must report to state within 48 hours when any check sample confirms the
presence of coliform bacteria.
Must report to state within 24 hours if check sampling confirms MCL has
been exceeded
Must be reported to the state within 10 days after the end of the month in
which the sample was received.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-7
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MCL Violations
CONTAMINANT
VIOLATION
Inorganic chemicals (expect nitrate) and organic
chemicals (except THMs)
Nitrate
THMs
Radionuclides (natural and man-made)
Microbiological (coliform testing): membrane filter and
multiple-tube fermentation
If average of results from initial sample plus 3 check
samples exceeds MCL
If average of results from initial sample plus the
check sample exceeds MCL
If average of results from present quarter plus
those of 3 preceding quarters exceeds MCL*
If average annual concentration exceeds MCL**
If any of the MCLs are exceeded
Quarter means a 3-month period. For convenience, calendar quarters are used.
Based on individual analyses of 4 consecutive quarterly samples or a single analysis of an annual composite
of 4 quarterly samples.
Public Notification Requirements, §141.32
VIOLATION OR CONDITION
Violation of an MCL, acute
Violation of an MCL, non-acute
Failure to monitor
Failure to follow compliance schedule
Failure to use approved testing procedure
System granted a variance or exemption
REQUIRED TIMING
72 HOURS
3,4, 5
14 DAYS
2,4, 5
2,4,5
45 DAYS
1,4, 5
1,4,5
3 MONTHS
1,4, 5
1,4,5
2,4, 5
2,4,5
2,4, 5
1,4,5
1 - Direct mail
4 - Hand delivery
2 - Local newspaper
5 - Continuous posting in conspicuous places
3 - By local radio and/or TV
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-8
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Applicable Subparts:
These regulations are not
Federally enforceable but are
intended as guidelines for
States.
40 CFR Part 143
National Secondary Drinking Water
Regulations
40 CFR Part 143
Component
Regulatory Recommendation
Standards
Monitoring
Analytical Methods
Notification
Secondary MCLs exist for 15 contaminants
Conducted at least as frequently as the monitoring performed for
inorganic chemicals in the National Interim Primary Drinking
Water Regulations and more frequently for parameters such as
pH, color, and odor
pH, copper, and fluoride should be analyzed consistent with
methods described in 40 CFR Part 141. Other contaminants
should be analyzed using the procedures specified in 143.4(b).
Community water systems that exceed the secondary MCL for
fluoride, but do not exceed the primary MCL, should notify (using
the public notice provided in 143.5(b)) all billing units annually, all
new billing units at the time service begins, and the state public
health officer.
00
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-9
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. R-1 D
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Applicable Subparts:
Well classifications applicable
to organic chemical
manufacturers:
40 CFR Part 144
Underground Injection Control Program
Class I - Wells used to inject hazardous or nonhazardous wastes beneath the lower most
formation containing within one-quarter mile of the well-bore, an underground source of
drinking water.
Class V - Injection wells not included in other classes.
40 CFR PART 144
REQUIREMENTS
EFFECTIVE DATE
Any underground injection is prohibited unless authorized
by permit or rule. Construction of any well required to
have a permit is prohibited until the permit has been
issued.
Authorization by Rule Requirements:
Reporting Requirements:
Inventory information as specified in 40 CFR 144.26
24-hour notification of noncompliance that may
endanger health or the environment (Class I wells)
as required in 40 CFR 144.28(b)
Plugging and abandonment plan (Class I wells) as
required in 40 CFR 144.28(c).
Reports containing the information required in 40
CFR 144.28(h)(l) (Class I wells)
Notice of abandonment as required in 40 CFR
144.28(j)
Plugging and abandonment report as required in 40
CFR 144.28(k)
One year after the date of approval or effective
date of the UIC program for the State.
Orally within 24 hours and written five days
One year after the effective date of the UIC
program in the State (EPA administered
programs).
Quarterly
As specified by the Director
Existing wells: No later than 4 years from
approval or promulgation of UIC program.
New wells: Reasonable time before construction
is expected to begin
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-ll
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40 CFR PART 144
REQUIREMENTS
EFFECTIVE DATE
Authorization by Permit
Monitoring requirements:
All owners and operators (even those authorized by
rule, unless authorized for life of the well) are
required to submit a permit application containing
the information in 40 CFR 144.31.
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B-12
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Appendix C Federal
Insecticide, Fungicide,
and Rodenticide Act (FIFRA)
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regulates the manufacture,
distribution, sale, and use of pesticides to minimize risk to human health and the environment.
A pesticide is defined as any substance intended to prevent, destroy, repel, or mitigate pests.
Chemical facilities that produce pesticides or pesticide active ingredients are subject to FIFRA
and its implementing regulations, which are found at 40 CFR §§150-189. These regulations
are summarized below; however, the detailed requirements included in the applicable
regulations are presented later in this appendix. For the purposes of this manual, the term
pesticide includes pesticide active ingredients. Specifically, FIFRA requires:
* All pesticides to be registered with EPA
* All manufacturers of pesticides to be registered with EPA, submit specific
reports, and keep specific records.
Registration of Pesticides and Pesticide-Producing Establishments
Section 3 of FIFRA and the regulations at 40 CFR Part 152 state who may register a pesticide
and the procedures and information necessary for registration. Basically, no pesticide can be
sold or distributed unless it is registered with EPA. The party who registers the pesticide is
known as the registrant, and may be the manufacturer. Any party seeking a registration for a
new pesticide product must submit an application for registration, which contains the
information specified in 40 CFR §152.50. (40 CFR Part 158 specifies the types and minimum
amounts of data and information EPA requires to make regulatory judgements about the risks
and benefits of pesticides.) All applications for new registrations must be approved by EPA
before the product may legally be distributed or sold. Exemptions to the registration
requirements are
contained in 40 CFR
§152.30.
and 40 CFR Part 167, all
The Federal Insecticide. Fungicide, and Rodenticide Act
I Registration of Pesticides and Pesticide-Producing Establishments... C-l j
Under Section 7 ot HFRA I FIFRA Assessment Considerations C-2
FIFRA Regulatory Requirements C-3
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
pesticide-producing establishments must register with EPA and receive a registration number.
40 CFR §167.2 identifies who must register, the exact information an establishment must
submit, and the required timeframes for registration. Specific reporting requirements for
pesticide-producing establishments (found at 40 CFR §167.85) include for each pesticide
produced, the amount (1) produced during the past year, (2) sold or distributed during the
past year, or (3) estimated to be produced during the current year. These reports (called
Annual Pesticide Production Reports) must be submitted to EPA annually on or before March
1. 40 CFR §167.85 also identifies the specific recordkeeping requirements with which the
pesticide producer must comply. Additional recordkeeping and reporting requirements for
the pesticide producer are identified in 40 CFR Part 169.
In addition to the above requirements, FIFRA has stringent standards for the labeling and
packaging of pesticides. 40 CFR Part 156 identifies specific labeling requirements. 40 CFR
Part 157 identifies packaging requirements, including child-resistant packaging requirements
(SubpartB).
FIFRA Assessment Considerations
Chemical manufacturers are not responsible for complying with the requirements of FIFRA
unless it produces a pesticide. If a facility does produce a pesticide, it should have an EPA
Establishment Number. And, if it has an EPA Establishment Number, it should be submitting
an Annual Pesticide Production Report for each pesticide it produces.
Not all chemical facilities that produce a pesticide are necessarily registrants. A registrant is the
person who registers the pesticide with EPA prior to selling or distributing it. If the chemical
facility is the registrant of a specific pesticide, that pesticide must be registered with EPA and
have a registration number.
Most facilities that produce pesticides are aware of the various registration processes they must
comply with. However, it is the reporting and recordkeeping requirements that tend to be
overlooked. The facility must be certain it is complying with all reporting requirements, not
just the Annual Pesticide Production Report. One of the regularly overlooked requirements is
the child-resistant packaging reporting requirements at 40 CFR Part 157. Recordkeeping
requirements under FIFRA are extensive with retention times varying from 2 years up to 20
years. Again, a pesticide producer must ensure that it maintains all the records required by
regulation for the period of time required. As mentioned, some of the records must be kept
for a period of 20 years; however, they can be transferred to EPA after 3 years. A facility must
track these records carefully and ensure it has documentation regarding the transfer to EPA.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. f"1-?
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FIFRA Regulatory Requirements
The following sections provide a summary of the principal regulations developed pursuant to
FIFRA that may apply to the organic chemical industry. These regulations include:
> 40 CFR Part 152 - Pesticide Registration and Classification Procedure
> 40 CFR Part 156 - Labeling Requirements for Pesticides and Devices
> 40 CFR Part 157 - Packaging Requirements for Pesticide Devices
> 40 CFR Part 167 - Registration Pesticide and Active Ingredient Producing
Establishments
* 40 CFR Part 167.85 - Submission of Reports for Pesticide and Active Ingredient
Producing Establishment
> 40 CFR Part 169 - Books and Records of Pesticide Production and Distribution
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P-4
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Affected Community:
Anyone wishing to legally
distribute or sell a pesticide
Applicability:
Prior to distributing or selling the pesticide
Requirements:
All pesticides must be registered with EPA
FIFRA-40CFRPartl52
Pesticide Registration and Classification
Procedures
10
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
C-5
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
FIFRA-40CFRPartl56
Labeling Requirements for Pesticides and
Devices
Affected Community:
Producer or registrant of the
pesticide
Applicability:
Prior to distribution or selling
Requirements:
All pesticide products must bear a label containing the following information:
1) name, brand, or trademark under which the product is sold;
2) name and address of the producer/registrant;
3) net contents;
4) product registration number;
5) producing establishment number;
6) ingredient statement;
7) warning or precautionary statement;
8) directions for use; and
9) use classification^)
The label must be approved by EPA prior to distribution of the product.
10
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
FIFRA-40CFRPartl57
Packaging Requirements for Pesticides and
Devices
Affected Community:
Registrant of the pesticide
Applicability:
Certification:
When applying for registration or within 6 months of notification that the pesticide must
be in child-resistant packaging.
Reporting:
When applying for registration or within 6 months of notification that the pesticide must
be in child-resistant packaging.
Record Keeping:
As long as the registration of the pesticide is in effect
Requirements:
Pesticides meeting the requirements of §157.22 must be packaged in child-resistant packaging
for distribution or sale.
Certification:
Certify that the package meets the standards of §157.32
Reporting:
A certification statement containing:
- name and EPA registration number of the product to which the certification applies,
- registrant's name and address,
- date,
- name, title, and signature of the company official making the certification, and
- a statement that the packaging meets the established effectiveness, compatibility, and
durability standards
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P q
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Record Keeping:
A description of the package including:
- the dimension and composition of container and
- the closure or child-resistant mechanism
Copy of the certification statement (see above)
One of the following types of records verifying the package is child-resistant:
- test data based on established protocol;
- test data, not based on established protocol, or measurements of the package and an
explanation as to why the data or measurements demonstrate the package is child
resistant;
- test data on a different package and an explanation of why the data demonstrate the
package is child resistant, or
- written evidence indicating testing was conducted in conformance with the established
protocol
Records verifying the package meets the established compatibility and durability standards
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i n
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FIFRA-40CFRPartl67
Registration of Pesticide and Active Ingredient
Producing Establishments
Affected Community:
Any pesticide-producing
establishment
Applicability:
Prior to any pesticide production at the facility
Requirement:
Any establishment where a pesticide is produced must be registered with EPA
§
QJ
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
C-ll
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i o
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FJFRA - 40 CFR Section 167.85
Submission of Pesticide Reports for Pesticide
and Active Ingredient Producing
Establishments
Affected Community:
Each pesticide producer
operating an establishment
Applicability:
Initial report no later than 30 days after the first registration and annually thereafter, on or
before March 1
Requirement:
Each pesticide producer operating an establishment must submit a report, using a form
supplied by EPA, containing the following information:
name and address of the establishment, and
the amount of each pesticide
produced during the past year,
sold or distributed during the past year, and
estimated to be produced during the current year
§
53
10
00
§
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
C-13
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i ,
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FIFRA-40CFRPartl69
Books and Records of Pesticide Production
and Distribution
Affected Community:
All producers of pesticides
Applicability:
Retention of records from 2 years to 20 years
Requirement:
Maintain the specific records identified in §169.2 and provide access to authorized
representatives to review and to copy records required to be maintained.
0}
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
C-15
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i r.
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Appendix D Resource Conservation
and Recovery Act (RCRA)
The Resource Conservation and Recovery Act (RCRA) of 1976, which amended the Solid
Waste Disposal Act of 1965, addresses hazardous (Subtitle C) and solid (Subtitle D) waste
management activities. The Hazardous and Solid Waste Amendments (HSWA) of 1984
strengthened RCRA's waste management provisions, including adding a Subtitle I which
governs Underground Storage Tanks (USTs). The goals and objectives of RCRA are to
protect human health and the environment and to conserve valuable materials and energy
resources. The applicable RCRA titles and the regulations and guidelines developed pursuant
to RCRA are illustrated in Exhibit D-l and are discussed below.
Regulations promulgated pursuant to Subtitle C of RCRA, at 40 CFR Parts 260-299, establish
a "cradle-to-grave" system that governs hazardous wastes from the point of generation to
treatment or disposal. As of 1996, 46 States are authorized to implement aspects of the
RCRA program and may include requirements more stringent than Federal regulations in their
authorized program. There are different levels of State authorization. States can be granted
primacy (i.e., approval to implement a State-administered program) for the base RCRA
program, or pre-HSWA RCRA requirements, for administering land disposal requirements,
and for administering the RCRA corrective action program. Non-RCRA authorized states or
territories (Alaska, Hawaii, Iowa, Puerto Rico and Wyoming) may also have state laws that
address hazardous waste management requirements.
Subtitle D of RCRA sets up a framework for regulating non-hazardous solid wastes. Impacts
from Subtitle D on a chemical facility may be direct, where the facility operates a solid waste
incinerator or manages an on-site solid waste landfill, or indirect, coming into play as a result
of a facility's use of an off-site solid waste disposal facility. Non-hazardous solid wastes are
regulated through state solid waste management programs and are specific to each state.
Typically, units such as solid waste
landfills and non-hazardous waste
incinerators are regulated through
state-issued permits. Subtitle I
regulates USTs that contain
petroleum and hazardous substances.
Regulations for USTs are
promulgated at 40 CFR Part 280.
Following is a summary of RCRA
regulations applicable to the chemical
industry.
Resource Conservation and Recovery Act Requirements
Hazardous Waste Generation D-2
Hazardous Waste Transportation Regulations D-7
Hazardous Waste Treatment, Storage, and
Disposal Regulations D-7
Land Disposal Restrictions D-8
Underground Storage Tank Regulations D-9
RCRA Assessment Considerations D-l 1
RCRA Regulatory Requirements D-l2
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. -p\_ i
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Exhibit D-1. RCRA Statutes and Regulatory Requirements for Organic
Chemical Facilities
Resource Conservation and Recovery Act
Subtitle C Hazardous Waste Management
Subtitle D State or Regional Solid Waste Plans
Subtitle I Regulation of Underground Storage Tanks
Subtitle C
40 CFR Part 261 Hazardous Waste
Identification
40 CFR Part 262 Hazardous Waste
Generators
40 CFR Part 263 Hazardous Waste
Transportation
40 CFR Part 264-265 Treatment,
Storage, Disposal
40 CFR Part 266 Specific Hazardous
Wastes/Specific Hazardous Waste
Management Facilities (Subpart H-
Boilers/Industrial Furnaces)
40 CFR Part 268 Land Disposal
Restrictions
40 CFR Part 270 RCRA Permit
Program
40 CFR Part 279 Used Oil
Management
Subtitle D
40 CFR Part 257 Solid
Waste Disposal Criteria
40 CFR Part 258
Municipal Waste Landfills
Subtitle 1
40 CFR Part 280
Underground Storage
Tanks
Hazardous Waste Generation
Generators of hazardous waste are subject to requirements under 40 CFR Part 262. The
determination of what material is a hazardous waste is the essence of any RCRA compliance
evaluation. Regulations for identification of hazardous wastes are detailed in 40 CFR Part 261.
The definition of a hazardous waste is not straightforward. Under the Federal rules, to be a
hazardous waste, a waste must: be a solid waste (as defined in 40 CFR §261.2); not be
excluded from regulation as a hazardous waste under 40 CFR §261.4; and be a characteristic
waste, a listed waste, a mixture of a solid waste and a listed waste, or a mixture of a solid
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-2
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waste and a characteristic waste that still exhibits that characteristic. Also, a waste is hazardous
if it is a mixture of soil or water and a listed waste, or a mixture of soil or water and a
characteristic waste that still exhibits that characteristic.
A solid waste, by definition, is any discarded materialsolid, liquid, or containerized gasthat
is not excluded under the regulations. Exclusions include hazardous waste mixed with
domestic sewage, discharged as point source discharges regulated under the CWA and
certain secondary materials that are reclaimed and reused in the original process or processes
in which they were generated.
If a waste meets the definition of solid waste, it is considered hazardous if it exhibits one or
more of four defined hazardous waste charactieristics (see Exhibit D-2), or is listed as a
hazardous waste in 40 CFR Part 261 (see Exhibit D-3). It is the generator's responsibility to
determine whether a waste is hazardous. This determination must be based on test results
or the generator's knowledge and familiarity with the waste. Generators may be subject to
enforcement penalties for improperly determining that a waste is not hazardous.
Exhibit D-2. Characteristic Hazardous Wastes
Ignitability
Corrosivity
Reactivity
Toxicity
Flashpoint below 140°F §261.21
Liquids with a pH equal to or below 2 or equal to or above 12.5 or which corrode steel at a specified
rate §261. 22
Reacts violently with water or other substances to create toxic gases§261.23
A waste that leaches specified amounts of metals, pesticides, or organic chemicals
Characteristic Leaching Procedure (TCLP) §261.24
using the Toxicity
Exhibit D-3. Listed Hazardous Wastes
"F" Wastes
"K" Wastes
"U" Wastes
"P" Wastes
Hazardous wastes from nonspecific sources §26 1.31
Hazardous wastes from specific sources §261.32
Hazardous wastes from discarded commercial chemical products, off-specification species, container
residues, and spill residues §261.34
Acutely hazardous wastes from discarded commercial chemical products, off-specification species,
container residues, and spill residues §26 1.33
If the waste is not found on any of these lists, it is not hazardous, although it may be listed on
a State hazardous waste list.
Secondary materials generated by organic chemical industries may be classified as solid wastes
and potentially hazardous wastes where they are recycled in certain ways (e.g., used in a
manner constituting disposal, burned for energy recovery, reclaimed, or accumulated
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-3
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speculatively). Such materials are considered accumulated speculatively where the material is
stored with less than 75 percent recycled within one calender year. Under 40 CFR
261(c)(8), persons accumulating secondary materials prior to recycling must be able to show
1) the material is potentially recyclable; 2) they have a feasible means of recycling such
material; and 3) during the calendar year the amount of material recycled or transferred to a
different site for recycling equals at least 75 percent by weight or volume of the amount of
material accumulated at the beginning of the period. The 75 percent requirement is to be
applied to each material of the same type that is recycled in the same way. Materials
accumulating in units exempt from regulation under § 261.4(c) are not included in making the
calculation. And commercial chemical products being speculatively accumulated are not
regulated as solid wastes.
Hazardous wastes that are recycled are subject to the requirements for generators,
transporters, and storage facilities as identified in 40 CFR §261.6(b) and (c), except as
excluded in 40 CFR §261.6(a)(3). In addition, §261.6(a)(2) identifies recycled materials that
are only subject to Parts 266 (recycling regulations), 270 (permits), and 124 (NPDES permits).
This includes recyclable materials such as those that are used in a manner constituting
disposal, hazardous wastes burned for energy recovery in boilers and industrial furnaces, and
used oil burned for energy recovery. Any facility that stores recyclable materials before they
are recycled, except those materials excluded in 40 CFR §261.6(a), must comply with
applicable storage requirements of 40 CFR Parts 264 and 265.
The regulations also establish requirements for residues of hazardous waste in empty
containers. Specifically, 40 CFR §261.7 establishes that empty containers and inner liners
from an empty container are not subject to the hazardous waste regulations, provided that all
wastes have been removed using the practices commonly employed to remove materials
from that type of container, no more than one inch of residue remains in the container or
inner liner, or no more than 3 percent by weight of the total capacity (or 0.3 percent for
larger containers) remains in the container or inner liner. Containers that have held
compressed gas are considered empty when the pressure approaches atmospheric. For
acute hazardous wastes, additional measures are required.
Generators of hazardous wastes are the first link in the cradle-to-grave chain of hazardous
waste management. Under RCRA, there are three categories of hazardous waste generators:
large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt
small quantity generators (CESQGs). The determination of a generator's applicable category
is summarized in Exhibit D-4.
CESQGs must only comply with the Part 262 generator regulations as established at 40 CFR
§261.5. Specifically, CESQGs must identify the waste to determine if it is a hazardous waste,
accumulate less than 1,000 kilograms of hazardous waste at any time, treat or dispose of the
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. TX4
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waste on-site, or ensure that the waste is sent to a permitted facility or a recycling facility.
The requirements CESQG are exempt from include, but are not limited to, the following:
* Manifest requirement
> Exception reportwhen generator does not receive a copy of the signed
manifest from the TSD facility
Biennial/annual report
Personnel training
Contingency plan
* EPA ID number
> Storage requirementsno need to meet technical requirements under part
264 or 265 for containers or tanks.
However, many transporters will not accept wastes from a generator without an EPA ID
number or manifest.
CESQGs that exceed the 100 kilograms per month hazardous waste generation cutoff are
subject to SQG provisions. CESQGs that exceed the 1 kilogram per month of acutely
hazardous waste generation cutoff are subject to the LQG provisions. Note that some States
do not have CESQG exemptions (i.e., all generators must meet the same requirements).
All SQGs and LQGs must comply with requirements as described in 40 CFR Part 262.
Standards for generators establish responsibilities including obtaining an EPA identification
number, preparing hazardous waste manifests, ensuring proper packaging and labeling,
meeting standards for waste accumulation units, and recordkeeping and reporting
requirements. This Part also identifies requirements for generators that are importing or
exporting hazardous wastes into or out of the country.
Generators can accumulate and store hazardous waste for up to 90 days (180 days for SQGs)
without obtaining a storage permit provided that the facility complies with specific conditions
in 40 CFR §262.34, including applicable management standards for containers, tanks, and drip
pads. Each accumulation container must include a "Hazardous Waste" label, identify the date
upon which accumulation began, and the facility must comply with 40 CFR Part 265, Subpart
C (Preparedness and Prevention). Additionally for LQGs, Subpart D (Contingency Plan and
Emergency Procedures), and with 40 CFR §265.16 (Personnel Training). SQGs have less
stringent requirements for accumulation than LQGs as identified in 40 CFR §262.34(d) and
(e).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. TX
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Exhibit D-4. Categories of Hazardous Waste Generators
KEY:
= 1 barrel = about 200 kilograms of hazardous
waste which is about 55 gallons
You ARE A LARGE QUANTITY GENERATOR IF ...
In one calendar month you ...
generate 2,200 pounds or more of hazardous waste or
generate 2,200 pounds or more of spill cleanup debris containing
hazardous waste or
generate more than 2.2 pounds of acutely hazardous waste or
generate more than 220 pounds of spill cleanup debris containing an
acutely hazardous waste or
At any time you ...
accumulate more than 2.2 pounds of acutely hazardous waste on-site
You ARE A SMALL QUANTITY GENERATOR IF ...
221 Ibs. -
2,199 Ibs.
In one calendar month you ...
generate more than 220 pounds and less than 2,200 pounds of hazardous
waste or
T*1 v-, * generate more than 220 pounds and less than 2,200 pounds of spill
', \ ^ cleanup debris containing hazardous waste or
i i -
i< ; i
|H... =''= v At any time you ...
^^H accumulate more than 2,200 pounds of acutely hazardous waste on-site
You ARE A CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR IF ...
In one calendar month you ...
generate 2.2 pounds or less of acutely hazardous waste or
-^-- * generate 220 pounds or less of hazardous waste or
*~ M~~ ^J * generate 220 pounds or less of spill cleanup debris containing hazardous
Ł s waste or
. -
220 Ibs. (. '| ]
At any time you ...
accumulate up to 2.2 pounds of hazardous waste on-site
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-6
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Hazardous Waste Transportation Regulations
Facilities that transport hazardous wastes off-site, where these wastes are required to be
manifested pursuant to 40 CFR Part 262, must comply with transporter requirements
established in 40 CFR Part 263. Hazardous waste transportation requirements, the middle
link in the "cradle-to-grave requirements of RCRA, require that the transporter obtain an EPA
identification number, and specify manifesting and recordkeeping requirements, including
specific conditions for shipment by rail or water. It is important to note that a transporter that
stores wastes at an off-site location for more than 10 days must comply with Parts 264, 265,
268, and 270 for storage of those wastes. Subpart C of Part 263 establishes response
requirements for discharges of hazardous wastes during transport.
Hazardous Waste Treatment, Storage, and Disposal Regulations
Any facility that treats, stores, or disposes of hazardous waste is considered to be an
owner/operator of a treatment, storage, or disposal (TSD) facility and is subject to
requirements identified in 40 CFR Parts 264 and 265. Treatment, storage, and disposal
facilities (TSDFs) are the last link in the cradle-to-grave regulation of RCRA. All TSDFs are
required to obtain an operating permit and abide by TSD regulations. The TSD regulations
establish design and operating criteria as well as performance standards that owners and
operators must meet to protect human health and the environment. Because TSDs involve
many different types of units, these regulations are far more extensive than those just
described for generators and transporters.
The RCRA TSD regulations include both administrative and technical requirements. The
regulations identify administrative requirements such as the applicability of the requirements,
general facility standards, preparedness and prevention, contingency plans and emergency
procedures, and manifesting, reporting, and recordkeeping. Technical requirements may
address ground water monitoring, closure/post-closure, financial requirements, and standards
related to the different types of waste management units. Specifically, the regulations identify
requirements for containers, tanks, surface impoundments, waste piles, land treatment,
landfills, incinerators, waste treatment, underground injection, and miscellaneous units. Also,
RCRA TSD regulations identify air emission requirements for process vents, equipment leaks,
and units that store hazardous wastes with high volatile organic concentrations from specific
operations related to the managing and recycling of hazardous waste.
EPA's hazardous waste permitting program is established at 40 CFR Part 270. New TSDFs
requiring a permit must submit a two part permit application. Part A is a short, standard form
that collects general information about the facility, while Part B of the application is much
more extensive and requires the facility to supply detailed and highly technical information.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. TX7
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This submission must be made at least 180 days prior to the date on which physical
construction is expected to start. Once issued, RCRA permits are valid for up to 10 years.
TSDFs fall into two categories: interim status facilities and permitted facilities. Interim status
regulations (40 CFR Part 265) apply to facilities that are operating under a Part A permit while
their Part B permit application is being reviewed. Any facility that is in existence on the
effective date of statutory or regulatory amendments under RCRA that render the facility
subject to permitting requirements shall have interim status, provided that the facility notifies
EPA of hazardous waste activity and complies with application requirements of 40 CFR
§270.10. Interim status standards are "good housekeeping" types of requirements that must
be addressed until a Part B permit is issued. TSDF permit standards (40 CFR Part 264) are
facility-specific performance standards and design and operating requirements that are
incorporated into a TSD permit. Permit writers use the standard permit language established
in 40 CFR Part 264 to set facility-specific conditions. TSD permits can be extremely complex
and may be several hundred pages in length. As such, an evaluation of specific permit
conditions must be made at chemical facilities operating under a RCRA TSD permit.
Land Disposal Restrictions
Under the Land Disposal Restriction (LDR) regulations (40 CFR Part 268), hazardous wastes
are largely prohibited from land disposal. Once prohibited, the statute provides two options:
comply with a specified treatment standard or dispose of the waste in a "no migration unit."
Land disposal includes any placement of hazardous waste into a landfill, land treatment unit,
waste pile, inject well, salt dome or salt bed formation, underground mine or cave or surface
impoundment. Restricted hazardous wastes may be land disposed only if certain treatment
standards are met or if waste extract or waste treatment residue concentrations are met, as
specified in 40 CFR §§268.41-43. Generators of wastes subject to the LDRs must provide
notification of such to the designated TSD facility to ensure proper treatment prior to
disposal. Facilities that generate less than 100 kilograms of non-acute hazardous waste or less
than one kilogram of acute hazardous waste per month are not subject to the LDRs. The
LDRs allow wastes which would otherwise be prohibited from land disposal to be treated in
surface impoundments, provided that specific conditions are met as outlined in 40 CFR
§268.4. Facilities may petition EPA for extensions to the LDRs in certain instances.
The Land Disposal Restrictions also specify that for certain characteristic wastes managed in
non-Clean Water Act (CWA) wastewater treatment systems, non-CWA equivalent systems
or non-Class I injection wells, the underlying hazardous constituents reasonably expected to
be present in the waste at the point of generation should be treated as well as the hazardous
characteristic. For wastes that are characteristic for organics (i.e., D018-D043), this
requirement applies to both wastewaters and non-wastewaters. Underlying hazardous
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. TX8
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constituents include all those constituents listed in 40 CFR 268.48 (Universal Treatment
Standards).
The LDRs prohibit the use of dilution as a substitute for treatment to meet the LDRs with one
exception. Wastes that are hazardous only because they exhibit a characteristic in a treatment
system which treats wastes and subsequently discharges these wastes pursuant to a CWA
permit are exempt from LDRs. Exhibit D-5 provides a decision tree for making the
determination as to whether dilution of a waste is permissible. Storage of hazardous wastes
restricted from land disposal under Part 268 Subpart C is prohibited, unless certain conditions
are met as identified in 40 CFR §268.50.
Underground Storage Tank Regulations
Underground storage tanks (USTs) containing petroleum and hazardous chemicals are
regulated under 40 CFR Part 280. Federal, state, and local agencies are or may be involved
in regulating USTs. The statute provides EPA with the authority to develop and enforce the
UST program, but states have discretionary authority to develop their own UST regulatory
program as long as the program is no less stringent than the Federal program. Local agencies
may also implement UST provisions through local ordinances.
An underground storage tank is one that stores "regulated substances" and that has at least 10
percent of its volume below the surface of the ground, including piping connected to the tank.
Regulated substances include hazardous chemical products regulated under CERCLA (above
de minimis concentrations) and any petroleum products that are liquid at standard conditions.
Regulated substances do not include hazardous wastes. As identified in 40 CFR
§280.10(b)(l), underground tanks containing hazardous waste are not subject to 40 CFR Part
280 requirements. Rather, underground tanks containing hazardous wastes are subject to
RCRA requirements, as appropriate.
Exclusions to the UST regulations include tanks such as for heating oil used primarily for space
heating on the premises where the tank is stored, flow-through process tanks, any
wastewater treatment tank system regulated under the CWA, tanks less than 110 gallons in
capacity, spill or overflow containment systems that are expeditiously emptied after use,
storm water and wastewater collection systems, and tanks situated on or above the floor of
underground areas such as basements, shafts, and tunnels.
The regulations at 40 CFR Part 280 include conditions for design, construction, operation,
installation, and notification; general operating requirements; release detection; release
response, investigation, and confirmation; release reporting and corrective action; out-of-
service UST systems and closures; and financial responsibility.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. TXQ
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Exhibit D-5. LDR Dilution Decision Tree
1
Dilution is
prohibited
"Toxic only includes: D001 (high
TOC NWW), D003 (cyanides and
sulfides), D004-17
Note: Dilution prohibition does not
apply to wastes with national
capacity extension or to wastes
going to no migration units
The UST program requires that by December 22, 1998, all existing USTs must add spill,
overfill, and corrosion protection; close the existing UST; or replace the existing UST with a
new UST. Spill protection is defined as installation of catchment basins to contain spills from
delivery hoses. Overfill protection requires either an automatic shutoff valve, overfill alarms,
or ball float valves. Corrosion protection requires that existing tanks match one of the
following tank conditions and one of the piping conditions:
Tanks
Steel tank has corrosion-resistant coating AND cathodic protection
Tank made of noncorrodible material
Steel tank clad with noncorrodible material or tank enclosed in
noncorrodible material
Uncoated steel tank has cathodic protection system
Uncoated steel tank has interior lined with noncorrodible material
Uncoated steel tank has cathodic protection AND interior lined with
noncorrodible material
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-10
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* Piping
Uncoated steel piping has cathodic protection
Steel piping has a corrosion-resistant coating AND cathodic protection
Piping made of (or enclosed in) noncorrodible material.
New USTs must have a suitable dielectric coating in addition to cathodic protection. Also,
new USTs must be installed in accordance with a code of practice and in accordance with the
manufacturer's instructions. Installation of new USTs must also be certified. Any facility which
brings an UST into use after May 8, 1986, must submit the Notification Form prescribed in
Appendix I of Part 280 (or a comparable state form) within 30 days of bringing the UST into
use. This form must be submitted to the state or local agency or department designated in
Appendix II of Part 2 80.
RCRA Assessment Considerations
Similar to the facility assessment elements discussed in the Overview, the key components of
a RCRA assessment are knowledge of the facility, a document review, and an assessment
plan.
A RCRA self-assessment requires familiarity with what hazardous wastes are generated at the
chemical facility and how these wastes are managed. Chemical facilities' operations can be
exceedingly complex and varied, so a knowledge of each operation is necessary.
One source of information for determining compliance with RCRA requirements is a
document review. Useful documents to review include facility maps and blueprints; aerial
photographs; plant organization charts; piping and instrumentation diagrams (P&IDs);
operating or procedure manuals; information about emission points, waste streams, or
monitoring results; the daily operating log; company spill reports; permit applications; TRI
reports; annual/biannual operating reports; and documents prepared for environmental
activities such as siting a facility or remedial activity.
Before conducting an assessment, the assessor should draw up a Plan that traces material
flows through the plant. The Plan should indicate whether samples will be necessary to
determine if a particular waste stream is hazardous or if a release of hazardous material has
occurred. In addition, appropriate reports should be prepared as required, for example,
Quality Assurance/Quality Compliance Plans. Also, the Plan should reflect any special
considerations set forth in the facility permit or any consent decree or agency findings and
orders.
EPA has published various RCRA Inspection Checklists which are useful as guidance and as a
framework for a Plan. For example, checklists are available that list requirements from RCRA
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. D-1 1
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regulations for generators of hazardous waste, closure and post-closure plans and
requirements, and land disposal requirements for generators.
Assessing compliance with RCRA paperwork and administrative requirements is as important
as assessing compliance with waste management requirements. Administrative and
paperwork requirements include keeping a daily log of facility operations, submitting an
annual/biannual operating report to the regulatory agency, manifest requirements, waste
analysis plans, certifications, having a contingency plan on file and procedures in place to
implement the plan, conducting an adequate training program, and implementing adequate
plant security.
During the actual assessment, the evaluation team should sit down with plant operations
personnel and discuss plant organization and site operations, identifying and verifying major
facility processes, preparedness and prevention measures, safety procedures that are
observed and that need to be observed during the visual inspection, descriptions and
locations of special equipment, and training programs.
RCRA Regulatory Requirements
The following sections provide summaries of the principal regulations developed pursuant to
RCRA that may apply to that organic chemical industry. The section includes:
40 CFR §§261.5 and 262.34 - Generator Classifications and Requirements
40 CFR Part 262 - Hazardous Waste Generator Requirements
40 CFR Part 263 - Hazardous Waste Transporter Requirements
40 CFR Part 264 and 265 - Hazardous Waste Treatment Storage and Disposal
40 CFR Part 268 - Land Disposal Restrictions
40 CFR Part 280 - Underground Storage Tanks (UST)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F)-1 ?
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40 CFR Part 261.5 and 262.34
Generator Classifications and Requirements
Conditionally Exempt Small Quantity Generators (CESQG)
REQUIREMENTS
AFFECTED FACILITY
Make hazardous waste determination under
§262.11
Waste must be managed and disposed in a
hazardous waste facility, or a landfull or other
facility approved by the State for industrial or
municipal wastes
Must comply with §261.5(g) to be excluded
from requirements under parts 262 through
266, 268, and 270.
Generate less than 100 kg/month (220
Ibs/month) of hazardous waste, or
Generate less than 1 kg/month (2.2
Ibs/month) of acute hazardous waste, or
Accumulate up to 1,000 kg (2,200 Ibs) of
hazardous waste onsite at any time
Small Quantity Generator (SQG)
REQUIREMENTS
AFFECTED FACILITY
00
Subject to regulation under parts 262
through 266, 268, and 270.
Special requirements under §265.201 for
accumulating hazardous waste in tanks.
May not accumulate more than 6,000 kg of
hazardous waste at any time.
May not accumulate hazardous waste onsite
for longer than 180 days (270 days if waste
must be transported over 200 miles to
hazardous waste facility), otherwise
hazardous waste storage permit required.
Generate more than 100 kg/month (220
Ibs/month) of hazardous waste and less than
1,000 kg/month (2,200 Ibs/month) of
hazardous waste, or
Accumulate more than 1,000 kg (2,200 Ibs),
but less than 6,000 kg of hazardous waste at
any time
^i
CO
CS
Large Quantity Generator (LQG)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-13
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REQUIREMENTS
AFFECTED FACILITY
Subject to regulation under parts 262
through 266, 268, and 270.
May not store hazardous waste onsite for
more than 90 days, otherwise hazardous
waste storage permit required.
Generate more than 1,000 kg/month (2,200
Ibs/month) of hazardous waste, or
Generate more than 1 kg/month (2.2
Ibs/month) of acutely hazardous waste, or
Generate more than 100 kg/month (220
Ibs/month) of spill cleanup debris containing
an acutely hazardous waste, or
Accumulate more than 1kg (2.2 Ibs) of
acutely hazardous waste at any time
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-14
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40 CFR Part 262
Hazardous Waste Generator Requirements
40 CFR PART 262 - HAZARDOUS WASTE GENERATOR REQUIREMENTS
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
EPA ID Number §262.12
Subpart B - Manifest
Requirements §§262.20-
260.33
Subpart C - Pre-transport
Requirements §§262.30-
262.34
Cannot treat, store dispose of,
or transport hazardous waste
without EPA ID Number
Cannot offer hazardous waste
to transporter or to
treatment, storage, or
disposal facilities that do not
have an EPA ID Number
Must complete and sign EPA
form 8700-22 or 8700-22A
for each shipment of
hazardous waste
Must label and package
hazardous waste in
accordance with DOT
regulations (49 CFR parts
172, 173, 178, 179) prior to
transport
Accumulation in units that
comply with Subpart I of 40
CFR 265 (containers), or
Subpart J of 40 CFR part 265
(tanks)
LQG or SQG that transports, or
offers for transportation,
hazardous waste for offsite
treatment, storage or disposal
SQGs allowed up to 180 (or
270) days for accumulating
hazardous waste without a
storage permit
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-15
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40 CFR PART 262 - HAZARDOUS WASTE GENERATOR REQUIREMENTS
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
Subpart D - Record keeping
and Reporting §§262.40-
262.44
Subpart E - Exports of
Hazardous Waste §§262.50-
262.57
Accumulation in units that
comply with air emission
standards identified in 40 CFR
265 Subparts AA (process
vents), BB (equipment leaks)
and CC (tanks, surface
impoundments and
containers) and with Subpart
DD (containment buildings)
May accumulate wastes up to
90 days without storage
permit
Must develop and maintain a
contingency plan for storing
wastes on-site
Maintain copies of manifest
for three years
Must prepare and submit
Biennial Report
Must file exception report if
manifests not received by
designated facility within 35
days (LQG) or 60 days
(SQG)
Notify EPA 60 days before
shipment
Must confirm waste receipts
or file an exception report
Must file a Summary Report
of Foreign Activity on March 1
of each year
SQG exempt from biennial
reporting requirements
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-16
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40 CFR PART 262 - HAZARDOUS WASTE GENERATOR REQUIREMENTS
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
Subpart F - Imports of
Hazardous Waste §262.60
Must prepare manifest that
identifies foreign generator
and importer
Must comply with all other
generator standards in 40
CFR Part 262
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-17
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p, i o
-------
40 CFR Part 263
Hazardous Waste Transporter Requirements
40 CFR PART 263 - HAZARDOUS WASTE TRANSPORTER REQUIREMENTS
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
EPA ID Number §263.11
Transfer Facility Requirements
§263.12
Manifest and Record Keeping
Requirements §263.20
Hazardous Waste Discharges
§263.30
Must obtain an EPA ID
Number in order to
transport hazardous waste
May store manifested
shipments for ten days or
less, otherwise subject to
hazardous waste storage
requirements under parts
264, 265, 268, and 270
Cannot receive a waste
shipment unless
accompanied by a
hazardous waste manifest
Take appropriate action
Notify proper authorities
Persons who transport
hazardous waste within the
U.S. if manifest is required
under 40 CFR §262.
00
i
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-19
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p, on
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40 CFR Part 264 and 265
Hazardous Waste Treatment, Storage, and
Disposal
40 CFR PART 264 - FACILITY REQUIREMENTS
(PART 265 INTERIM STATUS STANDARDS ARE SIMILAR BUT NOT IDENTICAL)
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
General Facility Requirements
(Subpart B) Identification
Number §264.11
Required Notices §264.12
General Facility Management
Plans §§264.13-264.19
Must obtain an EPA ID Number in
order to treat, store, or dispose of
hazardous waste
Must notify Regional Administrator
of receipt of a hazardous waste
from foreign source
Must notify generator that the
facility receiving the waste has the
proper permits
General Waste Analysis §264.13
Security §264.14
General Inspection Requirements
§264.15
Personnel Training §264.16
General Requirements for I, C, R
wastes §264.17
Location Standards §264.18
Construction Quality Assurance
Program §264.19
Facilities that treat, store
or dispose of hazardous
waste
CO
5=1
CO
CM
^h
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-21
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40 CFR PART 264 - FACILITY REQUIREMENTS
(PART 265 INTERIM STATUS STANDARDS ARE SIMILAR BUT NOT IDENTICAL)
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
Preparedness and Prevention
(Subpart C)
Contingency Plan and
Emergency Procedures
(Subpart D)
Manifest System, Record
keeping/Reporting (Subpart E)
Releases from Solid Waste
Management Units (Subpart F)
Must be equipped with
communications and alarm
systems, fire control equipment,
spill control equipment,
decontamination equipment,
adequate water supply and
distribution system
Must make arrangements with
local authorities for the event of an
emergency
Must develop and follow written
contingency plan to minimize
hazardous from fires, explosions
and releases
Must maintain a written operating
record
Must comply with hazardous
waste manifest requirements
Must submit a biennial report
Must submit Unmanifested Waste
Report within 15 days of receiving
hazardous waste without an
accompanying manifest
Must implement a groundwater
program capable of determining
the facility's impact on ground-
water quality
Groundwater monitoring system
Develop and follow a ground-
water sampling and analysis plan
Owner/operator of a
surface impoundment,
landfull or land
treatment facility used to
manage hazardous
waste
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-22
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40 CFR PART 264 - FACILITY REQUIREMENTS
(PART 265 INTERIM STATUS STANDARDS ARE SIMILAR BUT NOT IDENTICAL)
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
Closure and Post-Closure
(Subpart G)
Financial Requirements
(Subpart H)
Must develop and submit a
written closure plan as part of the
permit application under 40 CFR
Part 270
Must have detailed written
estimate of the cost of closing the
facility under the closure plan
Must establish financial assurance
by selecting appropriate options
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-23
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F) ?4
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40 CFR Part 264 and 265
Hazardous Waste Treatment, Storage and
Disposal - Unit Specific Standards
40 CFR PART 264 AND 265 UNIT SPECIFIC STANDARDS
REQUIREMENTS
AFFECTED FACILITY
Containers (Subpart I)
Tank Systems (Subpart J)
Surface Impoundments
(Subpart K)
Waste Piles (Subpart L)
Land Treatment (Subpart M)
Landfills (Subpart N)
Incinerators (Subpart O)
Drip Pads (Subpart W)
Miscellaneous (Subpart X)
Air Emission Standards for
Process Vents (Subpart AA)
Air Emission Standards for
Equipment Leaks (Subpart BB)
Facilities that treat, store, or dispose of hazardous wastes in
containers
Facilities that treat, store or dispose of hazardous wastes in tanks
Facilities that treat, store, or dispose of hazardous wastes in
surface impoundments
Facilities that treat, store, or dispose of hazardous wastes in piles
Facilities that treat or dispose of hazardous wastes in land
treatment units
Facilities that dispose of hazardous waste in landfills
Facilities that treat or dispose of hazardous wastes in incinerators
Facilities that treat, store, or dispose of hazardous waste on drip
pads.
Facilities that treat, store or dispose of hazardous wastes in units
not identified in 40 CFR Parts 264/265
Facilities subject to RCRA permitting that have distillation,
fractionation, thin-film evaporation, solvent extraction, or
air/stream stripping operations that manage wastes with organic
concentrations of at least 10 ppmw. (See §264.1030)
Facilities with equipment, regardless of process, that manage
hazardous wastes in units which are subject to permitting under
40 CFR Part 270 and recycling units located at facilities subject to
permitting. (See §264.1050).
Units that manage less than ten percent organics by weight
require only record keeping.
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a
10
CO
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-25
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40 CFR PART 264 AND 265 UNIT SPECIFIC STANDARDS
REQUIREMENTS
AFFECTED FACILITY
Air Emissions Standards for
Tanks, Surface Impoundments,
and Containers (Subpart CC)
Containment Buildings
(Subpart DD)
Facilities that treat, store, or dispose of hazardous waste in tanks,
surface impoundments, or containers subject to subparts J, K, or I,
respectively.
Certain units may not be subject to subpart CC if criteria under
§§264.1080 and 264.1082 re met.
Facilities that treat or store hazardous wastes in containment
buildings are required to meet certain design and operating
standards.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-26
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40 CFR Part 268
Land Disposal Restrictions - Certification and
Notification
40 CFR PART 268 - GENERATOR - CERTIFICATION AND NOTIFICATION
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
Waste Analysis and Record
keeping for Generators
§268.7(a)
Must determine if waste is
restricted from land disposal
If waste does not meet
treatment standards in §268
Subpart D, must notify
treatment or storage facility
receiving waste
If waste meets treatment
standards §268 Subpart D,
must submit notification,
certification, and supporting
information to treatment,
storage, or disposal facility
receiving the waste
If accumulating and treating
restricted wastes onsite,
must develop waste analysis
plan and file with
Administrator or authorized
State
Maintain copies of records,
certifications, and notices for
five years
LQGs and SQGs
00
CO
^h
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-27
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40 CFR 268 - TREATMENT AND DISPOSAL - CERTIFICATION AND NOTIFICATION
REQUIREMENTS
DESCRIPTION
AFFECTED FACILITY
Waste Analysis and Record
Keeping for Treatment
Facilities §268.7(b)
Waste Analysis and Record
Keeping for Disposal Facilities
§268.7(c)
Must test waste in
accordance with waste
analysis plan
Must submit notification and
certification to land disposal
facility receiving the waste
Must maintain copies of all
notices and certifications
specified in §268.7(a) and
(b)
Must test waste in
accordance with waste
analysis plan to determine if
the treatment standards
have been met
Facilities that treat hazardous
wastes subject to LDRs
Disposal facilities
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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40 CFR Part 280
Underground Storage Tanks (UST)
40 CFR PART 280 - UNDERGROUND STORAGE TANK REQUIREMENTS
REQUIREMENTS
DESCRIPTION
AFFECTED
FACILITY
Design,
Construction,
Installation, and
Notification (Subpart
B)
General Operating
Requirements
(Subpart C)
Release Detection
(Subpart D)
New USTs (installed after December 1988)
must meet performance standards detailed in
40 CFR §280.20
All existing UST systems (installed before
December 1988) must be upgraded to meet
standards detailed in 40 CFR §280.21 by
December 1998
Notify State and/or local agencies upon the
Installation and use of new UST systems (40
CFR §280.22)
Must ensure the prevention of releases through
spill and overfill control, proper corrosion
protection, use of compatible materials, and
proper and appropriate repairs to the UST
system
Reporting requirements include notification,
reports of all releases (suspected and
confirmed), corrective action, and permanent
change ins service or closure.
Record keeping requirements include
documentation of corrosion controls, UST
system repairs, release detection compliance
Must provide a method or combination of
methods to detect leaks and releases from the
UST system
Must comply with release detection
requirements according to the schedule set
forth in 40 CFR §280.40(c)
All owners and
operators of
underground storage
tank systems as
defined in 40 CFR
§280.12 (See
§280.10(b-d)for
exceptions)
00
^h
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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40 CFR PART 280 - UNDERGROUND STORAGE TANK REQUIREMENTS
REQUIREMENTS
DESCRIPTION
AFFECTED
FACILITY
Release Reporting,
Investigation, and
Confirmation
(Subpart E)
Release Response
and Corrective
Action for UST
Systems Containing
Petroleum or
Hazardous
Substances (Subpart
F)
Out-of-Service UST
Systems and
Closure (Subpart G)
Petroleum USTs must comply with release
detection requirements under 40 CFR §280.41
Hazardous substance USTs must comply with
release detection requirements under 40 CFR
§280.42
Must maintain records demonstrating
compliance with release detection requirements
Must report any suspected releases within 24
hours or another reasonable time period
specified by implementing agency
Must investigate and confirm any suspected
releases
Must contain and cleanup any release, and
report to implementing agency
In the event of a release
Must notify implementing agency upon
confirmation of a release and take action to
prevent additional release
Must submit report to implementing agency that
summarizes initial abatement activities within 20
days
Must submit site characterization report
Must develop and implement a corrective
action plan as directed by implementing agency
For temporary closure, must maintain operating
practices to ensure prevention of releases
Must notify within 30 days of permanent closure
Must maintain records to demonstrate
compliance with closure requirements in
accordance with §280.34
UST systems that
manage petroleum
or hazardous
substances.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-30
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40 CFR PART 280 - UNDERGROUND STORAGE TANK REQUIREMENTS
REQUIREMENTS
Financial
Responsibility
(Subpart H)
DESCRIPTION
Must demonstrate financial responsibility for
taking corrective action and for compensating
third parties for bodily injury and property
damage caused by accidental releases
AFFECTED
FACILITY
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D-31
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F)
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Appendix E Emergency
Planning and Community
Right-to-Know Act (EPCRA)
The Emergency Planning and Community Right-To-Know Act (EPCRA), also known as
Superfund Amendments Reauthorization Act (SARA) Title III, is designed to provide the
general public and emergency planning and response personnel with information regarding
the potential hazards in their community. EPCRA regulations identify emergency planning and
notification procedures for hazardous chemicals in the community. Pursuant to EPCRA, EPA
implements and enforces four regulatory programs applicable to chemical facilities. These
programs are described below. The detailed requirements included in the applicable
regulations are presented later in this appendix.
Hazardous Substance Notification
Pursuant to 40 CFR §302.6, facilities that release a hazardous substance in a quantity equal to
or exceeding the reportable quantity (RQ) established in 40 CFR §302.4 must immediately
notify the National Response Center at (800) 424-8802 and in the Washington, D.C. area at
(202) 426-2675. Depending on the hazardous substance, the RQ ranges from 1 to 5,000
pounds. For this regulation, "release" means any spilling, leaking, pumping, emitting,
emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the
environment, but excludes any release that results in exposure to persons solely within a
workplace. Reporting procedures are similar to those required under 40 CFR Part 117
(FWPCA) (see Appendix F), but specify a different list of hazardous substances.
Emergency Planning and Notification
Pursuant to 40 CFR Part 355,
any facility at which there is
present an amount of any
extremely hazardous
substance, as defined in 40
CFR Part 355, equal to or in
excess of its threshold planning
quantity, shall notify the
Commission (i.e., the State
Emergency Planning and Community Right-to-Know Act
Hazardous Substance Notification E-l
Emergency Planning and Notification E-l
Hazardous Chemical Reporting: Community Right-to-Know .... E-2
Toxic Chemical Release Inventory E-2
EPCRA Assessment Considerations E-3
EPCRA Regulatory Requirements E-4
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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emergency response commission (SERC) or the Governor if there is no commission) and the
local emergency planning committee (LEPC) identified in 40 CFR §355.30. Any facility
producing, using, or storing a hazardous chemical, as defined in 40 CFR §355.20, that
releases an RQ of an extremely hazardous substance or a CERCLA hazardous substance must
immediately notify the local emergency planning committee and the State emergency planning
commission as specified in 40 CFR §355.40.
Hazardous Chemical Reporting: Community Right-To-Know
As required in 40 CFR Part 370, chemical facilities are required to submit a Material Safety
Data Sheet (MSDS), as required in 29 CFR §1910.1200(c), or a list of hazardous chemicals
for which MSDSs are required (i.e., a minimum threshold of zero pounds), for each
hazardous chemical used as defined in 40 CFR §370.2 to the SERC, LEPC, and the fire
department.
All chemical facilities must also submit a Tier I or Tier II Form, as identified in 40 CFR
§§370.40 and 41, for all hazardous chemicals (above a threshold of 500 pounds) and all
extremely hazardous chemicals (above a threshold of zero pounds) indicating the aggregate
amount of these chemicals at their facilities classified by hazard category. All facilities must
submit a Tier I form (Aggregate Information by Hazard Type). If any agency requests a Tier II
report (Specific Information by Chemical), the chemical facility is required to submit this
information within 30 days of the request. Any facility may submit a Tier II form in lieu of a
Tier I form.
Information required in 40 CFR Part 372 must be submitted to the SERC, LEPC, and the fire
department.
Toxic Chemical Release Inventory
Section 313 of EPCRA requires submission of the Toxic Chemical Release Inventory (TRI)
Reporting Form (the Form R) as required in 40 CFR Part 372. Form R provides EPA with a
compilation of release information that supports future regulations and also provides the
public with information on releases of toxic chemicals in the community. Facilities subject to
the requirement must report the quantities of both routine and accidental releases of listed
toxic chemicals (40 CFR §372.65), the maximum amount of the listed toxic chemicals onsite
during the calendar year, and the amount contained in wastes transferred offsite.
A complete Form R is required annually for each toxic chemical manufactured, processed, or
otherwise used at each covered facility as described in 40 CFR Part 372. The form must be
filed on or before July 1 of the following year and submitted both to EPA and the State.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. -co
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Included in the Form R reporting requirements are air releases that are not released through
any point source (stocks, vents, ducts, pipes, or any other combined air stream). These
releases include (1) fugitive equipment leaks from valves, pump seals, flanges, compressors,
sampling connections, etc., (2) evaporative losses from surface impoundments and spills; (3)
releases from building ventilation systems; and (4) any other fugitive or non-point air
emissions. Engineering estimates and mass balance equations may be useful in estimating
these fugitive emissions.
Chemical manufacturing facilities that have 10 or more employees are required to submit a
form for any Section 313 listed toxic chemical that is manufactured or processed at the facility
in excess of a 25,000 pound threshold during the course of a calendar year or is a listed toxic
chemical that is otherwise used at the facility in excess of a 10,000 pound threshold during the
course of the year. (Toxic chemicals contained in mixtures and trade name products must
also be accounted for when making threshold and release determinations.) The facility should
use the best information available to determine chemical quantities. Section 313 listed toxic
chemicals do not have to be considered if they are present in a mixture at less than a de
minimis total of 1.0 percent, or 0.1 percent combined for toxic chemicals meeting the OSHA
carcinogen standard. Uses that are exempt from reporting requirements include, among
others, use of toxic chemicals contained in intake water (used for processing or non-contact
cooling) or in intake air (used either as compressed air or for combustion).
A supplier notification requirement exists at 40 CFR Part 372, Subpart C for facilities that
manufacture, import, or process a listed toxic chemical, and then sell or otherwise distribute a
mixture or trade name product containing the toxic chemical above de minimis levels to
either another manufacturing facility or another facility that then sells the same mixture or
trade name product to another manufacturing facility. Supplier notification is also required if a
waste mixture containing a toxic chemical is sold to a recycling or recovery facility. This
notification must be made to each customer with the first shipment of each calendar year.
Records of notifications must be kept for at least 3 years.
An alternative threshold of one million pounds per year applies to facilities that calculate the
annual reportable amount of a toxic chemical to be less than 500 pounds for the combined
total of quantities released, disposed, treated, recovered, combusted, and transferred.
Facilities meeting these alternative reporting thresholds are not required to submit Form R for
these chemicals. Rather, the regulations at 40 CFR §372.95 identify certification procedures
that are to be followed.
EPCRA Assessment Considerations
When attempting to determine compliance with EPCRA at a chemical facility, activities will
focus primarily on reporting and recordkeeping. The Form R is the highest profile reporting
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p_o
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requirement under EPCRA. If the chemical facility meets the requirements set out above for
reporting, it must submit a Form R annually for every chemical it has on site in excess of the
threshold amounts. The Form R does not require specific studies or analyses, the information
submitted may be based on existing information and on estimates. However, EPA does
consider data quality when reviewing the Form R and will question numbers and data that do
not appear to be reasonable.
The facility should pay particular attention to intermediate products it manufactures and then
uses in different products; it should also identify any chemicals it uses in waste treatment. The
facility is required to submit a Form R both for intermediates and treatment chemicals. A
facility should also be mindful of areas that are likely to have unreported spills, such as raw
materials handling areas, pumps, and pipe fittings and connections. In addition, a facility
should identify if (and where) volatile organic chemicals are used. VOC emissions in an open
area to the atmosphere do constitute a regulated release under EPCRA. These emissions
must be reported on the Form R.
EPCRA Regulatory Requirements
The following sections provide a summary of the principal regulations developed pursuant to
EPCRA that may apply to the organic chemical industry. The regulations included are:
* 40 CFR Part 302 - Designation, Reportable Quantities and Notification
* 40 CFR Part 355 - Emergency Planning and Notification
* 40 CFR Part 370 - Hazardous Chemical Reporting: Community Right-to-Know
* 40 CFR Part 372 - Toxic Chemical Release Reporting, Community Right-to-
Know
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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40 CFR Part 302
Designation, Reportable Quantities, and
Notification
Designation of Hazardous Substances, §302.4
REQUIREMENTS
REGULATORY THRESHOLD
Under Section 102 (a) of CERCLA, these
regulations identify reportable quantities of
hazardous substances and set forth reporting
requirements of releases.
Listed hazardous substances are in Table
§302.4 and are designated as "hazardous under
Section 102 (a) of CERCLA." Also included are
"unlisted" hazardous substances which are
defined in 40 CFR 302.4(b) as characteristics of
hazardous waste.
The Table includes the reportable quantities of
these substances. Unlisted hazardous
substances have reportable quantity limit of 100
pounds (§302.5), except for unlisted hazardous
wastes that exhibit extraction procedure (EP)
toxiciry as identified in Part 261 which vary
based on the reportable quantity of the
pollutant of concern and its lowest value in
Table §302.4. Appendix A of §302.4 contains a
sequential CAS number listing of chemicals and
Appendix B contains a listing of regulated
radionuclides.
Notification Requirements, §302.6
REQUIREMENTS
REGULATORY THRESHOLD
Facilities which release reportable quantities
established in Table §302.4 must immediately
notify the National Response Center at (800)
424-8802 or in the Washington D.C. area at
(202) 426-2675.
Table §302.4 is used to determine whether the
regulations apply to a specific facility based on
chemicals that are released.
Exposure to persons within a workplace is
excluded. Reportable quantities range from 1
to 5,000 pounds. Release means any spill, leak,
pumping, emitting, emptying, discharging,
injecting, escaping, leaching, dumping, or
disposing into the environment. Specific
requirements for various types of radionuclides,
including those which are exempt from
reporting to the National Response Center are
given in §302.6.
00
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p r.
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40 CFR Part 355
Emergency Planning and Notification
Emergency Planning, §355.30
REQUIREMENTS
REGULATORY THRESHOLD
Facilities subject to emergency planning
requirements must notify the local and State
emergency planning commissions. They must
designate an emergency planning coordinator,
provide information to the local planning
committee, and calculate Threshold Planning
Quantities [§355.30(e)] for substances listed in
Appendices A and B of §355.
§355.30(b) notification of planning
commission due May 17, 1987, or within 60
days of becoming subject to the planning
requirements;
§355.30Š facility emergency coordinator
designated due September 17, 1987, or 30
days after establishing a local emergency
planning committee;
§355.30(d) information for planning must be
provided "promptly" upon request.
The facility has onsite an extremely hazardous
substance equal to or greater than its threshold
planning quantity.
10
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Emergency Release Notification, §355.40
REQUIREMENTS
REGULATORY THRESHOLD
A facility must immediately notify the local
community emergency coordinator (or
emergency response personnel) and State
coordinator any time a release will likely affect
an area/state. Notice must include chemical
name or identity of any substance released,
indication of whether it is an extremely
hazardous substance, estimate of quantity
released, estimate of time and duration of
release, media into which release occurred,
known or expected acute or chronic health risks
including medical advice for exposed individuals,
precautions to be taken, contact/phone
numbers for further information.
A written follow up emergency notice must be
provided to update the information about the
release, and actions taken. For transportation-
related releases, this information can be
provided to the 911 operator.
The facility produces, uses, or stores a
hazardous chemical and there is a release of a
reportable quantity of any extremely hazardous
substance or CERCLA hazardous substance.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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40 CFR Part 370
Hazardous Chemical Reporting: Community
Right-to-Know (EPCRA)
General Applicability:
Any facility that is required to
prepare or have available an
MSDS for a hazardous chemical
under OSHA (1970).
Reporting Requirements, §370.20
This part applies to any amount of onsite hazardous chemicals greater than or equal to 10,000
Ib and for all extremely hazardous substances present in an amount greater than or equal to
500 pounds, or the Threshold Planning Quantity (TPQ), whichever is less. Applicable facilities
must submit Tier I forms by March 1 , 1991 , and annually thereafter. If requested, they must
also submit Tier II forms.
MSDS Reporting. §370. 21
Applicable facilities must submit to the local emergency planning committee, state emergency
response commission and the local fire department (1) MSDSs for the facility for hazardous
chemicals as required in §370.20; or (2) similar information including a list of hazardous
chemicals by hazard category, the chemical or common name and components.
Reporting Upon Request, §370.21(d)
An MSDS must be provided for any changed chemicals within 3 months of the change.
Inventory Reporting, §370.25
The owner or operator must provide an inventory form to the emergency planning
commission, the committee and the fire department with jurisdiction over the facility. It
should contain Tier I information on hazardous chemicals present at the facility during the
preceding calendar year above the threshold levels in §370.20(b). It must be submitted
before March 1 each year. Tier II information may be submitted as an alternative per
§370.25(b).
Submission of Tier II Information, §370.25Š
Upon request by the committee, the facility must submit Tier II information.
This manual is intended solely for guidance. No statutory or regulatory >P
requirements are in any way altered by any statements) contained herein. p q
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Fire Department Inspection, §370.25(d)
The facility must allow the fire department to conduct inspections and must provide specific
information on locations of chemicals upon request.
Mixtures. §370.28
The facility must report on mixtures and quantify its mixtures using procedures in §370.28.
Public Access and Availability of Information (Subpart C), §370.30
The committee must provide any person with MSDS or Tier II information for a specific
facility, except upon request by the facility owner or operator, the commission or committee
can withhold information on the locations of chemicals identified on Tier II forms.
Inventory Forms, Tier I and Tier II (Subpart D), §370.40
The forms contain information on hazardous and extremely hazardous chemicals onsite at the
facility.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i n
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40 CFR Part 372
Toxic Chemical Release Reporting,
Community Right-to-Know
Reporting Requirements, Subpart B
REQUIREMENTS
AFFECTED FACILITY
This section of the regulations sets forth
requirements for the submission of information
relating to the release of toxic chemicals under
§313 of EPCRA yearly on July 1. Date of
applicability: February 16, 1988.
Section §372.22 specifies the types of facilities
that are subject to the Form R reporting
requirements:
a) facilities with 10 or more full time employees;
b) facilities in SIC codes 20-39 (as of January 1,
1987). Criteria for the determination of SIC are
further explained in Section §372.22(b); and
(c) facilities which process, manufacture, or use
a toxic chemical in excess of the threshold
quantity set forth for the chemical in §§372.25
or 372.27.
Exemptions to the reporting of releases of toxic
chemicals are detailed in §372.38 (e.g., de
minimis concentrations, toxic chemicals
contained in articles, structural components,
routine janitorial uses, personal use by
employees, maintaining motor vehicles,
chemicals in process water or noncontact
cooling water, and laboratory activities).
Owners of industrial parks or similar real estate
owners are also exempt since the operators of
the facilities would hold this responsibility.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Record Keeping, §372.10
REQUIREMENTS
REGULATORY THRESHOLD
Facilities must retain copies of reports, supporting
documentation, including such items as data to show
how reportable quantities were determined, data to
calculate the quantity of a release, documentation of
offsite transfer or release of toxic chemicals, and
manifests or records for offsite transfer for a period of 3
years after each report is made. The reports must be
available for inspection by EPA.
All facilities subject to any reporting
requirements in Part 372.
Threshold in §372.25(a) applies to
chemicals manufactured, imported or
processed at a facility. The threshold is
25,000 Ib/yr for chemicals manufactured
or processed and 10,000 Ib/yr for
chemicals used.
Reporting Requirements and Schedule for Reporting, §372.30
REQUIREMENTS
REGULATORY THRESHOLD
EPA Form 9350-1 (i.e. EPA Form R) is to be used to
report chemicals above thresholds for manufactured,
imported, processed, used or combined into a mixture
or trade name product. Details on characterizing
mixtures and trade name products are given in
§372.30(b). Reports are due annually on July 1.
A regulated facility may consist of more
than one establishment (defined as
economic unit) and separate forms may
be used for each establishment as long
as reporting is accomplished for the
entire facility.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
E-12
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Supplier Notification Requirement - Subpart C
REQUIREMENTS
REGULATORY THRESHOLD
Facilities must notify the person to whom toxic
chemicals, mixtures or trade name products containing
toxic chemicals, are sold. The notification must be in
writing and include specific information per §372.45(b):
product trade name, a statement that the product
contains a SARA Title III, Section 313 chemical and the
chemical name, the CAS number of the chemical, and
the percent by weight of each toxic chemical in the
mixture or product.
Notification must be with the first shipment of the
product in each calendar year. If the product is
renamed or changed, the notification must be initiated
over again.
Owners and operators of facilities
classified as SIC code 20-39 who
manufacture, import or process toxic
chemicals, and who sell or otherwise
distribute a mixture or trade name
product containing a toxic chemical to a
facility who uses or sells the product or
mixture. If an MSDS is required in
accordance with 29 CFR 1910.1200,
the notification must be attached or
incorporated into the MSDS.
Exceptions include mixtures or trade
name chemicals with de minimis
amounts (see §372.45(d) for others).
However, if the chemical is considered
proprietary (trade secret) under 29 CFR
1910.1200, the notification can be
written with generic language.
Specific Toxic Chemical Listings - Subpart D
Tables, with alphabetical and CAS number listings of chemicals and chemical categories, along
with the effective date of the regulation for each of the chemicals are provided in §372.65.
Forms and Instruction - Subpart E
Toxic Chemical Release Reporting Form and Instruction - §372.85
REQUIREMENTS
EPA Form R must be used and is available by writing to
the Section 313 Document Distribution Center, PO
Box 12505, Cincinnati, OH 45212.
REGULATORY THRESHOLD
Toxic chemicals, manufactured,
processed, or otherwise used in excess
of an applicable threshold in §372.25.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i ,
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Appendix F Clean Water Act (CWA)
The primary objective of the Clean Water Act (CWA) is to restore and maintain the chemical,
physical, and biological integrity of the nation's waters. The CWA regulates both "direct"
discharges to waters of the United States and "indirect" discharges to publicly owned
treatment works (POTWs). Under the authority of the CWA, several types of regulations
have been developed to control discharges to the Nation's waters. Exhibit F-l illustrates
how the following regulations and permits work to limit the wastewater discharged:
> Effluent Limitation Guidelines and Categorical Pretreatment Standards establish
limitations for direct and indirect discharges (40 CFR Part 405-471)
* National Pollutant Discharge Elimination System (NPDES) Program controls
direct discharges (40 CFR Parts 122-125, 501, 503)
> National Pretreatment Program controls indirect discharges (40 CFR Parts 403)
> Spills of Oil and Hazardous Substances [CWA §311 (b) (3)] prohibits oil
discharges (40 CFR Part 110)
* Oil Pollution Prevention establishes procedures to prevent discharge of oil (40
CFR Part 112)
> Reportable Quantities for Hazardous Substances designates hazardous
substances and the reportable volumes for each (40 CFR Parts 116 and 117).
The following sections address each
regulation individually and identify the
inspection considerations for
programs implemented under the
CWA. The following sections
emphasize how the program is
implemented with the specific
requirements and compliance dates.
Clean Water Act:
Effluents Limitations Guidelines and Categorical
Pretreatment Standards F-2
NPDES Program F-7
Pretreatment Program F-l 1
Policy on Effluent Trading in Watersheds F-l3
Spills of Oil and Hazardous Substances F-l4
Oil Pollution Prevention F-14
Reportable Quantities for Hazardous Substances .... F-l5
CWA Assessment Considerations F-l 5
CWA Regulatory Requirements F-l7
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-l
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Exhibit F-1. CWA and Regulatory Requirements for
Organic Chemical Facilities
Clean Water Act
NPDES Program
40 CFR Part 122
Regulatory requirements to issue permits controlling
the discharge of pollutants to the nation's waters
Regulates all industrial direct
(point source) discharges (e.g.,
process wastewater, cooling
water) discharged to the
nation's waters
Storm water requirements
Effluent Guidelines for
Process Wastewater
Discharges
Cooling water discharges
Regulates municipal wastewater
treatment plant discharges
Requires implementation
of municipal pretreatment
programs
Individual control
mechanism (i.e., permit)
issued by municipality to all
facilities regulated by
categorical pretreatment
standards
Oil and Hazardous
Substances
40 CFR Part 110
40 CFR Part 112
40 CFR Part 116 and 117
Regulatory requirements
that regulate the discharges
of oil into waters of the
United States and the
designation of and
reportable quantities of
hazardous substances
Effluent Limitations Guidelines and Categorical Pretreatment Standards
For the CWA, industrial wastewater is regulated either by effluent limitations guidelines (direct
dischargers) or categorical pretreatment standards (indirect dischargers). Effluent guidelines
and categorical pretreatment standards apply only to industrial users with specific industrial
processes. Categorical pretreatment standards are technology-based limitations, requiring
compliance at the end-of-process. EPA
has promulgated effluent guidelines (for
direct discharges) and existing source and
new source pretreatment standards (for
indirect dischargers) for about 50
industrial categories. In addition to effluent
limitations and standards for Organic
Chemicals, Plastics, and Synthetic Fibers
(OCPSF) (Part 414), chemical
Less frequently, but still of potential applicability,
effluent limitations also exist for Soaps and
Detergents (Part 417), Fertilizers (Part 418),
Phosphate Manufacturing (Part 422), Rubber
Manufacturing (Part 428), Roofing Materials (Part
443), Paint Formulating (Part 446), Ink Formulating
(Part 447), Explosives (Part 457), Plastics Molding
and Forming (Part 463), and Pesticides Formulating,
Packaging, and Repackaging (Part 465).
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-2
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manufacturers are also commonly subject to regulations for Inorganic Chemicals (Part 415),
Petroleum Refining (Part 419), Pharmaceutical Manufacturing (Part 439), Gum and Wood
Chemicals (Part 454), and Pesticides Manufacturing (Part 455). These standards may limit any
pollutant, but emphasize the control of the 126 toxic pollutants designated by EPA as "priority
pollutants." Although chemical facilities may produce both organic and inorganic chemicals,
this document focuses on organic chemical manufacturers.
In general, wastewater from organic chemical facilities is regulated by 40 CFR Part 414
regulations (i.e., OCPSF Effluent Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards) but may also be regulated by one or more of the industry-
specific CFR Parts identified above. These regulations apply to process wastewater
discharged from organic chemical facilities. In most cases, the facility will have a wastewater
discharge permit issued either by an EPA Regional office, the State, or the local sewer
authority that incorporates applicable guidelines and standards. Where a facility discharges to
a POTW that is not authorized to implement and enforce the pretreatment program, the
facility will generally not have a wastewater discharge permit unless it has been issued by the
State. In these instances, it is the facility's responsibility to comply with the applicable
categorical pretreatment standards and requirements. Specific applicability determinations are
described in the appropriate regulation and are summarized below.
The 40 CFR Part 414 regulations do not apply to all organic chemical manufacturers.
Specifically, process wastewater discharges from the manufacture of organic chemicals solely
by extraction from plant and animal raw materials or by fermentation processes are not
regulated. Also, OCPSF process/product discharges which are covered by the provisions of
other categorical effluent limitations guidelines or categorical pretreatment standards if the
wastewater is treated in combination with the non-OCPSF industrial category regulated
wastewater are not covered. However, the OCPSF regulations do apply to the
product/processes covered if the facility reports OCPSF products under SIC codes 2865,
2869, or 2821, and its OCPSF wastewaters are treated in a separate treatment system at the
facility or discharged separately to a POTW.
For example, some vertically integrated petroleum refineries and pharmaceutical
manufacturers discharge wastewaters from the production of synthetic organic chemical
products that are specifically regulated under the Petrochemical and Integrated Subcategories
of the Petroleum Refining Category (40 CFR Part 419) or the Chemical Synthesis Products
Subcategory of the Pharmaceuticals Manufacturing Category (40 CFR Part 439). Unless the
OCPSF production wastewater from these facilities is treated or discharged separately from
the non-OCPSF wastewaters, discharges from these operations are subject to the other
categorical standards.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. -p o
-------
In addition, the OCPSF regulation does not apply to a plant's OCPSF production that has
been reported by the plant in the past under Standard Industrial Classification (SIC) groups
that are regulated by other guidelines. For example, benzene, toluene, and xylene
manufacturing that has been reported under SIC code 2911058 (Aromatics, Made from
Purchased Refinery Products) is not subject to the OCPSF requirements. Rather, these
facilities must comply with 40 CFR Part 419 (Petroleum Refining) requirements.
Additionally, EPA intends to promulgate effluent limitations guidelines and categorical
pretreatment standards for the Centralized Waste Treatment Category (40 CFR part 437)
that will regulate discharges from facilities that treat wastes received form offsite.
The following sections provide some additional details on the OCPSF, pharmaceutical
manufacturing, gum and wood chemicals, pesticide chemicals, and centralized waste
treatment regulations. Due to the scope of the petroleum refining regulations and the detail
needed to adequately address the industry, it has not been included in the scope of this
manual.
Organic Chemical. Plastics, and Synthetic Fibers
The 40 CFR Part 414 regulations cover all OCPSF products or processes whether or not
they are located at facilities where the OCPSF covered operations are a minor portion of and
ancillary to the primary production activities or a major portion of production. Stand-alone
OCPSF research and development, pilot plants, technical services, and laboratory bench scale
operations are covered by the OCPSF regulation only if these operations are conducted in
conjunction with and related to existing OCPSF manufacturing operations.
Federal effluent limitations guidelines, categorical pretreatment standards, and new source
performance standards set numerical concentration-based limitations. Applicable limitations
for a chemical facility subject to 40 CFR Part 414 must be based on a reasonable estimate of
process wastewater flows and the concentration limitations to develop mass limitations.
Compliance is to be evaluated against these mass limits.
Process wastewater flows are defined in the regulations (40 CFR §401.11) to include
wastewaters resulting from manufacture of OCPSF products that come in direct contact with
raw materials, intermediate products, or final products, and surface runoff from the immediate
process area that has the potential to become contaminated. Non-contact cooling waters,
utility wastewaters, general site runoff, ground waters, and other nonprocess wastewaters
generated onsite are specifically excluded from the definition of process wastewater
discharges. As such, the composition of each wastestream that is being generated is not as
crucial as the source of the wastewater. The permitting authority is responsible for
determining the appropriate flows to use for calculating permit limits.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. -p_A
-------
In addition to limitations for organics and conventional pollutants, the OCPSF regulations also
set specific requirements for chromium, copper, lead, nickel, zinc, and cyanide. For these
pollutants, only the flows from metal-bearing (for metals) or cyanide-bearing (for cyanide)
wastestreams and any incidental metals from intake water, corrosion of construction material,
or contamination of raw waters are to be used to calculate mass limitations. Specific metal-
and cyanide-bearing wastestreams are identified in Appendix A of 40 CFR Part 414, in
addition to any wastestreams, metal-bearing or cyanide-bearing, identified by the regulatory
agency issuing the permit. Discharges of chromium, copper, lead, nickel, and zinc, in
"complexed metal-bearing wastestreams," listed in Appendix B of 40 CFR Part 414, and non-
amenable cyanide as identified by the permitting authority, are not subject to the OCPSF
regulations.
Pharmaceutical Manufacturing
The existing Pharmaceutical Manufacturing regulations at 40 CFR Part 439 set effluent
limitation guidelines (for direct dischargers) based on required removal efficiencies for BOD,
COD, and TSS. In addition, the regulations specify cyanide limits according to the applicable
subpart (except Subpart E - Research for which categorical pretreatment standards are not
specified) and set allowable pH ranges. Cyanide effluent limitation guidelines are not specified
for discharges from bench-scale pharmaceutical research operations and product
development activities under Subpart E. The existing regulations specify categorical
pretreatment standards (for indirect dischargers) for cyanide only.
On May 2, 1995, EPA proposed revisions to the Pharmaceutical Manufacturing regulations.
The proposed regulations set end-of-pipe effluent limitation guidelines (for direct dischargers)
for BOD, COD, TSS, pH, and the priority and nonconventional pollutants contained in the
applicable subpart. EPA anticipates the rule to be finalized in early 1998. EPA may
simultaneously promulgate the effluent guidelines along with the planned National Emission
Standards for Hazardous Air Pollutants (NESHAPs) for the pharmaceutical industry.
Gum and Wood Chemicals
Under 40 CFR Part 454, direct discharge facilities manufacturing char and charcoal briquets
under Subpart A are prohibited from discharging process wastewater. The regulations
establish BOD and TSS production-based effluent limitation guidelines and specify an
allowable pH range for direct dischargers subject to other subparts of the regulations:
* Subpart B-Gum Rosin and Turpentine
> Subpart C-Wood Rosin, Turpentine, and Pine Oil
* Subpart D-Tall Oil Rosin, Pitch, and Fatty Acids
> Subpart E-Essential Oils
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p_ c
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* Subpart F-Rosin-Based Derivatives.
The regulations do not establish categorical pretreatment standards for indirect dischargers.
Therefore, indirect dischargers are only subject to the general and specific discharge
prohibitions and any applicable local limits as referred in 40 CFR § 403.5.
Pesticide Chemicals
Existing 40 CFR Part 455 regulations establish effluent limitation guidelines for dischargers
under Subpart A (Organic Pesticide Chemicals) for BOD, COD, TSS, organic pesticide
chemicals, and pH. In addition, dischargers subject to Subpart A must meet the effluent
limitation guidelines for pesticide active ingredients contained in Tables 2 or 3 of 40 CFR Part
455, if that pesticide active ingredient is manufactured and listed in Table 1 of 40 CFR Part
455. Finally, dischargers subject to Subpart A that manufacture pesticide active ingredients
listed in Table 1 of 40 CFR Part 455 must meet the effluent limitation guidelines for priority
pollutants listed in Table 4 of 40 CFR Part 455 (if end-of-pipe biological treatment is used) or
Table 5 of 40 CFR Part 455 (if end-of-pipe biological treatment is not used). Direct
dischargers subject to Subpart B (Metallo-Organic Pesticide Chemicals) and Subpart C
(Pesticide Chemicals Formulating and Packaging) are prohibited from discharging process
wastewater.
Existing 40 CFR Part 455 regulations establish categorical pretreatment standards for
dischargers under Subpart A (Organic Pesticide Chemicals) for the pesticide active ingredients
contained in Tables 2 or 3 of 40 CFR Part 455, if that pesticide active ingredient is
manufactured and listed in Table 1 of 40 CFR Part 455. Dischargers subject to Subpart A
must also comply with the categorical pretreatment standards for the priority pollutants listed
in Table 6 of 40 CFR Part 455. Facilities subject to Subpart C are prohibited from discharging
process wastewater. The existing regulations do not establish categorical pretreatment
standards for facilities subject to Subpart B.
On April 14, 1994, EPA proposed revisions to 40 CFR Part 455 which would establish
Subpart E to regulate discharges from the repackaging of agricultural pesticides performed by
refilling establishments whose principal business is retail sales. Direct and indirect dischargers
subject to Subpart E would be prohibited from discharging process wastewater. Exterior
wastestreams from small sanitizer pesticide facilities would be exempt from the zero discharge
requirements. Table 8 of proposed 40 CFR Part 455 includes a list of sanitizer pesticides
included in this exemption. Under the proposed regulations, direct and indirect dischargers
subject to Subpart C would have wastewater discharges from employee showers, fire
protection equipment test, and laundries exempted from regulation. Indirect dischargers
subject to Subpart C would have wastewater discharges from the formulating, packaging, or
repackaging of bleach exempted.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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On June 8, 1995, EPA published a supplemental notice to the proposed April 14, 1994, rule.
This supplemental notice solicited comments on providing a Pollution Prevention Alternative
to the zero discharge limitations and standards for direct and indirect dischargers. Under this
option, facilities regulated under existing Subpart C and proposed Subpart E would have the
choice of meeting the zero discharge limitation or standard or conducting the pollution
prevention practices listed in Tables B-l and B-2 of the notice. Facilities that choose to
conduct the pollution prevention alternatives would also have to notify the NPDES permit
writer (direct dischargers) or pretreatment authority (indirect dischargers), and keep necessary
paperwork onsite.
The June 8, 1995, supplemental notice solicited comments on exempting additional sanitizer
pesticides, microorganisms, and certain pesticide mixtures from regulation and on exempting
other chemicals used in the swimming pool industry from pretreatment standards.
Centralized Waste Treatment
On April 27, 1995, EPA proposed 40 CFR Part 437, Effluent Limitations Guidelines,
Pretreatment Standards, and New Source Performance Standards: Centralized Waste
Treatment Category (60 FR 5463). This proposed regulation would establish technology-
based limits and standards for discharges by existing and new "centralized waste treatment
facilities." The facilities covered by the guideline include stand-alone waste treatment and
recovery facilities which treat waste received from offsite and also include treatment systems
which treat onsite generated process wastewater with wastes received from offsite.
Specifically, centralized waste treatment facilities include the following: (1) commercial
facilities that accept waste from offsite for treatment from facilities not under the same
ownership; (2) non-commercial facilities that accept waste from offsite for treatment only
from facilities under the same ownership (i.e., intra-company transfer); or (3) mixed
commercial/non-commercial facilities that accept some waste from offsite for treatment from
facilities not under the same ownership and some waste from facilities under the same
ownership.
Organic chemical manufacturing facilities that might be covered by this rule should review the
proposed regulation and note any
future rulemaking activities for 40 CFR
Part 437.
NPDES Program
NPDES permits, issued by either EPA
or an authorized State (EPA has
authorized 41 States and territories, as
The NPDES permit program is implemented
according to 40 CFR Part 122: EPA Administered
Permit Programs: The National Pollutant Dis-
charge Elimination System. These regulations
establish the general program requirements,
permit application requirements, permit conditions,
and procedures for transfer, modification,
revocation, reissuance, and termination of permits.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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identified in Exhibit F-2, to issue permits), contain industry-specific technology-based (i.e.,
effluent guidelines as discussed in the previous section) and water quality-based effluent
discharge limitations, as well as monitoring, recordkeeping, reporting, and other
requirements. All facilities discharging to the Nation's waters must receive an NPDES
permit prior to initiating their discharges. This covers both process and non-process (e.g.,
non-contact cooling) wastewaters, and storm water discharges associated with industrial
activity that discharge either to a municipal separate storm sewer or directly to waters of the
United States. To regulate such dischargers, EPA/States may issue NPDES permits to
chemical facilities that include process, non-process, and storm water conditions or these may
be in separate permits.
EPA issues two types of NPDES
permits, individual and general. An Th/ter Procef' n°n-contact cooling water, and
:,..,, ... ...., Jf industrial activity (as it applies to the storm water
mdividua permit is a permit tai ored for ... x J,\ ,. .n ^rr) Art1 11f ^
F F regulations) are defined in 40 CFR 401.11 (q),
401.11(n), and 122.44(b) respectively.
a specific facility. A general permit
regulates a category of similar
dischargers within a geographical area
or within a State. However, because of the potential hazards associated with the chemical
industry, EPA has elected to issue individual permits to this sector with the exception that
general permits for storm water discharges may be issued. There are few exemptions to the
requirement to obtain an NPDES permit, as specified in 40 CFR §122.3. For chemical
facilities, there are four instances where this exemption may apply:
> Discharges to POTWs (these discharges will be regulated by a permit issued by
the POTW if the municipality has an approved pretreatment program and are
regulated by the National Pretreatment Program)
> Discharges into privately owned treatment works, except as otherwise
required by EPA
> Discharges of dredged or fill material (regulated by CWA §404)
> Any discharge in compliance with instructions from an on-scene coordinator
pursuant to 40 CFR Part 300 (i.e., The National Oil and Hazardous Substances
Pollution Contingency Plan) or 33 CFR §153.10(e) (i.e., Pollution by Oil and
Hazardous Substances).
[Note: Pollution by Oil and Hazardous Substances is enforced by the
Coast Guard and is not discussed herein.]
EPA or the State may terminate or modify a permit where it is determined that a permitted
activity endangers human health or the environment and can only be regulated to acceptable
levels by a permit modification or termination of the permit. Likewise, the permit may be
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p_o
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Exhibit F-2. State NPDES Program Approval Status
State
Alabama
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wvomins
TOTALS
Approved State NPDES
Permit Program
10/19/79
11/01/86
05/14/73
03/27/75
09/26/73
04/01/74
05/01/95
06/28/74
11/28/74
10/23/77
01/01/75
08/10/78
06/28/74
09/30/83
08/27/96
09/05/74
10/17/73
06/30/74
05/01/74
10/30/74
06/10/74
06/12/74
09/19/75
04/13/82
10/28/75
10/19/75
06/13/75
03/11/74
11/19/96
09/26/73
06/30/78
09/17/84
06/10/75
12/30/93
12/28/77
07/07/87
03/11/74
06/30/76
03/30/75
11/14/73
05/10/82
02/04/74
01/30/75
43
Approved to Regulate
Federal Facilities
10/19/79
11/01/86
05/05/78
01/09/89
12/08/80
06/01/79
09/20/79
12/09/78
08/10/78
08/28/85
09/30/83
08/27/96
11/10/87
12/09/78
12/09/78
01/28/83
06/26/79
06/23/81
11/02/79
08/31/78
04/13/82
06/13/80
09/28/84
01/22/90
01/28/83
11/19/96
03/02/79
06/30/78
09/17/84
09/26/80
12/30/93
09/30/86
07/07/87
--
02/09/82
--
05/10/82
11/26/79
05/18/81
37
Approved State
Pretreatment Program
10/19/79
11/01/86
09/22/89
06/03/81
05/01/95
03/12/81
08/12/83
06/03/81
09/30/83
08/27/96
09/30/85
04/16/85
07/16/79
05/13/82
06/03/81
09/07/84
04/13/82
-
06/14/82
07/27/83
11/19/96
03/12/81
-
09/17/84
04/09/82
12/30/93
08/10/83
07/07/87
03/16/82
--
04/14/89
09/30/86
05/10/82
12/24/80
31
06/26/91
11/01/86
09/22/89
03/04/83
03/10/92
10/23/92
05/01/95*
01/28/91
09/30/91
01/04/84
04/02/91
08/12/92
11/24/93
09/30/83
08/27/96
09/30/91
11/29/93
12/15/87
09/27/91
12/12/85
04/29/83
07/20/89
07/27/92
04/13/82
10/15/92
09/06/91
01/22/90
08/17/92
02/23/82
08/02/91
09/17/84
09/03/92
12/30/93
04/18/91
07/07/87
08/26/93
--
05/20/91
09/26/89
05/10/82
12/19/86
09/24/91
41
Number of Fully Authorized Programs (Federal Facilities, Pretreatment, General Permits) = 27
* New with phased Federal facilities & storm water programs by 2000.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-9
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terminated or an application denied if the permittee fails to fully disclose all relevant facts or
misrepresents relevant facts at any time. EPA or the State may modify a permit as a minor
modification allowing for a change in ownership or operational control of a facility where the
Director determines that no other change in the permit is necessary, provided that a written
agreement containing a specific date for
transfer of permit responsibility,
Specific permit applicability requirements for storm
water discharges are identified in 40 CFR
coverage, and liability between the
current and new permittee has been
submitted to the Director as specified in ^f2^). Facilities requesting to be covered
r under the storm water general permitting program
are required to submit a Notice of Intent (NOI) to
be covered under the general permit consistent
The evaluation team should be aware witu AC\ pro si ?? ?s
W 1U.1 TXJ \_sL JA. j-L L-I L-I . L-I (J.
that NPDES permits are issued with
both an issuance and expiration date
and the permits are issued for a period of up to 5 years. In some instances, the NPDES
permits issued by EPA or the State remain in effect even after their expiration date, provided
that the facility has submitted a timely and complete application (pursuant to 40 CFR §122.21)
and EPA or the State, through no fault of the permittee, does not issue a new permit with an
effective date on or before the expiration date of the previous permit.
Pursuant to 40 CFR §122.21, new dischargers are required to apply at least 180 days before
commencing discharge while existing permittees are required to reapply at least 180 days
prior to the expiration date of the existing permit, unless a later date has been granted by the
Director. In no case may an application be submitted after the expiration date of an existing
permit. EPA has specific application forms that are to be used for NPDES permits.
Application forms that apply to an organic chemical facility include:
Form Title Regulation
Cite
1 General Information 122.21(1)
2 C Existing manufacturers 12 2.21 (g)
2D New manufacturers 122.21(k)
2E Manufacturers that only discharge non-process 122.21(h)
wastewater
2F Storm water discharges associated with industrial 122.26(d)
activity and consistent with the requirements of
122.26(c)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 D
-------
While specific permit conditions might vary from permit to permit, all NPDES permits must
contain the conditions specified in 40 CFR §122.41. In general, these include requirements
for:
Reapphcation chemicai manufacturing faciiities ^e aiso
ť
Operation and maintenance
Effluent limitations
Monitoring and
recordkeeping
Reporting
Bypass restrictions
Upset provisions
Other standard conditions.
required to notify the permitting authority as soon
as they know or have reason to believe that any
activity has occurred or will occur which would
result in the discharge, on a routine, non-routine,
frequent, or infrequent basis, of any toxic pollutant
which is not limited in the permit, if that discharge
will exceed the highest of specified notification
levels as identified in 40 CFR §122.42(a).
For organic chemical facilities
considered by this guidance (SIC code 286), both maximum daily and average monthly
discharge permit limitations are set for each outfall based on the Part 414 guidelines (i.e.,
technology-based limitations), water quality considerations, and the permit writer's best
professional judgment. When it is impractical to impose permit limitations at the point of
discharge, effluent limitations may be imposed on internal wastestreams before mixing with
other wastestreams. In these instances, monitoring requirements also apply to these internal
streams.
Additionally, environmental laws (as identified in 40 CFR §122.49) may apply to the issuance
of NPDES permits. Specific laws that may apply include:
> Wild and Scenic Rivers Act
* National Historic Preservation Act of 1966
> Endangered Species Act
* Coastal Zone Management Act
> Fish and Wildlife Coordination Act
* National Environmental Policy Act.
It is the facility's responsibility to work with the EPA or State NPDES permit writers to ensure
that these statutes are adequately addressed during the permitting process. The evaluation of
applicability for each of these statutes will occur as part of permit development.
Pretreatment Program
The goals of the pretreatment program are to: (1) prevent damage to municipal wastewater
treatment plants that may occur when hazardous, toxic or other wastes are discharged into a
sewer system (i.e., interference); (2) prevent pollutants from passing through the treatment
plant untreated and violating discharge limitations or causing exceedances of water quality
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 1
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standards; and (3) encourage the reuse and recycling of municipal and industrial sludges (i.e.,
protect the quality of sludge generated by these plants). Nationwide, approximately 1,500
POTWs have been required to develop and implement local municipal pretreatment
programs. The requirement to develop and implement a program is included in the POTWs
NPDES permit. Through this program, the POTW is directly responsible for regulation of
certain significant industrial users discharging to the POTW wastewater treatment system,
including facilities regulated by categorical pretreatment standards. EPA's General
Pretreatment Regulations for Existing and New Sources of Pollution (40 CFR Part 403)
establish requirements for POTW programs to regulate discharges from industrial facilities to
POTWs and establishes certain requirements for industrial users (e.g., monitoring and
recordkeeping).
In most instances, chemical facilities discharge to POTWs that are authorized to implement
and enforce the pretreatment requirements through an approved pretreatment program.
Where this occurs, the facility is required to abide by the terms of a POTW-issued control
mechanism (e.g., permit) and the local sewer use ordinance (SUO). It is the POTWs
responsibility to appropriately implement and enforce these requirements and its
pretreatment program, that must be at least as stringent as the Federal pretreatment
requirements specified in 40 CFR Part 403, on its industrial users. However, even if a POTW
fails to properly apply Federal or State regulations, the chemical facility has an independent
obligation to comply with applicable Federal and State requirements.
Some chemical facilities are located in municipalities that do not have locally-run pretreatment
programs. In these areas, permits are generally not issued by EPA or the State, rather these
facilities are obligated to comply with Federal and/or State pretreatment requirements as
identified in the regulations. Both the general pretreatment regulations (40 CFR Part 403) and
any applicable categorical pretreatment standards apply to the facility. Currently, EPA has
delegated pretreatment program authority to 29 States (as identified in Exhibit F-2), in which
the State directly controls those industries that discharge to municipalities without locally-run
pretreatment programs. In all remaining States, unless the POTW is authorized to implement
and enforce its own pretreatment program, EPA implements and enforces the program.
The 40 CFR Part 403 pretreatment regulations specify, among other things, requirements for
non-domestic sources discharging pollutants into POTWs. The regulations set out three
different types of effluent limitations for industrial discharges: prohibited discharge standards,
categorical pretreatment standards, and local discharge limitations.
Prohibited discharge standards forbid certain types of discharges to the POTW, including
POTWs without approved pretreatment programs. These standards include both general
and specific prohibitions. The general prohibitions are national prohibitions against pollutants
discharged to a POTW that cause pass through or interference, as defined in §403.3. Specific
prohibitions, at 40 CFR §403.5(b), are national prohibitions against pollutants that cause
problems at the POTW, such as fire or explosion, harm to worker health and safety,
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 ?
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corrosion, obstruction of flow, excessive heat, trucked or hauled waste or excessive mineral
or synthetic oil and grease.
As noted earlier in Section 3.1.1.1, effluent guidelines and categorical pretreatment standards
apply to specific process water wastestreams from specific industrial processes. The
standards are technology-based and apply at the end of the regulated industrial process.
Although a number of regulations might apply to a facility manufacturing chemicals, the organic
chemicals industry that does not produce pesticide active ingredients, pharmaceutical
products, or conduct petroleum refining will generally be regulated by the OCPSF standards
at 40 CFR Part 414.
Since National prohibited discharge standards and categorical standards are not POTW-
specific, these limitations may not necessarily protect a POTW from pass through or
interference. As such, all POTWs authorized to implement and enforce a local pretreatment
program, and many other POTWs that have received problematic discharges from their
industrial users, are required to develop local discharge limitations to address site-specific
concerns regarding interference with the POTW wastewater collection system or treatment
plant or pass through of pollutants to the receiving stream or sludge. In addition, local limits
translate prohibited discharge standards into numerical limitations that can be more readily
evaluated.
The General Pretreatment Regulations (40 CFR Part 403) also specify reporting requirements
applicable to industrial dischargers. POTWs may set more stringent requirements in their
local sewer use ordinance or in a wastewater discharge permit issued to the chemical facility,
but at a minimum, chemical facilities must submit semiannual monitoring reports (403.12 (e)),
notices of potential problems, including slug loads (403.12(fj), notification of effluent violations
(403.12(g)(2)), notification of changed discharge (403.12(j)); must keep records as required
(403.12(o)), and must notify of hazardous waste discharges (403.12(p)). The regulations also
include upset and bypass provisions, in §403.16 and §403.17, respectively, that apply to
industrial dischargers.
Policy on Effluent Trading in Watersheds
The evaluation team should be aware of EPA's draft Framework for Watershed-Based Effluent
Trading (May 1996). The fundamental principle of trading within the Clean Water Act
framework is that water quality standards must be met and technology-based requirements
must remain in place.
Trading is a method to attain and/or maintain water quality standards, by allowing sources of
pollution to achieve pollutant reductions through substituting a cost-effective and enforceable
mix of controls on other sources of discharge. Effluent trading potentially offers a number of
economic, environmental, and social benefits. Proposed types of effluent trading approaches
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p i o
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are (1) intra-plant, (2) pretreatment, (3) point/point source, (4) point/nonpoint source, and (5)
nonpoint/nonpoint source.
Watershed-based trading will be implemented on a voluntary basis under existing CWA
authorities. There will be a substantial public outreach effort to obtain stakeholders' (e.g.,
regulated sources, non-regulated sources, regulatory agencies, and the public)
recommendations and insights on draft portions of the trading policy prior to implementation.
Facilities interested in this trading policy should initiate dialogue with their local permitting
authority.
Spills of Oil and Hazardous Substances
The regulations at 40 CFR Part 110 apply to the discharge of oil, which is prohibited by
Section 311 (b) (3) of the CWA. For purposes of this regulation, "discharge" is defined as any
spilling, leaking, pumping, pouring, emitting, emptying, or dumping. Prohibited discharges
include those into or upon the navigable waters of the United States, adjoining shorelines, or
the contiguous zone in such quantities that may be harmful to the public health or welfare of
the United States, that violate applicable water quality standards, or cause a film or sheen
upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or
emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.
Addition of dispersants or emulsifiers to oil to be discharged that would circumvent these
provisions is prohibited. The National Response Center as described in 40 CFR §110.10
must be immediately notified of any discharge in violation of these restrictions.
Oil Pollution Prevention
The regulations at 40 CFR Part 112 establish procedures, methods and equipment, and other
requirements for equipment to prevent the discharge of oil into or upon the navigable waters
of the United States or adjoining shorelines (i.e., preparation and implementation of Spill
Prevention Control and Countermeasure (SPCC) Plans). This part applies to owners or
operators of onshore facilities engaged in drilling, producing, gathering, storing, processing,
refining, transferring, distributing, or consuming oil and oil products which could reasonably
be expected to discharge oil in harmful quantities, as defined in 40 CFR Part 110. Guidelines
for the preparation and implementation of a SPCC Plan are summarized in 40 CFR §112.7,
while specific requirements for these Plans are outlined in 40 CFR §112.3.
This Part does not apply to facilities that both (1) have an underground buried storage capacity
for oil of 42,000 gallons of oil or less and (2) the storage capacity for oil, which is not buried,
is 1,320 gallons or less, provided that no single container has a capacity in excess of 660
gallons.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 4
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Reportable Quantities for Hazardous Substances
Parts 116 and 117 of the Federal Water Pollution Control Act (40 CFR Parts 116 and 117)
designate hazardous substances and the reportable quantity (RQ) of hazardous substances,
respectively. When an amount equal to or in excess of the RQ is discharged into or upon the
navigable waters of the United States, adjoining shorelines, or into or upon the contiguous
zone, the facility must provide notice to the Federal government of the discharge, following
Department of Transportation requirements set forth in 33 CFR §153.203. For purposes of
this regulation, "discharge" means any spilling, leaking, pumping, pouring, emitting, emptying,
or dumping. This requirement does not apply to facilities that discharge the substance under
an NPDES permit or a Part 404 Wetlands (dredge and fill) permit, or to a POTW, as long as
any applicable effluent limitations or pretreatment standards have been met. RQs for specific
chemicals are listed in 40 CFR §117.3.
CWA Assessment Considerations
To evaluate compliance with effluent limitations and effluent monitoring, the assessor should
verify that the facility's operations are properly regulated by the permit and that monitoring
results are representative of the facility's operations. One of the unique features of many
chemical facilities are their dynamic processing operations. Both production volumes and the
types of chemicals produced can vary drastically over the course of a month or year. Many
facilities will manufacture a given chemical during a campaign for a few weeks or months and
then may never make that chemical again. One of the investigator's responsibilities should be
to verify that monitoring results represent these types of activities. Chemical production may
also be either a batch or continuous operation. For batch processes, the amount and
frequency of wastewater generated is potentially much higher than for continuous processes.
Additionally, many specialty chemical manufacturers will use a given reaction vessel to
manufacture a variety of different products. Wastes that are generated in that unit will vary,
possibly on a daily basis. Also, the investigator should verify that facility operations have not
changed such that wastewater characteristics changed significantly, but if so, that proper
notification was given to the permitting authority.
One of the fundamental components of the effluent limitations guidelines and categorical
standards for facilities regulated by OCPSF regulation (40 CFR Part 414), is that calculated
limits (as calculated from concentration standards and process flows) are based on process
flows. Final permit limitations are based on the sum of the mass effluent limitations from
process wastewaters plus any mass allowances, determined by the permit writer using best
professional judgment, to account for nonprocess wastewater pollutant contributions. The
assessor needs to understand the basis of the facility's permit limits and the data needed to
evaluate compliance (e.g., flow concentration data, standards, regulated flows). Based on
permit information and the process flow diagram, investigators should verify that the reported
process and non-process flows are accurate and that the facility's limits (based on flows) are
representative of the facility's process. Often, a facility will commingle boiler blowdown,
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p_ i c
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cooling tower blowdown, and water treatment regeneration chemicals (i.e., caustics and
acids) with process wastewater and identify this combined flow as process wastewater. In
most cases, individual wastewater contributions are estimated based on the facility's total plant
flow or based upon visual estimates. The assessor should verify that these flows are
reasonable. (A simple bucket and stopwatch method may be to estimate the accuracy of the
reported flow values.) It is a common mistake for a facility to drastically over- or under-
estimate flows when preparing permit applications simply because, estimating flows based on
visual observation is very difficult. Of note, process wastewater flows from chemical facilities
may be highly variable. As such, wastewater flows may be fairly significantly different during
the assessment than the flows used to calculate permit limits.
The assessor should be aware that in States that have high volume storm events (e.g., Texas),
permit limitations may be based on a process flow that takes into account storm water flows
from process areas during these storm events. As such, permit limitations may be based on
flows that are much greater than normal dry weather flows.
The process wastewater flow used to develop mass limitations should be based upon the
facility's flow using sound water conservation practices, as applicable. For example, process
water use should be minimized, cascading or countercurrent washes or rinses should be used
where possible, and intermediate process waters or treated wastewaters should be reused or
recycled (e.g., from pump seals and equipment washdowns).
Barometric condensers can generate excessive large volumes of water contaminated at low
levels. Replacement of these with surface condensers can reduce wastewater volumes
significantly and result in collection of condensates that may be returned to the process.
The assessor team should pay particular attention to treatment system performance at a
chemical facility. Where treatment systems are installed, the investigator needs to verify that
proper O&M practices are in place to ensure consistent treatment plant performance. O&M
should include documentation of all activities performed (e.g., calibrations, inspections,
repairs, chemical additions, etc.). Evaluation of trends in monitoring results can indicate
improper O&M. For example, steam strippers can lose efficiency due to fouling of the
packing material if the equipment is not cleaned at the proper frequency. The investigator
should verify that backup systems or procedures exist for the periods when system O&M is
being conducted. Also, the investigator should verify that the facility has adequate staff to
operate and maintain the treatment system. In many instances, this may require full-time,
around the clock staffing.
Because of the vast array of process equipment and piping, it is important that the facility's
operation and maintenance (O&M) program include regular facility assessments for leaks,
spills, and stressed equipment and a documented procedure for conducting these
assessments. In addition, areas that have a high potential for spills or leaks (e.g., pipes,
pumps, fittings, etc.) should have spill containment installed to prevent major releases to the
environment, to the facility's onsite treatment system, or to the POTW.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 fi
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Finally, when evaluating compliance with effluent limitations, the investigator should verify that
the monitoring results are representative of facility operations and consistent with 40 CFR Part
136 procedures. [Note that "EPA approved methods" does not indicate that proper
procedures were followed. EPA has approved methods for drinking water, wastewater, and
solid waste which can all be used to analyze pollutant concentrations in wastewater, but only
Part 136 regulations apply to CWA regulations.] Because of the variations in production at
many chemical facilities, a wastewater sample collected on a given day may not be a fair
estimate of typical facility operations. Also, wastewater from chemical manufacturers can be
highly complex, causing matrix interferences that can hinder laboratory analysis at the
regulatory limitations. Assessor should verify that analytical results reported as "Not Detected"
have been analyzed down to the requisite quantification level. In June 1993, EPA published a
guidance manual on laboratory protocol to improve analytical performance due to matrix
interference and other complications. The manual is called Guidance on Evaluation,
Resolution, and Documentation of Analytical Problems Associated with Compliance
Monitoring.
When evaluating compliance with the oil and hazardous substance regulations, the investigator
should inquire about past instances of spills (or leaks, pumping, etc.) and should identify how
the facility reacted to each circumstance. Specifically, the assessors should note: what
material was spilled; where did the discharge go; what quantity was spilled; what was the
reportable quantity; what was the facility's response for containment, clean-up, and
notification; any related health and safety issues for the plant, the community, or the
environment; and what are the facility's plans to prevent a recurrence of the situation. The
assessor should also review the SPCC Plan and any other spill or slug control plan onsite
applicable to the facility. As part of the pretreatment program, the facility may be required to
implement a spill and slug control plan concurrent with the SPCC plan and reportable
quantities regulation.
CWA Regulatory Requirements
The following section provides a summary of the principal regulations developed pursuant to
the CWA that are applicable to the organic chemical industry. The regulations included are:
> 40 CFR Part 414 - Organic Chemicals, Plastics, and Synthetic Fibers
> 40 CFR Part 439 - Pharmaceutical Manufacturing
> 40 CFR Part 454 - Gum and Wood Chemicals Manufacturing
> 40 CFR Part 455 - Pesticide Chemicals
> 40 CFR Part 110 - Discharge of Oil
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 7
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> 40 CFR Part 112 - Oil Pollution Prevention
* 40 CFR Part 116 - Designation of Hazardous Substances
* 40 CFR Part 117 - Determination of Reportable Quantities for Hazardous
Substances
The regulatory summaries for applicable effluent guidelines are provided for direct discharges
(i.e., facilities that discharge directly to waters of the U.S. and are regulated by an NPDES
permit) and those that discharge indirectly (i.e., discharge to a Publicly Owned Treatment
Works (POTW) which in turn discharges to waters in the U.S.)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-18
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Applicability:
40 CFR Part 414
~ , f ., Organic Chemicals, Plastics, and Synthetic
Discharges from the & , , , V,
Fibers as administered through 40 CFR Part
122: EPA Administered Permit Programs,
The National Pollutant Discharge Elimination
System
manufacture of OCPSF
products under SIC codes 2821
(Plastic Materials, Synthetic
Resins, and Nonvulcanizable
Elastomers), 2823 (Cellulosic
Man-Made Fibers), 2824
(Synthetic Organic Fibers, Except Cellulosic), 2865 (Cyclic Crudes and Intermediates, Dyes
and Organic Pigments), and 2869 (Industrial Organic Chemicals, Not Elsewhere Classfied).
Exemptions:
Discharge from the manufacture of OCPSF products if the products are included in the
following SIC subgroups and in the past have been reported as such:
- SIC 2843085 - bulk surface active agents
- SIC 28914 - synthetic resin and rubber resin
- Chemicals and chemical preparations not elsewhere classified
> 2899568 - sizes, all types
> 2899597 - other industrial chemical specialties, including flaxes, plastic wood
preparations, and embalming fluids C^
- SIC 2911058 - aromatic hydrocarbons manufactured from purchased refinery products ť-C!
- SIC 2911632 - aliphatic hydrocarbons manufactured from purchased refinery products ^
Q
Discharge for which a different set of previously promulgated effluent limitations guidelines ^
and standards apply, unless the facility reports OCPSF products under SIC codes 2865, O
2869, or 2821, and the facility's OCPSF waste waters are treated in a separate treatment ^
system or discharged separately to a publicly owned treatment works (^
i
Process wastewater discharges from the manufacture of organic chemical compounds
solely by extraction from plant and animal raw materials or by fermentation processes
Discharges of chromium, copper, lead, nickel, and zinc in "complexed metal-bearing waste
streams," listed in Appendix B of 40 CFR 414
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-1 Q
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Applicable Subparts:
Subpart B: Rayon Fibers - manufactured by the viscose process only [414.20]
Subpart C: Other Fibers - manufactured under SIC codes 2823 (except rayon) and 2824
[414.30]
Subpart D: Thermoplastic Resins - manufactured under SIC 28213 [414.40]
Subpart E: Thermosetting Resins - manufactured under SIC code 28214 [414.50]
Subpart F: Commodity Organic Chemicals - manufacture of chemicals listed in 414.60
under SIC codes 2865 and 2869
Subpart G: Bulk Organic Chemicals - manufacture of chemicals listed in 414.70 under SIC
codes 2865 and 2869
Subpart H: Specialty Organic Chemicals - manufactured under SIC codes 2865 and 2869,
not defined as commodity or bulk organic chemicals in 414.60 or 414.70
[414.80]
Subpart I: Direct Discharge point Sources that use End-of-Pipe Biological Treatment
[414.90]
Subpart J: Direct Discharge Point Sources that Do Not Use End-of-Pipe Biological
Treatment [414.100]
40 CFR PART 414 - DIRECT DISCHARGES
REQUIREMENTS
Discharge Limitations:
Effluent limitations contained in 40 CFR Part 414
including:
- Applicable BPT, BAT, or NSPS discharge limitations
(depending on subpart) for BOD, TSS, and pH
- Limitations in 414.91 for other pollutants for facilities
that use end-of-pipe biological treatment
- Limitations in 4 1 4. 1 0 1 for other pollutants for facilities
that do not use end-of-pipe biological treatment
COMPLIANCE DATES
Existing Sources: 11/5/90, as
required by permit.
New Sources: Date source begins
operation, as required by permit.
Compliance with specific permit
limitations upon effective date of the
permit.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-20
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40 CFR PART 414 - DIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
- Limitations in 414.91 and 414.101 are applied on a
mass basis (determined by multiplying regulated
process wastewater flow times the concentration limits
in 414.91 and 414.101)
Any other effluent limitation contained in the NPDES
permit
Monitoring and Reporting Requirements:
Note: All direct dischargers are required to obtain an
NPDES permit. The NPDES permit outlines the dischargers
specific monitoring and reporting requirements.
Permit Applications - containing the information required
under 122.21(0, (g), and (k) (application requirements for
new sources and new discharges)
Planned Changes - notification to the Director as soon as
possible of any planned physical alteration or addition that
meets the criteria in 122.41(1)(1)
Anticipated Noncompliance - advance notification to the
Director of any planned changes that may result in permit
noncompliance
Monitoring Reports - monitoring results must be
submitted as required by the NPDES permit (at least
annually). All monitoring must be conducted using 40
CFR Part 136 methods.
Compliance Schedules - reports of compliance or
noncompliance with compliance schedule requirements
24-Hour Reporting - of any noncompliance that may
endanger health or the environment, including the
information listed in 122.41(1)(6)
Anticipated and Unanticipated Bypass - notification as
required under 122.41 (m)
Discharge of Toxic Pollutants - notification to the Director
of activity that results in the discharge of toxic pollutants
not limited in the permit, if it exceeds the levels outlined
in 122.42(a)(l)
Storm Water Permit Applications - submission of either
individual permit application or general permit applications
Permit applications are to be
submitted 180 days prior to the
commencement of discharge.
Applications for permit renewal are
required to be submitted 180 days
before the existing permit expires.
As soon as possible, when
applicable
In advance of changes, when
needed
At least annually or more frequently
as required by permit
Within 14 days of each compliance
schedule date
Within 24 hours
At least 10 days prior to anticipated
bypass. Within 24 hours of
unanticipated bypass
As soon as facility knows or has
reason to believe that levels will be
exceeded
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-21
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40 CFR PART 414 - DIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Individual permit applications must include the
information in 122.26(c)(l)
Facilities to be covered under a general permit must
file a Notice of Intent (NOI)
Other Storm Water Reports - submission of other
reports as required under a facility's storm water
discharge permit. These reports may include pollution
prevention plans and monitoring reports.
Record Keeping Requirements:
Records of monitoring information as required under
122.41 (j) must be kept for at least three years.
Individual permit applications for
existing facilities were due October
1, 1992. New facilities must submit
an application 180 days prior to
commencement of industrial activity
NOIs from existing facilities were
due on October 1, 1992. NOIs
from new facilities are due 2 days
prior to the commencement of
industrial activities.
Due dates as required by permits
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-22
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40 CFR Part 414
Organic Chemicals, Plastics, and Synthetic
Fibers as administered through 40 CFR Part
403: General Pretreatment Regulations for
Existing and New Sources of Pollution
Applicability:
Discharges from the
manufacture of OCPSF
products under SIC codes 2821
(Plastic Materials, Synthetic
Resins, and Nonvulcanizable
Elastomers), 2823 (Cellulosic
Man-Made Fibers), 2824 (Synthetic Organic Fibers, Except Cellulosic), 2865 (Cyclic Crudes
and Intermediates, Dyes and Organic Pigments), and 2869 (Industrial Organic Chemicals, Not
Elsewhere Classfied).
Exemptions:
Discharge from the manufacture of OCPSF products if the products are included in the
following SIC subgroups and in the past have been reported as such:
- SIC 2843085 - bulk surface active agents
- SIC 28914 - synthetic resin and rubber resin
- Chemicals and chemical preparations not elsewhere classified
> 2899568 - sizes, all types
> 2899597 - other industrial chemical specialties, including flaxes, plastic wood
preparations, and embalming fluids
- SIC 2911058 - aromatic hydrocarbons manufactured from purchased refinery products
- SIC 2911632 - aliphatic hydrocarbons manufactured from purchased refinery products ^
O
Discharge for which a different set of previously promulgated effluent limitations guidelines -^
and standards apply, unless the facility reports OCPSF products under SIC codes 2865, Ł-H
2869, or 2821, and the facility's OCPSF waste waters are treated in a separate treatment s~->
system or discharged separately to a publicly owned treatment works S^
-^3
Process wastewater discharges from the manufacture of organic chemical compounds ""Q
solely by extraction from plant and animal raw materials or by fermentation processes
Discharges of chromium, copper, lead, nickel, and zinc in "complexed metal-bearing waste
streams," listed in Appendix B of 40 CFR 414
Applicable Subparts:
Subpart E-H: As identified for direct discharges
Subpart K: Indirect Discharge Point Sources [414.110] ^
<0
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-?9
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40 CFR PART 414 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Discharge limitations:
Limitations contained in 414.111:
- Are applied on a mass basis (determined by multiplying
regulated process wastewater flow times the
concentration limits in 414.111)
- Mass limits for lead, zinc, and total cyanide are
determined by multiplying the concentration limits in
414.111 times the flow from metal-bearing waste
streams for metals and cyanide-bearing waste streams
for total cyanide. Appendix A of Part 414 defines
metal and cyanide-bearing waste streams.
Prohibited discharge standards (general and specific) in 40
CFR 403.5
Applicable local limits
Monitoring and Reporting Requirements:
Note: Reports must be submitted whether or not the facility
has been issued a permit.
Baseline Monitoring Reports (BMR) - containing the
information required under 40 CFR 403.12 (b).
Compliance Schedule Progress Reports - containing the
information required under 40 CFR 403.12(c)(3)
90-Day Compliance Report - containing the information
required under 40 CFR 403.12(d)
Periodic Reports on Continued Compliance - containing
the information in 403.12(e) (including monitoring data
for all categorically regulated pollutants) All monitoring
must be conducted using 40 CFR Part 136 methods.
Notice of Potential Problems Including Slug Loadings
PSES: 11/5/90, as required by
permit
PSNS: Date new source begins
operation, as required by
permit
BMRs from existing sources were
due by June 20, 1988. BMRs from
new sources are due 90 days prior
to commencement of discharge.
Due within 14 days of completing
compliance schedule milestone or
due date
Due within 90 days following date
for final compliance (11/5/90) or for
new sources, following the
commencement of introduction of
wastewater to the POTW
Must be submitted at least
semiannually
Due to the Control Authority
immediately upon identification of
discharges that could cause
problems to the POTW
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-24
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40 CFR PART 414 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Notice of Changed Discharge - advanced notification of
any substantial change in the volume or character of
pollutants in the discharge (including hazardous wastes)
Notice of Violations and Resampling - notification due to
the Control Authority within 24 hours of noting a
violation; results of resampling must be submitted within
30 days
Notification of Hazardous Waste Discharge - notification
to the POTW, EPA, and the State of the hazardous
wastes discharged to the POTW
Record Keeping Requirements:
Monitoring records including the information listed in
403.12(o) must be maintained for at least 3 years
Prompt notification in advance of
any substantial change
Notice within 24 hours, results of
resampling within 30 days
One time notification, unless
changes to discharge
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-25
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-?fi
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Applicability:
Any pharmaceutical manufacturing facility
discharging process waste waters to water,
of the United States.
Exemptions:
None
40 CFR Part 439
Pharmaceutical Manufacturing as
Administered Through 40 CFR Part 122: EPA
Administered Permits Programs, The
National Pollutant Discharge Elimination
System
Applicable Subparts:
Subpart A: Fermentation Products
Subpart B: Extraction Products
Subpart C: Chemical Synthesis Products
Subpart D: Mixing, Compounding, and Formulating
Subpart E: Research
40 CFR PART 439 - DIRECT DISCHARGES
REQUIREMENTS
Discharge Limitations:
Effluent limitations contained in 40 CFR Part 439 including:
- BOD, COD, and TSS limits based on required removal
efficiencies (Subparts A, B, C, D, E)
- Allowable pH range (Subparts A, B, C, D, E)
- BPT, BAT and NSPS cyanide limits (Subparts A, B, C, D)
Relate to May 2, 1995, proposed rule:
- BPT end-of-pipe limits for BOD, TSS, COD, and pH
(Subparts A, B, C, D)
- BPT, BAT, or NSPS cyanide limits at in-plant monitoring
points (Subparts A,C)
COMPLIANCE DATES
Existing Sources: 10/27/86
(under current regulations as
required by permit).
New Sources: Date source
begins operation, as required
by permit.
Compliance with specific
permit limitations upon
effective date of the permit.
fo
t!
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
^h
F-27
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40 CFR PART 439 - DIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
- BAT or NSPS end-of-pipe limits for priority and
nonconventional pollutants (Subparts A, B, C, D)
- BOD, COD and TSS limits based on required removal
efficiencies and allowable pH range (Subpart E)
Any other effluent limitation contained in the NPDES permit
Monitoring and Reporting Requirements:
Note: All direct dischargers are required to obtain an NPDES
permit. The NPDES permit outlines the dischargers' specific
monitoring and reporting requirements.
Permit Applications - containing the information required under
122.21(f), (g), and (k) (application requirements for new
sources and new discharges) Permit applications are to be
submitted 180 days prior to the commencement of discharge.
Applications for permit renewal are required to be submitted
180 days before the existing permit expires.
Planned Changes - notification to the Director as soon as
possible of any planned physical alteration or addition that
meets the criteria in 122.41(1)(1). As soon as possible, when
applicable.
Anticipated Noncompliance - advance notification to the
Director of any planned changes that may result in permit
noncompliance.
Monitoring Reports - monitoring results must be submitted as
required by the NPDES permit (at least annually). All
monitoring must be conducted using 40 CFR Part 136
methods.
Permittees not using or generating cyanide may certify in lieu of
monitoring.
(Section 439.2 specifies required monitoring frequencies for
each regulated pollutant generated or used at a facility.)
Compliance Schedules - reports of compliance or
noncompliance with compliance schedule requirements
24-Hour Reporting - of any noncompliance that may endanger
health or the environment, including the information listed in
122.41(1) (6)
Anticipated and Unanticipated Bypass - notification as required
under 122.41 (m)
Permit applications are to be
submitted 180 days prior to
the commencement of
discharge for new sources and
180 days before the existing
permit expires for existing
sources.
As soon as possible, when
applicable.
In advance of changes, when
needed.
At least annually or more
frequently by permit.
Within 14 days of each
compliance schedule date
Within 24 hours
At least 10 days prior to
anticipated bypass. Within 24
hours of unanticipated bypass.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-28
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40 CFR PART 439 - DIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Discharge of Toxic Pollutants - notification to the Director of
activity that results in the discharge of toxic pollutants not limited
in the permit, if it exceeds the levels outlined in 122.42(a)(l)
Storm Water Permit Applications - submission of either
individual permit application or general permit applications
- Individual permit applications must include the information in
122.26(c)(l)
Facilities to be covered under a general permit must file a
Notice of Intent (NOI)
Other Storm Water Reports - submission of other reports as
required under a facility's storm water discharge permit. These
reports may include pollution prevention plans and monitoring
reports.
Record Keeping Requirements:
Records of monitoring information as required under 122.41 (j)
must be kept for at least three years.
As soon as facility knows or
has reason to believe that
levels will be exceeded
Individual permit applications
for existing facilities were due
October 1, 1992. New
facilities must submit an
application 180 days prior to
commencement of industrial
activity.
NOIs from existing facilities
were due on October
1,1992. NOIs from new
facilities are due 2 days prior
to the commencement of
industrial activities.
Due dates as required by
permits.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-29
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
Applicability:
Any pharmaceutical
manufacturing facility discharging
process wastewater to a
POTW
40 CFR Part 439
Pharmaceutical Manufacturing as
Administered Through 40 CFR Part 403:
General Pretreatment Regulations for Existing
and New Sources of Pollution
40 CFR PART 439 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Discharge limitations (text in italics relates to
May 2, 1995, proposed regulations):
Limitations contained in 40 CFR Part 439
including:
- Cyanide limits (Subparts A, B, C, D)
Prohibited discharge standards (general and
specific) in 40 CFR 403.5
Applicable local limits
Relates to May 2, 1995, proposed rule:
- Priority and non-conventional pollutants
limits at in-plant and end-of-pipe
monitoring points (Subparts A, B, C, D)
Monitoring and Reporting Requirements:
Note: Reports must be submitted whether or
not the facility has been issued a permit
Baseline Monitoring Reports (BMR) -
containing the information required under 40
CFR 403.12(b)
Compliance Schedule Progress Reports -
containing the information required under 40
CFR 403.12(c) (3)
PSES: 10/27/86, as required by permit
PSNS: Date new source begins operation as
required by permit
BMRs from existing sources due within 180 days
of effective date of categorical pretreatment
standard (fune 9, 1984, for current regulations)
BMRs from new sources are due 90 days prior
to commencement of discharge
Due within 14 days of completing compliance
schedule milestone or due date
O
Q>
00
^
E^H
^h
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-31
-------
40 CFR PART 439 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
90-Day Compliance Report - containing the
information required under 40 CFR
403.12 (d)
Periodic Reports on Continued Compliance
- containing the information in 403.12(e)
(including monitoring data for all categorically
regulated pollutants). All monitoring must be
conducted using 40 CFR Part 136 methods.
Dischargers not using or generating cyanide
may certify in lieu of monitoring.
(Section 439.2 specifies required monitoring
frequencies for each regulated pollutant
generated or used at a facility.) 1
Notice of Potential Problems Including Slug
Loadings
Notice of Changed Discharge - advanced
notification of any substantial change in the
volume or character of pollutants in the
discharge (including hazardous wastes)
Notice of Violations and Resampling -
notification due to the POTW within 24
hours of noting a violation; results of
resampling must be submitted within 30 days
Notification of Hazardous Waste Discharge -
notification to the POTW, EPA, and the State
of the hazardous wastes discharged to the
POTW
Due within 90 days following date for final
compliance (10/27/86 under current
regulations) or for new sources following the
commencement of introduction of wastewater
to the POTW
Must be submitted at least semiannually
Due to the POTW immediately upon
identification of discharges that could cause
problems to the POTW
Prompt notification in advance of any substantial
change
Notice within 24 hours, results of resampling
within 30 days
One time notification, unless changes to
discharge
The June 8, 1995 (Pesticide Chemicals) supplemental notice to the proposed April 1994 rule provides a
Pollution Prevention Alternative for facilities regulated under Subpart C and proposed Subpart E. In lieu of
meeting the zero discharge of process wastewater requirement, these facilities could demonstrate that the
requirements of the Pollution Prevention Alternative listed in Tables B-l and B-2 are met, notify the NPDES
permit writer or pretreatment authority, and keep necessary paperwork onsite.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-32
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40 CFR PART 439 - INDIRECT DISCHARGES
REQUIREMENTS
Record Keeping Requirements
Monitoring records including the information
listed in 403. 1 2 (o) must be maintained for at
least 3 years
COMPLIANCE DATES
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-33
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
Applicability:
Discharges from the
manufacture of gum and wood
chemicals as described by
applicable subparts.
Exemptions:
None
Applicable Subparts:
Subpart A: Char and Charcoal Briquets
Subpart B: Gum Rosin and Turpentine
Subpart C: Wood Rosin, Turpentine, and Pine Oil
Subpart D: Tall Oil Rosin, Pitch, and Fatty Acids
Subpart E: Essential Oils
Subpart F: Rosin-Based Derivatives
40 CFR Part 454
Gum and Wood Chemicals Manufacturing as
Administered through 40 CFR Part 122: EPA
Administered Permits Programs, The
National Pollutant Discharge Elimination
System
40 CFR PART 454 - DIRECT DISCHARGES
REQUIREMENTS
Discharge Limitations:
Effluent limitations contained in 40 CFR Part
454 including:
- Applicable BPT production-based
limitations (Subparts B, C, D, E, and F)
- Prohibition on discharge of process
wastewater (Subpart A)
Any other effluent limitation contained
wastewater (Subpart A)
COMPLIANCE DATES
Compliance with specific permit limitations
upon effective date of permit.
-------
40 CFR PART 454 - DIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Monitoring and Reporting Requirements:
Note: All direct dischargers are required to
obtain an NPDES permit. The NPDES permit
outlines the dischargers specific monitoring and
reporting requirements.
Permit Applications - containing the
information required under 122.21(1), (g),
and (k) (application requirements for new
sources and new discharges)
Planned Changes - notification to the
Director as soon as possible of any planned
physical alteration or addition that meets the
criteria in 122.41(00)
Anticipated Noncompliance - advance
notification to the Director of any planned
changes that may result in permit
noncompliance
Monitoring Reports - monitoring results must
be submitted as required by the NPDES
permit (at least annually). All monitoring
must be conducted using 40 CFR Part 136
methods.
Compliance Schedules - reports of
compliance or noncompliance with
compliance schedule requirements.
24-Hour Reporting - of any noncompliance
that may endanger health or the
environment, including the information listed
in!22.41(l)(6)
Anticipated and Unanticipated Bypass -
notification as required under 122.41 (m)
Discharge of Toxic Pollutants - notification to
the Director of activity that results in the
discharge of toxic pollutants not limited in the
permit, if it exceeds the levels outlined in
122.42(a)(l)
Permit applications are to be submitted 180
days prior to the commencement of discharge.
Applications for permit renewal are required to
be submitted 180 days before the existing
permit expires.
As soon as possible, when applicable.
In advance of changes, when needed.
At least annually or more frequently by permit.
Within 14 days of each compliance schedule
date.
Within 24 hours
At least 10 days prior to anticipated bypass.
Within 24 hours of unanticipated bypass.
As soon as facility knows or has reason to
believe that levels will be exceeded.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-36
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40 CFR PART 454 - DIRECT DISCHARGES
REQUIREMENTS
Record Keeping Requirements:
Records of monitoring information as
required under 122.41(j) must be kept for at
least three years.
COMPLIANCE DATES
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-37
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
Applicability:
Any gum and wood chemicals
manufacturing facility discharging
process wastewater to a
POTW
40 CFR Part 454
Gum and Wood Chemicals Manufacturing as
Administered through 40 CFR Part 403:
General Pretreatment Regulations for Existing
and New Sources of Pollution
40 CFR PART 454 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Discharge limitations:
Prohibited discharge standards (general and
specific) in 40 CFR 403.5
Applicable local limits
Monitoring and Reporting Requirements:
Periodic Compliance Reports
Notice of Potential Problems Including Slug
Loads
Notice of Changed Discharge - Advanced
notification of any substantial change in the
volume or character of pollutants in the
discharge (including hazardous wastes)
Notification of Hazardous Waste Discharge -
notification to the POTW, EPA, and the State
of the hazardous wastes discharged to the
POTW
Record Keeping Requirements:
Monitoring records including the information
listed in 403.12 (o) must be maintained for at
least 3 years.
As required by permit.
As required by permit.
Due to the Control Authority immediately upon
identification of discharges that could cause
problems to the POTW
Prompt notification in advance of any substantial
change.
One time notification, unless changes to the
discharge.
s
a
I
i
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-39
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-4-D
-------
Applicability:
Discharge from the
manufacture of pesticide
chemicals (text in italics relates
to April 14, 1994, proposed
regulations)
40 CFR Part 455
Pesticide Chemicals as Administered through
40 CFR Part 122: EPA Administered Permits
Programs, The National Pollutant Discharge
Elimination System
455.20 (Subpart A) specifies effluent limitations for the manufacture of listed organic
pesticide active ingredients.
455.30 (Subpart B) applies to discharges from the manufacture of metallo-organic active
ingredients containing mercury, cadmium, arsenic, or copper.
455.40 (Subpart C) does not apply to wastewater discharges from employee showers, fire
equipment test, and laundry facilities. Discharges resulting from the formulating, packaging
or repacking of bleach is also exempt.2
Exemptions:
None
Applicable Subparts
Subpart A: Organic Pesticide Chemicals
Subpart B: Metallo-Organic Pesticide Chemicals
Subpart C: Pesticide Chemicals Formulation and Packaging and Repacking
8J
Subpart D: Test Methods for Pesticide Pollutants tS
Subpart E: Repackaging of Agricultural Pesticides Performed by Refilling Establishment Whose i
Principal Business is Retail Sales \^
10
t!
2
The June 8, 1995 (Pesticide Chemicals) supplemental notice to the proposed April 1994 rule also exempts
wastewater from safety showers and eye washers, storm water, DOT aerosol leak test bath water (batch), and r-"s
laboratory wastewater from cleaning analytical equipment. The supplemental notice also includes exception of
wastewater discharges from formulation, packaging, and/or repacking of sanitizer products, pool chemicals, and
microorganisms and mixtures.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-4 1
-------
40 CFR PART 455 - DIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Discharge limitations
Effluent limitations contained in 40 CFR Part
455 including:
- BPT, BCT, and NSPS limits for COD,
BOD, TSS, organic pesticide chemicals,
and pH (Subpart A)
- BAT and NSPS limits for pesticide active
ingredients listed in Table 2 or Table 3 of
40 CFR Part 455 if that pesticide active
ingredient is manufactured and listed in
Table 1 of 40 CFR Part 455 (Subpart A)
- BAT and NSPS limits for priority
pollutants listed in Table 4 (if end-of-pipe
biological treatment is used) and 5 (if end-
of-pipe biological treatment is used) of 40
CFR Part 455, if the facility manufactures
a pesticide active ingredient listed in Table
1 (Subpart A)
- No discharge of process wastewater
pollutants (Subparts B, C, and E)3
Existing sources: 9/28/96 (under existing
regulations), as required by permit.
New sources: Date source begins operation, as
required by permit.
Compliance with specific permit limitations
upon effective date of permit.
The June 8, 1995 (Pesticide Chemicals) supplemental notice to the proposed April 1994 rule provides a
Pollution Prevention Alternative for facilities regulated under Subpart C and proposed Subpart E. In lieu of
meeting the zero discharge of process wastewater requirement, these facilities could demonstrate that the
requirements of the Pollution Prevention Alternative listed in Tables B-l and B-2 are met, notify the NPDES
permit writer or pretreatment authority, and keep necessary paperwork onsite.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-42
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40 CFR PART 455 - DIRECT DISCHARGES (CONTINUED)
REQUIREMENTS
COMPLIANCE DATES
Monitoring and Reporting Requirements:
Note: All direct discharges are required to
obtain an NPDES permit. The NPDES permit
outlines the dischargers specific monitoring and
reporting requirements.
Permit Applications - containing the
information required under 122.21(1), (g),
and (k) (application requirements for new
sources and new discharges)
Planned Changes - containing the
information required under 122.21(1), (g),
and (k) (application requirements for new
sources and new discharges)
Anticipated Noncompliance - notification to
the Director as soon as possible of any
planned physical alternation or addition that
meets the criteria in 122.41(1)(1)
Monitoring Reports - monitoring results
must be submitted as required by the
NPDES permit (at least annually) (. All
monitoring must be conducted using 40 CFR
Part 136 methods.
Discharge parameter values must be
determined using the analytical methods in
Table 7 of 40 CFR part 455
Compliance Schedules - reports of
compliance or noncompliance with
compliance schedule requirements
24-Hour Reporting - of any noncompliance
that may endanger health or the
environment, including the information listed
in!22.41(l)(6)
Anticipated and Unanticipated Bypass -
notification as required under 122.41 (m)
Permit applications are to be submitted 180
days prior to the commencement of discharge.
Applications for permit renewal are required to
be submitted 180 days before the existing
permit expires.
As soon as possible, when applicable.
In advance of changes, when needed.
At least annually or more frequently as required
by permit.
Within 14 days of each compliance schedule
date
Within 24 hours
At least 10 days prior to anticipated bypass.
Within 24 hours of unanticipated bypass.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-43
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40 CFR PART 455 - DIRECT DISCHARGES (CONTINUED)
REQUIREMENTS
COMPLIANCE DATES
Discharge of Toxic Pollutants - notification to
the Director of activity that results in the
discharge of toxic pollutants not limited in the
permit, if it exceeds the levels outlined in
122.42(a)(l)
Storm Water Permit Applications -
submission of either individuals permit
application or general permit applications
- Individual permit applications must include
the information in 122.26(c)(l)
Facilities to be covered under a general
permit must file a Notice of Intent (NOI)
Other Storm Water Reports - submission of
other reports as required under a facility's
storm water discharge permit. These
reports may include pollution prevention
plans and monitoring reports.
Record Keeping Requirements:
Records of monitoring information as
required under 122.41(j) must be kept for at
least three years.
As soon as facility knows or has reason to
believe that levels will be exceeded
Individual permit applications for existing facilities
were due October 1, 1992. New facilities
must submit an application 180 days prior to
commencement of industrial activity.
NOIs from existing facilities were due on
October 12, 1992. NOIs from new facilities
are due 2 days prior to the commencement of
industrial activities.
Due dates as required by permits
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-44
-------
Applicability:
Any pesticide chemical
manufacturing facility discharging
process wastewater to a
POTW
40 CFR Part 455
Pesticide Chemicals as Administered through
40 CFR Part 403: General Pretreatment
Regulations for Existing and New Sources of
Pollution
40 CFR PART 455 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Discharge limitations
Limitations contained in 40 CFR Part 455 including:
- PSES and PSNS limits for pesticide active
ingredients listed in Table 2 or Table 3 of 40 CFR
Part 455, if that pesticide active ingredient is
manufactured and listed in Table 1 (Subpart A)
- PSES and PSNS limits for priority pollutants listed in
Table 6 of 40 CFR Part 455 (Subpart A)
- No discharge of process wastewater pollutants
(Subparts C and Ł)4
Monitoring and Reporting Requirements:
Note: Reports must be submitted whether or not the
facility has been issued a permit.
Baseline Monitoring Reports (BMR) - containing the
information required under 40 CFR 403.12 (b).
PSES: 9/28/96 (under current
regulations), as required by
permit
PSNS: Date new source begins
operation, as required by
permit
BMRs from existing sources are due
within 180 days of effective date of
categorical pretreatment standard for
BMRs from new sources are due 90
days prior to commencement of
discharge.
"5
a
I
The June 8, 1995 (Pesticide Chemicals) supplemental notice to the proposed April 1994 rule provides a
Pollution Prevention Alternative for facilities regulated under Subpart C and proposed Subpart E. In lieu of
meeting the zero discharge of process wastewater requirement, these facilities could demonstrate that the
requirements of the Pollution Prevention Alternative listed in Tables B-l and B-2 are met, notify the NPDES
permit writer or pretreatment authority, and keep necessary paperwork onsite.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
I!
I
F-45
-------
40 CFR PART 455 - INDIRECT DISCHARGES
REQUIREMENTS
COMPLIANCE DATES
Compliance Schedule Progress Reports - containing
the information required under 40 CFR 403.12(c)(3)
90-Day Compliance Report - containing the
information required under 40 CFR 403.12(d)
Periodic Reports on Continued Compliance -
containing the information in 403.12(e) (including
monitoring data for all categorically regulated
pollutants). All monitoring must be conducted using
40 CFR Part 136 methods.
Notice of Potential Problems Including Slug Loadings
Notice of Changed Discharge - advanced notification
of any substantial change in the volume or character of
pollutants in the discharge (including hazardous wastes)
Notice of Violations and Resampling - notification due
to the Control Authority within 24 hours of noting a
violation; results of resampling must be submitted
within 30 days
Notification of Hazardous Waste Discharge -
notification to the POTW, EPA, and the State of the
hazardous wastes discharged to the POTW
Record Keeping Requirements
Monitoring records including the information listed in
403.12(o) must be maintained for at least 3 years
Due within 14 days of completing
compliance schedule milestone or due
date
Due within 90 days following date for
final compliance or for new sources
following the commencement of
introduction of wastewater to the
POTW
Must be submitted at least
semiannually
Due to the Control Authority
immediately upon identification of
discharges that could cause problems
to the POTW
Prompt notification in advance of any
substantial change
Notice within 24 hours, results of
resampling within 30 days
One time notification, unless changes
to discharge
a
10
10
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-46
-------
40 CFR Part 110
Discharge of Oil
Applicability:
Prohibited discharges include
certain discharges to U.S.
Navigable water, adjoining
shorelines, or to waters of the contiguous zone, occurring in connection with activities under
the Outer Continental Shelf Lands Act of the Deepwater Port Act, or those that may affect
U.S. natural resources.
May be applicable to OCPSF facilities using oil and that are either located by a municipal storm
sewer that discharges to waters or near streams or bodies of water.
40 CFR PART 110
REQUIREMENTS
COMPLIANCE DATES
Discharge of oil is prohibited that:
- Violates applicable water quality
standards, or
- Causes a film or sheen upon or
discoloration of the surface of the water
or adjoining shorelines or causes a sludge
or emulsion to be deposited beneath the
surface of the water or upon the adjoining
shorelines
Notification must be provided immediately
to the National Response Center at (800)
424-8802 or (202) 426-2675 in the
Washington, DC, metropolitan area of any
discharge of oil in violation of the prohibition
t!
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-47
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. F-4-8
-------
40 CFR Part 112
Oil Pollution Prevention
Applicability:
Non-transportation related
onshore and off-shore facilities
engaged in drilling, producing,
gathering, storing, processing, refining, transferring, distributing, or consuming oil and oil
products that could reasonably discharge oil in harmful quantities, as defined in Part 110
Exemptions
Facilities with underground buried oil storage capacity of < 42,000 gallons; and
Storage capacity that is not buried < 1,320 gallons, with no single container capacity > 660
gallons
40 CFR PART 112
REQUIREMENTS
COMPLIANCE DATES
Reporting Requirements:
Prepare and implement Spill Prevention Control
and Countermeasure plans meeting the
requirements of 112.3 and 112.7
Submit report as described in 112.4 when
discharged oil > 1,000 gallons in single spill
event or discharged oil in harmful quantities
in two spill events
Review, evaluate, and update plan as
required under 112.5
Submit facility response plan as described in
112.20 and develop and implement facility
response training and drill exercise as
described in 112.21
Existing sources: Plans in effect
New sources: Prepare plan within 6 months of
beginning operation and fully implement in no
later than 1 year
Within 60 days of becoming subject to reporting
requirements
Review plan once every 3 years, amend plan
within 6 months, if needed
Existing sources: as described in 112.20
New source: prior to start of operations
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-49
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. p_ en
-------
40 CFR Part 116 and 117
Designation of Hazardous Substance and 40
CFR Part 117 Determination of Reportable
Quantities for Hazardous Substances
Applicability:
40 CFR Part 117 does not
apply to facilities that discharge
the substance under an NPDES
permit or to a POTW, as long
as any applicable effluent limit
or pretreatment standard is met.
Requirements:
40 CFR 116.4 designates hazardous substances and 40 CFR 117.3 establishes the Reportable
Quantity (RQ) for each substance listed in Part 116. When an amount equal to or in excess
of the RQ is discharged, the facility must provide notice to the Federal government following
DOT requirements in 33 CFR 153.203.
I
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F-51
-------
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
-------
I
Appendix G Toxic Substances
Control Act (TSCA)
The Toxic Substances Control Act (TSCA) authorizes EPA to test chemicals prior to and after
introduction into commerce based on their potential human health and environmental effects
and to regulate these chemicals at any point during the chemicals' life cycles as necessary to
minimize risks to human health and the environment. TSCA authorizes EPA to regulate the
manufacturing, processing, distribution in commerce, use, and disposal of chemical substances
and mixtures. The term "chemical substance" is broadly defined under TSCA to include
organic and inorganic chemicals, with several exclusions. Namely, pesticides, tobacco and
tobacco products, nuclear material and byproducts, food, food additives, drugs, cosmetics, or
devices (as defined in Section 201 of the Federal Food, Drug, and Cosmetic Act) are not
subject to TSCA requirements.
While TSCA is composed of four Titles, the inspection information in this guidance is only
described for the control and regulation of chemical substances and mixtures (i.e., Title I).
The major requirements that have the potential to impact chemical facilities are summarized
below. The detailed regulatory requirements are provided later in this appendix.
Testing - §4
Section 4 provides EPA the authority to require (by rule) that testing be conducted by
manufacturers, importers, or processors of a chemical substance or mixture. The purpose of
such testing is to allow EPA to determine if manufacturing, distribution, processing, use or
disposal of the chemical
substance or mixture presents an
unreasonable risk to health or the Toxic Substances Control Act (TSCA)
environment. Another objective
of TSCA §4 is that facilities Testing" §4 G~l
, Premanufacture Notice Requirements - §5 G-3
comply with Good Laboratory TT . K^t \^\ r o
r J J Significant New Uses of Chemical Substances - §5 (a) (2) . . G-3
Practice (GLP) standards which
represent the quality control
aspects of a TSCA §4 test rule.
In general, 40 CFR Parts 790-799
be performed and results and
Hazardous Chemical Substances and Mixtures - §6 G-4
Record Keeping and Reporting Requirements - §8 (a) G-5
Significant Adverse Reactions - §8(c) G-6
Health and Safety Data Reporting - §8(d) G-6
regulations provide the Notification of Substantial Risks - §8(e) . G-7
° , , ., , Chemical Exports and Imports - §§12 and 13 G-7
guidelines on how tests are to
TSCA Assessment Considerations G-8
TSCA Regulatory Requirements G-9
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> i
-------
Exhibit G-1. TSCA Statutes and Regulatory Requirements for Organic
Chemical Facilities
Toxic Substances Control Act
Section 4 Testing of Chemical Substances and Mixtures
Section 5 Manufacturing and Processing Notices
Section 6 Regulation of Hazardous Substances and Mixtures
Section 8 Reporting and Retention of Information
Section 12 & 13 Exports and Imports
Section 4
40 CFR Parts 790-799
Section 5
40 CFR Part 720
Premanufacture
Notification
40 CFR Part 721
Significant New Uses
of Chemical Substances
Section 6
40 CFR Part 747 Metal Working
Fluids
40 CFR Part 749 Water Treatment
Chemicals
40 CFR Part 750 Procedures for
Rulemaking Under TSCA Section 6
40 CFR Part 761 Polychlorinated
Biphenyls
40 CFR Part 762 Fully Halogenated
Chlorofluoro Alkanes
40 CFR Part 763 Asbestos
Sections 12 & 13
40 CFR Part 707 Chemical
Imports and Exports
Section 8
40 CFR Part 704 Reporting and
Record Keeping Requirements
40 CFR Part 710 Inventory Reporting
Regulations
40 CFR Part 712 Chemical
Information Rules
40 CFR Part 716 Health and Safety
Data Reporting
40 CFR Part 717 Records and
Reports of Allegations that
Chemical Substances Cause
Significant Adverse Reactions to
Human Health or the Environment
43 FR Part 11110 Policy Statement
procedures documented, and develops standards for all laboratories to follow. The rules
establish procedures for gathering information, developing and implementing test rules or
consent agreements regarding chemicals regulated under TSCA §4 and establishing
reimbursement for testing costs incurred under TSCA; codify GLPs for conducting studies and
guidelines for health effects, environmental effects, and chemical fate testing; and identify the
chemical substances and mixtures for which data must be developed, and the specific tests
required for each substance and mixture.
Also pursuant to §4, as well as §8, are the Federal regulations at 40 CFR Part 766. This part
identifies testing and reporting requirements for facilities that manufacture (and/or import) or
process specific chemical substances identified in 40 CFR §766.25 or a chemical substance
from a precursor chemical substance identified in 40 CFR §766.38. EPA has found that these
specific chemical substances may be contaminated with halogenated dibenzodioxins or
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
G-2
-------
dibenzofurans. The applicable TSCA titles and the regulations developed pursuant to TSCA
are illustrated in Exhibit G-l and are discussed below.
Premanufacture Notice Requirements - §5
Manufacturers and importers of new chemical substances are required to comply with
Premanufacture Notice (PMN) procedures and requirements as identified in 40 CFR Part
720. [PMN exemptions are itemized in 40 CFR Part 723.] New chemicals include any
chemical substance not listed on the TSCA Inventory, as maintained pursuant to §8(b) of
TSCA.
Manufacturers of chemicals that are not excluded or exempt from TSCA requirements or
from the PMN requirements must submit a PMN at least 90 days prior to commencing
commercial manufacturing or importing activities. Information that must be provided on the
PMN to the extent that it is known or reasonably ascertainable includes the submitter's
identity; the specific chemical identity; production, import, and use; worker, user, and
consumer exposure; and environmental fate.
EPA must review and take action on the PMN within 90 days (may be extended to 180 days
for cause), and if no action is taken, the submitter may commence manufacture or
importation. Based on the PMN submission, EPA may issue a proposed order pursuant to
§5(e) to prohibit or limit the manufacture, import, processing, distribution in commerce, use
and/or disposal if the available information is insufficient to permit a reasoned evaluation of the
health or environmental effects of the substance. TSCA §5(1) also provides EPA with the
authority to issue an order or propose a rule to limit or condition the manufacture,
processing, distribution in commerce, use and/or disposal, if there is a reasonable basis to
conclude that such activities would pose an unreasonable risk to health or the environment.
Within 30 days after commencing the manufacture or import, the manufacturer or importer
must submit a Notice of Commencement (NOC). This NOC prompts the addition of the
chemical substance to EPA's TSCA Inventory.
Significant New Uses of Chemical Substances - §5 (a) (2)
Reporting requirements for chemical facilities that manufacture, import, or process chemical
substances that EPA determines have significant new uses are identified in 40 CFR Part 721
pursuant to TSCA §5(a)(2). Chemical facilities that manufacture, import, or process a
chemical substance for a use that EPA has determined is a significant new use, as identified in
40 CFR Part 721, Subpart E, must submit a Significant New Use Notice (SNUN) 90 days
prior to such activity. A SNUN is equivalent to a PMN and is even submitted on the same
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P_
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form. Chemical facilities that submit a SNUN are required to maintain SNUN documentation
for at least 5 years.
EPA can apply any of five categories of standardized significant new uses as identified in 40
CFR Part 721, Subpart B to any existing chemical. These categories include:
> Protection in the workplace,
* Hazard communication program,
> Industrial, commercial, and consumer activities,
* Disposal, and
> Release to water.
As such, EPA can define certain actions or omissions of an action to be a significant new use.
For example, failure to use impervious gloves where the worker is reasonably likely to be
exposed could constitute a significant new use.
Subpart C of 40 CFR Part 721 establishes additional recordkeeping that EPA may impose on
chemical manufacturers, importers, and processors of specific chemical substances with
significant new uses. The specific recordkeeping requirements identified in 40 CFR §721.125
only apply as identified in Subpart E individually for each specific chemical substance with a
significant new use.
In addition, the authorities provided to EPA [§5(e) and §5(f) as discussed above] also are
applicable to SNUNs.
Hazardous Chemical Substances and Mixtures - §6
EPA has promulgated several regulations under TSCA specific to an individual chemical or
class of chemicals. It is possible that a chemical facility may be subject to one or more of
these regulations; however, the discussion regarding these regulations is limited in this
guidance. Facilities that meet the applicability of any of these regulations must be evaluated
against the specific requirements. Chemical-specific regulations are as follows:
Metalworking Fluids
Facilities that produce or use metal working fluids or produce a product that could be used in
or as a metalworking fluid containing any of the following chemical substances are subject to
use limitations and warnings/instructions requirements under 40 CFR Part 747: mixed mono
and diamides of an organic acid, triethanolamine salt of a substituted organic acid,
triethanolamine salt of a tricarboxylic acid, and tricarboxylic acid.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P_4
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Water Treatment Chemicals
Federal regulations at 40 CFR Part 749 prohibit the use of hexavalent chromium (usually in
the form of sodium dichromate) in comfort cooling towers (i.e., cooling towers that are
dedicated exclusively to and are an integral part of heating, ventilation, and air conditioning or
refrigeration systems).
Polychlorinated Biphenyls (PCBs)
Facilities that manufacture, process, distribute, use, dispose, or store PCBs must comply with
regulations established in 40 CFR Part 761. These regulations identify storage, disposal, spill
cleanup, disposal, labeling, recordkeeping, and reporting requirements.
Fully Halogenated Chlorofluoroalkanes
Federal regulations at 40 CFR Part 762 prohibit the manufacture, processing, or distribution in
commerce of fully halogenated Chlorofluoroalkanes for specific aerosol propellant uses which
are subject to TSCA. The 40 CFR Part 762 regulations specify exemptions to the prohibitions
and annual reporting requirements.
Record Keeping and Reporting Requirements - §8 (a)
Under Section 8(a), EPA has the authority to establish, by rule, recordkeeping and reporting
requirements for manufacturers, importers, and processors of chemical substances. To date,
EPA has established three such rules: the Preliminary Assessment Information Rule (PAIR), the
Comprehensive Assessment Information Rule (CAIR) and the Inventory Update Rule (IVR).
The CAIR requirements were rescinded in 1995.
The PAIR requires manufacturers and importers to submit a 2-page form with information
about any chemical listed in 40 CFR §712.30. The PAIR may be submitted through company
headquarters or the site where the chemical is being manufactured or imported, but a
separate form is required for each site where the chemical is being manufactured or
imported. The major elements of the PAIR form include the quantity of chemical
manufactured or imported for sale or use, the quantity lost to the environment and in wastes,
manufacturing processes and worker exposure, customer uses and products, trade names
and customer's process categories. Specific reporting dates are identified individually for each
chemical substance in 40 CFR §712.30.
IUR requires manufacturers and importers of chemicals on the TSCA Inventory to report
current data on chemical identity, production volume, plant site, and site-limited status (unless
exempt). Regulated facilities include those that manufacture at, or import to, any single site
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> _ c
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10,000 pounds or more during the latest complete corporate fiscal year immediately prior to
the reporting period. Reporting requirements include an initial report following by recurring
reports at four-year intervals thereafter. Regulated facilities must retain records for a period of
four years beginning with the effective date of that reporting period.
Significant Adverse Reactions - §8(c)
Section 8(c) of TSCA, codified at 40 CFR Part 717, establishes requirements for
manufacturers and processors as specified in 717.5(b), chemical substances and mixtures to
keep records of significant adverse reactions to health or the environment alleged to have
been caused by the substance or mixture and to permit inspection and submit copies of such
records as requested by EPA.
Manufacturers and processors (including formulators and repackagers) are required to
compile allegations regarding chemicals that are manufactured or processed. Certain
manufacturers are exempt from this part if the chemical substance meets one of the
conditions specified in 40 CFR §717.7(a), including, but not limited to manufacture of
chemical substances that result from incidental chemical reactions, chemical substances that
occur incidental to storage or disposal of other chemical substances, and chemical substances
that result from chemical reactions that occur upon end use of other chemical substances,
mixtures, or articles (e.g., adhesives, paints).
An allegation may be written or oral and consists of a statement made from any source,
without formal proof or evidence, that a chemical substance or mixture has caused a
significant adverse reaction to health or the environment. Known human health effects are
exempt from these requirements as are environmental impacts that are directly attributable to
a spill, discharge, permit violation, or other incident that must by law be reported to the
Federal government. Records of significant adverse reactions are to be kept at the firm's
headquarters or at any other appropriate location central to the firm's chemical operations.
These records must be retained for 30 years for employee allegations or 5 years for other
allegations.
Health and Safety Data Reporting - §8(d)
Chemical facilities that manufacture, import, or process, or propose to manufacture, import,
or process a substance or mixture listed in 40 CFR §716.120 are required to submit any
unpublished health and safety studies, as described in 40 CFR §716.3, pursuant to TSCA
§8(d). Reports on these studies must be submitted on, or subsequent to, the date the
substance was listed, as well as any studies conducted for 10 years prior to the substance
being listed. These reports are due 60 days after the effective date of the listing of a substance
or listed mixture or within 60 days of proposing to manufacture, import, or process one of
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P_fi
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these substances or mixtures. Several exemptions exist at 40 CFR §716.20 for the
submission of studies that have already been submitted.
Persons manufacturing, importing, or processing, or proposing to manufacture, import, or
process, the substances and mixtures identified in 40 CFR §716.120 must also submit, subject
to exclusions, lists of studies that are ongoing, initiated, known but not in possession, and
unpublished studies sent to a Federal agency without a claim of confidentiality. Lists of
initiated studies must be submitted within 30 days of initiation while copies of ongoing studies
must be submitted within 30 days of completing the study.
Notification of Substantial Risks - §8(e)
A chemical facility that (1) manufactures, imports, processes, or distributes in commerce a
chemical substance or mixture, and (2) obtains information that reasonably supports the
conclusion that such substance or mixture presents a substantial risk of injury to health or the
environment, must immediately report that information to EPA pursuant to the self-
implementing provisions of TSCA §8(e). EPA considers "immediate" to be within 15 days for
non-emergency situations and 24 hours for emergency situations. In general, the chemical
industry derives its §8(e) report from two sources: (1) results of human, animal, and
environmental studies, and (2) incidents involving chemicals, mixtures, effluents, or processes.
Records are not required to be maintained pursuant to §8(e).
Chemical Exports and Imports - §§12 and 13
Pursuant to 40 CFR Part 707, Subpart B, chemical facilities that import chemical substances,
mixtures, or articles must comply with TSCA rules or are in violation. Under U.S. Customs
Service rules (19 CFR §12.121), importers must certify either that the importation is being
undertaken in compliance with TSCA requirements or that it is not subject to such
requirements. Since TSCA Section 13 defines manufacturers as importers, importers may
also be subject to TSCA testing requirements.
TSCA §12 and Subpart D of 40 CFR Part 707 identifies applicable regulations for exporters.
Specifically, any person who exports or intends to export a chemical substance or mixture
must submit a notice of export to EPA in writing if any of the following actions have been
undertaken with respect to that chemical or mixture:
> Data are required under TSCA §4 (Testing) or §5(b) (Submission of Test
Data),
> An order has been issued under TSCA §5 (Manufacturing and Processing
Notices),
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P_7
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> A rule has been proposed or promulgated under TSCA §5 or §6 (Hazardous
Chemical Substances), or
> An action is pending or relief has been granted under TSCA §5 or §7
(Imminent Hazards).
Export notices are required for the first export to each country in each calendar year (except
for TSCA §4, that requires one-time notification only). Subpart D of 40 CFR Part 707
specifies the timing and contents of these notices which must be postmarked within 7 days of
acceptance of a definite contractual obligation to export. Where the actual export occurs less
than 7 days after the export obligation, the notice must be submitted to EPA no later than the
same day as the export.
TSCA Assessment Considerations
TSCA regulations focus specifically on manufacturing, importing, or processing chemical
substances and mixtures, making this statute of primary importance to chemical facilities. A
self-assessment of a chemical facility to determine compliance with TSCA requires that the
assessor be familiar, at least in general, with all regulations developed under the Act. Because
of the focus of TSCA on chemical substances and mixtures, inspection guidance, namely the
Toxic Substance Control Act §§5/8 Inspection Guidance, U.S. EPA, November 1992, is an
excellent industry-specific resource when evaluating compliance with Title I requirements at
chemical facilities. Also, it is helpful for the assessor team to have lists of chemical substances
regulated by the Act. In this way, the assessor can identify activities that may trigger TSCA
regulatory requirements during pre-inspection activities and the self-assessment.
The key to a successful TSCA self-assessor is a comprehensive pre-assessment records
review. Assessor should be aware that many TSCA reports may be submitted by the firm,
corporate headquarters, or office for the manufacturing facility as opposed to the specific
manufacturing plant submitting this information. It is also important for the assessment to
ascertain from facility representatives if the chemical facility is aware of requirements under
TSCA. One of the biggest reasons for TSCA violations is ignorance of the specific
requirements.
It may also be useful for an assessor to target one or more specific TSCA regulations that are
likely to apply at a facility rather than attempting to evaluate compliance with all requirements.
For example, specialty organic chemical manufacturers may manufacture hundreds of different
products, using hundreds of different raw materials. Attempting to evaluate compliance with
all applicable TSCA requirements at these types of facilities can be extremely time consuming.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> o
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One of the most egregious TSCA violations is failure to submit a PMN. The purpose of the
PMN is to provide EPA with the opportunity to determine whether the uncontrolled
manufacture, importation, processing, use, distribution in commerce, or disposal will present
an unreasonable risk of injury to health and the environment. Failure to submit the PMN
prevents EPA from making this critical evaluation. As such, an inspection team may try to
focus only on new chemicals and determine if TSCA §5 requirements are being met.
Focusing on high risk chemicals during compliance assessments is also a useful mechanism for
targeting TSCA compliance evaluations. Knowledge of the chemical substances regulated by
PAIR addresses this concern to a certain extent. Also, the Interagency Testing Committee
(ITC) as established by TSCA §4(e), as well as EPCRA Section 313, the CAA Amendments,
and the CWA (i.e., priority pollutants) represent additional sources for identifying high-risk
chemicals. High risk chemicals may also be identified by the inspection team based on the
health and safety precautions that are being taken at the chemical facility for specific process
operations or production areas.
TSCA Regulatory Requirements
The following sections provide a summary of the principal regulations developed pursuant to
TSCA that are applicable to the organic chemical industry. The regulations included are:
> TSCA Section 4 - 40 CFR Parts 790-799 - Subchapter R - Toxic Substance
Control Act
* TSCA Section 5(a)(l) - 40 CFR Part 720 - Premanufacture Notification
> TSCA Section 5 (a) (2) - 40 CFR Part 721 - Significant New Uses of Chemical
Substances
> TSCA Section 5(c) - Regulation Pending Development of Information
> TSCA Section 5(f) - Protection Against Unreasonable Risks
> TSCA Section 6
- 40 CFR Part 747 - Metalworking Fluids
- 40 CFR Part 749 - Water Treatment Chemicals
- 40 CFR Part 750 - Procedures for Rulemaking under TSCA Section 6
- 40 CFR Part 761 - Polychlorinated Biphenyls
- 40 CFR Part 762 - Fully Halogenated Chlorofluoroalkanes
- 40 CFR Part 763 - Asbestos
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P _Q
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TSCA Section 8(a) - 40 CFR Part 704 - Reporting and Recordkeeping
Requirements
- Subpart A General Provisions
- Subpart B Chemical Specific Rules
TSCA Section 8(a) PAIR - 40 CFR 712 - Chemical Information Rules
- Subpart B Manufacturers Reporting - Preliminary Assessment Information
TSCA Section 8(a) IUR - 40 CFR Part 710 - Inventory Reporting Regulations
TSCA Section 8(c) - 40 CFR Part 717 - Records and Reports of Allegations that
Chemical Substances Cause Significant Adverse Reactions to Human Health or
the Environment
TSCA Section 8(d) - 40 CFR Part 716 - Health and Safety Data Reporting
TSCA Section 8(e) - 43 FR Part 11110 - Policy Statement
TSCA Section 12-40 CFR Part 707 - Chemical Imports and Exports
- Subpart D Notices of Export Under Section 12(b)
TSCA Section 13-40 CFR Part 707 - Chemical Imports and Exports
- Subpart B General Import Requirements and Restrictions
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. C -1 f)
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TSCA Section 4 - 40 CFR
Parts 790-799
Subpart R - Toxic Substance Control Act
Affected Facility:
Persons that manufacture or
intend to manufacture and/or
process or intend to process a
substance subject to a test rule
or testing requirements of a consent agreement.
Date of Applicability:
Substance-specific
Exemptions:
Persons who manufacture less than 500 kg annually must comply only if directed to do so
by notice or test rule
Persons who manufacture small quantities solely for research and development must
comply only if directed to do so by notice or test rule
Affected Chemicals:
1) Chemicals listed in 40 CFR 799 ~L
0}
2) Also, dibenzo-para-dioxins and dibenzofurans (40 CFR 766)
^
Requirements: cx3
1) Submit letter of intent to conduct testing or exemption application no later than 30 days
of date of test rule
2) If a letter of intent is submitted, conduct tests listed in 40 CFR 799 for appropriate
substance
3) If testing is conducted, comply with Good Laboratory Practice Standards (40 CFR 792) ,
including retention of records for 10 years ^
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This manual is intended solely for guidance. No statutory or regulatory
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This manual is intended solely for guidance. No statutory or regulatory
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TSCA Section 5(a)(l) - 40 CFR
Part 720
Premanufacture Notification
Affected Facility:
Persons who intend to
manufacture or import a new
chemical substance into the
U.S. for commercial purposes,
or who contract with a manufacturer as outlined in 40 CFR 720. 22 (a) (2).
Date of Applicability:
July 12, 1983
Exemptions:
As listed in 40 CFR 720.30, 720.36, 720.38 and 40 CFR 723 (low volume, test marketing,
instant photographic film, and polymers)
Affected Chemicals:
New chemical substances; i.e., substances not listed on the Inventory
Requirements: *g
1) Submit Premanufacture Notification (PMN) at least 90 days before manufacture or import
2) PMN to include information in Subpart C, and test data as outlined in 40 CFR 720.50
3) Submit Notice of Commencement (NOC) no later than 30 days after commencement of
manufacture or import
Record Keeping Requirements:
Keep records described in 40 CFR 720.78 for 5 years ^^
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> i o
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. C -1 4
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TSCA Section 5(a) (2) - 40 CFR
Affected Facility:
7? 1
Persons who: a""c '^ą
Significant New Uses of Chemical Substances
1) Intend to manufacture,
import or process for
commercial purposes a chemical substance identified in Subpart E, and
2) Engage in a significant new use of the substance or intend to distribute the substance in
commerce [subject to the exemption outlined in 40 CFR 721.5 (a) (2)].
Date of Applicability:
Substance-specific
Exemptions:
As specified in 40 CFR 721.45
Affected Chemicals:
Chemical substances identified in 40 CFR 721 Subpart E
Requirements:
Submit Significant New Use Notice (SNUN) at least 90 days before commencing
manufacture, import, or processing, using Appendix A of 40 CFR 720, and including test data
specified in Section 5(d)(l)
Record Keeping Requirements:
5 years
§
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> i c
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. C -1 fi
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TSCA Section 5(e)
Regulation Pending Development of
Information
Affected Facility:
Persons engaged in, or
intending to engage in,
manufacture, processing,
distribution in commerce, use,
or disposal of the substance.
Date of Applicability:
Substance-specific
Exemptions:
None
Affected Chemicals:
As stated in order or injunction
Requirements:
Comply with order or injunction (in response to a PMN or SNUN) prohibiting or limiting the
manufacture, processing, distribution in commerce, use, or disposal of a specific substance
10
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> i o
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TSCA Section 5(f)
Affected Facility:
Protection Against Unreasonable Risks
Persons engaged in, or
intending to engage in,
manufacture, processing, or distribution in commerce of the substance
Date of Applicability:
Substance-specific
Exemptions:
None
Affected Chemicals:
As stated in order or injunction
Requirements:
1) Comply with order or injunction (in response to a PMN or SNUN) prohibiting the
manufacture, processing, or distribution in commerce of a specific substance, or
2) Comply with proposed rule issued under Section 6(a), effective as of publication, limiting
the amount of a specific substance that may be manufactured, processed, or distributed in
commerce, or requiring one or more actions from Section 6(a)(2) through (7)
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requirements are in any way altered by any statements) contained herein. C - 1 Q
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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TSCA Section 6 - 40 CFR Parts
747, 749, 750, 762, 763
Affected Facility:
Persons engaged in, or
intending to engage in,
manufacture, processing, or
distribution in commerce of the substance
40 CFR Part 747 - Metalworking Fluids
40 CFR Part 749 - Water Treatment Chemicals
40 CFR Part 750 - Procedures for Rulemaking under TSCA Section 6
40 CFR Part 761 - Polychlorinated Biphenyls (PCBs) Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions
40 CFR Part 762 - Fully Halogenated Chlorofluoroalkanes
c\
40 CFR Part 763 - Asbestos
Date of Applicability:
Varies based on rule.
Exemptions:
None
Affected Chemicals:
As stated in order or rule. Includes:
PCBs (40 CFR 761)
Fully halogenated Chlorofluoroalkanes (40 CFR 762)
Asbestos (40 CFR 763)
Metalworking fluids (40 CFR 747)
Hexavalent chromium (e.g., sodium dichromate) (40 CFR 749)
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P_? 1
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Requirements:
Dependent on substance-specific rule or order:
Comply with prohibition against or limits on manufacturing, processing, or distributing in
commerce
Comply with prohibition against manufacturing, processing, or distributing in commerce
for a particular use or a particular use above a specified concentration
Label substances or articles with adequate warnings and instructions
Make and retain records or processes used and monitor or test to assure compliance
with rule
Comply with prohibitions or regulations on specified commercial uses
Comply with prohibitions or regulations on specified methods of disposal
Give notice of risks to distributors, persons in possession of substance, and general
public, and replace or repurchase substance
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. C -99
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TSCA Section 8(a) - 40 CFR
Part 704
Reporting and Requirements
Subpart A - General Provisions
Subpart B - Chemical Specific Rules
Affected Facility:
Manufacturers, importers, and
processors
Date of Applicability:
Substance-specific
Exemptions:
As in 40 CFR 704.5
Affected Chemicals:
Chemical substances listed in 40 CFR 704 Subpart B
Reporting and Record Keeping Requirements:
Dependent on chemical
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. C-/M
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TSCA Section 8(a) PAIR - 40 CFR
Part 712
Chemical Information Rules
Subpart B - Manufacturers Reporting - Preliminary Assessment
Information
Affected Facility:
Manufacturers and importers
Date of Applicability:
June 1982 (Substance specific)
Exemptions:
As described in 40 CFR 712.25
Affected Chemicals:
Chemical substances listed in 40 CFR 712.30
Reporting Requirements:
1) 2-page report for each plant manufacturing a chemical listed in 40 CFR §712.30
2) Cover latest complete corporate fiscal year as of the effective date
3) Due 60 days from effective date
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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TSCA Section 8(a) IUR - 40 CFR
Part 710
Inventory Reporting Regulations
Affected Facility:
Manufacturers and importers
that manufacture at, or import
to, any single site 10,000 Ibs.
or more during the latest
complete corporate fiscal year immediately prior to the reporting period.
Date of Applicability:
August 25 - December 23, 1986, and subsequent reporting periods
Exemptions:
Substances exempted in 40 CFR 710.26
Persons exempted in 40 CFR 710.29 (small manufacturers)
Activities exempted in 40 CFR 710.30
Affected Chemicals:
Any chemical on TSCA Inventory. ^
Reporting Requirements:
Initial and recurring (every 4 years) reporting to TSCA Inventory
Record Keeping Requirements:
1) All TSCA Inventory data submissions and records that document submission
information (kept for 4 years after reporting period)
2) Site-specific production or import records to verify reporting exemption ^C^
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requirements are in any way altered by any statements) contained herein. C-97
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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TSCA Section 8(c) - 40 CFR
Part 717
Records and Reports of Allegations that
Chemical Substances Cause Significant
Adverse Reactions to Health or the
Environment
Affected Facility:
Manufacturers and processors
meeting criteria in 40 CFR
717.5
Date of Applicability:
1983
Exemptions:
As stated in 40 CFR 717.7
Affected Chemicals:
Any chemical substance or mixture
Reporting Requirements:
Regarding allegations that substances cause significant adverse reactions to health or the
environment:
Records must be reported when required by letter to firms or notice in the Federal Register
Record Keeping Requirements:
1) Record of all employee allegations (the original document and abstract) kept for 30 years
2) All other allegations kept for 5 years.
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requirements are in any way altered by any statements) contained herein.
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requirements are in any way altered by any statements) contained herein.
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TSCA Section 8(d) - 40 CFR
Part 716
Health and Safety Data Reporting
Affected Facility:
Persons who, from 10 years
prior to the effective date that a
substance or mixture is added
to 40 CFR 7 16. 120 to the
present, manufactured, imported, or processed the substance or proposed to do so.
Date of Applicability:
1982 (Substance specific)
Exemptions:
Studies not subject to reporting requirements as defined in 40 CFR 716.20.
Affected Chemicals:
Chemicals listed in 40 CFR 716.120
Requirements:
1) Submission of any unpublished health and safety studies as described by 40 CFR 716.3
2) Submit information within 60 days after effective date of chemical placed on 40 CFR
716.120 list
3) 10-year continuing obligation to report certain information
Record Keeping Requirements:
None
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. /-> o i
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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TSCA Section 8(e) - 43 Federal
Register 11110 Policy Statement
Affected Facility:
Manufacturers, importers,
processors, and distributors
Date of Applicability:
Statute:
- January 1977
Policy Statement:
- March 1978
Affected Chemicals:
Chemical substances and mixtures for which there is information that reasonably supports the
conclusion that the substance or mixture presents a substantial risk of injury to health or the
environment.
Requirements: jg
Substantial risk to health or environment information reported immediately: *-^
^
- Emergency - within 24 hours (oral) QJ
- Nonemergency - within 15 working days (written) Łrj
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P-^
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Affected Facility:
Persons who export or intend
to export a chemical substance
for which:
TSCA Section 12-40 CFR
Part 707
Chemical Imports and Exports
Subpart D - Notices of Export Under Section 12(b)
Data are required under
Section 4 or 5(b)
An order has been issued under Section 5
A rule has been proposed or promulgated under Section 5 or 6
An action is pending or relief has been granted under Section 5 or 7
Date of Applicability:
1980
Exemptions:
40 CFR 707.72
Affected Chemicals:
As set out in 40 CFR 707.60, including PCBs and PCB articles [40 CFR 707.60(c)]
Reporting Requirements:
Submit notice of export: Q^
F
Within 7 days of definite contractual obligation to export; or '
Actual date of export
Whichever is earlier. If in response to an EPA proposed rule, requirement to submit notice
begins 30 days after publication of proposed rule.
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Contents of notice: 5
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Name of chemical, name and address of exporter, country of import, date of export, ^
section of TSCA applicable to substance
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. P-^
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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TSCA Section 13-40CFR
Part 707
Chemical Imports and Exports
Subpart B: (General Import Requirements and Restrictions),
§707.20 Chemical Substance Import Policy (referring to 19 CFR
Parts 12 and 127 (U.S. Customs Service)
Affected Facility:
Importers
Date of Applicability:
1980
Exemptions:
None
Affected Chemicals:
Any chemical substance, mixture or article
Reporting Requirements:
Submit statement of compliance with TSCA or that import is not subject to TSCA
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s
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
G-37
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
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Appendix H References and
Resources
REFERENCES
Process Descriptions and Waste Treatment
Kent, J. (ed.) Reigel's Handbook of Industrial Chemistry, New York, Von Nostrand Reinhold,
Ninth Edition, 1992.
Scherm, E., et al. Treatment of Organic Chemical Manufacturing Wastewater for Reuse,
National Technical Information Service (NTIS), 1979.
Szmant, H. Harry. Organic Building Blocks of the Chemical Industry, New York, John Wiley
and Sons, 1989.
U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors,
Volume I: Stationary Point and Area Sources, Fourth Edition, September 1985.
U.S. Environmental Protection Agency. Control of Volatile Organic Compound Emissions
from Reactor Processes Distillation Operations Processes in the Synthetic Organic
Chemical Manufacturing Industry, Research Triangle Park, NC, 1991.
U.S. Environmental Protection Agency. Development Document for Effluent Limitations
Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point
Source Category, EPA 440/1-87/009, October 1987.
U.S. Environmental Protection Agency. Environmental Regulations and Technology: Fugitive
VOC Emissions in the Synthetic Organic Chemicals Manufacturing Industry, December
1984.
U.S. Environmental Protection Agency. EPA Office of Compliance Sector Notebook: Project
Profile of the Organic Chemical Industry, Review Team Draft, EPA/310-R-95-012,
May 1995.
U.S. Environmental Protection Agency/OAQPS. Control of VOC Emissions from Polystyrene
Foam Manufacturing, EPA 450/3-90-020, September 1990.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. LJ_ i
-------
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Compound
Emissions from Air Oxidation Processes in Organic Chemical Manufacturing Industry,
EPA-450/3-84-015, December 1984.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Compound
Emissions from Batch Processes, February 1993.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Compound
Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and
Polystyrene Resins, EPA-450/3-83-008, November 1983.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Compound
Emissions from Reactor Processes and Distillation Operations Processes in the
Synthetic Organic Chemical Manufacturing Industry, EPA 450/4-91/031, June 1993.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Compound
Emissions from Volatile Organic Liquid Storage in Floating and Fixed Root Tanks,
September 1991.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Compound
Leaks from Synthetic Organic Chemical and Polymer Manufacturing Equipment, EPA-
450/3-83-006, March 1984.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Emissions from
Manufacture of Synthesized Pharmaceutical Products, EPA-450/2-78-029.
U.S. Environmental Protection Agency/OAQPS. Control of Volatile Organic Emissions from
Petroleum Liquid Storage in External Floating Roof Tanks, EPA-450/2-78-047,
December 1989.
U.S. Environmental Protection Agency/OAQPS. Reasonably Available Control Technology
Options for Industrial Wastewater, April 1989.
Pollution Prevention
ASTM. Hazardous and Industrial Solid Waste Minimization Practices, 1989, ISBNO-8031-
1269-6.
Breen, Joseph J., and Michael J. Dellarco. Pollution Prevention in Industrial Pro cesses: The
Role of Process Analytical Chemistry. Washington, D.C. American Chemical Society,
1992.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. H-?
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California Department of Health Services, Toxic Substances Control Program, Alternative
Technology Division, Technology Clearinghouse Unit. Hazardous Waste Reduction
Checklist and Assessment Manual for Pesticides, 1990.
Center for Hazardous Materials Research. Fact Sheet-Pollution Prevention: Strategies for
Chemical Production, Center for Hazardous Materials Research, 1991.
Chemical Manufacturer's Association. Designing Pollution Prevention into the Process:
Research, Development, and Engineering, Washington, D.C., 1993.
Chemical Manufacturer's Association. Pollution Prevention Resource Manual, 1991, $75.00
(non-members), $50.00 (members, Order no. 018031).
Coulson, J.M, Richardson, J.F., and Sinnott, R.K. Chemical Engineering: Design, Volume 6,
Permagon Press, 1983.
Dorfman, M.H. et al. Environmental Dividends: Cutting More Chemical Wastes, New York,
NY, INFORM, Inc.
DuPont Corporation and U.S. Environmental Protection Agency. DuPont Chamber Works
Waste Minimization Project, 1993.
Forester, William S., and John H. Skinner. Waste Minimization and Clean Technology:
Waste Management Strategies for the Future, San Diego, CA, Academic Press, 1992.
Government Institutes. Case Studies in Waste Minimization, 1991, ISBNO-86587-267-8.
Government Institutes. Waste Minimization Manual, 1987, $57.00, ISBN: 0-86587-731-9.
Kirk-Othmer. Encyclopedia of Chemical Technology, Fourth Edition, John Wiley & Sons,
1993.
Lewis Publishers. Hazardous Waste Minimization Handbook, ISBNO-87371-176-9, 1989.
Lewis, R.J. Hawley's Condensed Chemical Dictionary, Twelfth Edition, Van Nostrand
Reinhold Company, 1993.
McCabe, W.L., and Smith, J.C. Unit Operations of Chemical Engineering, Third Edition,
McGraw-Hill, Inc., 1976.
McGraw-Hill, Inc. Hazardous Waste Minimization, ISBNO-07-022043-3, 1990.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. H-3
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Nelson, K., and Lindsly, J. Case Study: Winning Ideas Reduce Waste at DOW, 1991.
Overcash, Michael R. Techniques for Industrial Pollution Prevention: A Compendium for
Hazardous and Non-Hazardous Waste Minimization, Chelsea, MI, Lewis Publishers,
1986.
Perry, R.H., and Chilton, C.H. Chemical Engineers' Handbook, Fifth Edition, McGraw-Hill,
Inc., 1973.
Sawyer, Donald T., and Arthur E. Martell. Industrial Environmental Chemistry: Waste
Minimization in Industrial Processes and Remediation of Hazardous Waste, New
York, NY, Plenum Press, 1992.
SOCMA Pollution Prevention Study. Prepared for SOCMA Washington, D.C., January 1993.
Profiles pollution prevention activities at four specialty chemical manufacturers.
Theodore, Louis, and Young C. McGuinn. Pollution Prevention, New York, Van Nostrand
Reinhold, 1992.
U.S. Congress, Office of Technology Assessment. Industry, Technology, and the
Environment: Competitive Challenges and Business Opportunities, OTA-ITE-586,
Washington, DC, January 1994.
U.S. Environmental Protection Agency. Pollution Prevention Fact Sheets: Chemical
production, FREG-1 (PPIC), free.
U.S. Environmental Protection Agency. Prevention Reference Manual: Control
Technologies. Volume 2: Post-Release Mitigation Measures for Controlling Accidental
Releases of Air Toxics, EPA/600/S8-87/039b, 1987.
U.S. Environmental Protection Agency. Prevention Reference Manual: Control
Technologies. Volume 1: Prevention and Protection Technologies for Controlling
Accidental Releases of Air Toxics, EPA/600/S8-87/039a, 1987.
U.S. Environmental Protection Agency. Prevention Reference Manual: User's Guide,
Overview for Controlling Accidental Releases of Air Toxics, EPA/600/S8-87/028,
1987.
U.S. Environmental Protection Agency. Development Document for Effluent Limitations
Guidelines and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers:
Point Source Category, Volume II, October 1987.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. H-4
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U.S. Environmental Protection Agency. Prevention Reference Manual: Overviews on
Preventing and Controlling Accidental Releases of Selected Toxic Chemicals,
EPA/600/S8-88/074, 1988.
U.S. Environmental Protection Agency. Waste Minimization Opportunity Assessment Manual,
EPA/625/7-88/003, 1988.
U.S. Environmental Protection Agency. Case Studies from the Pollution Prevention
Information Clearinghouse: Solvent Recovery, ISM-4 (PPIC), 1989.
U.S. Environmental Protection Agency. Pollution Prevention Benefits Manual: Volume 1
(Draft), WAM-1 (PPIC), 1989.
U.S. Environmental Protection Agency. Pollution Prevention Information Exchange System
(PIES) User Guide, Version 1.1, EPA/600/9-89/086, free, 1989.
U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory, Guide to
Waste Minimization in the Pesticide Formulating Industry, 1990.
U.S. Environmental Protection Agency. Guides to Pollution Prevention: Research and
Educational Institutions, ISM-19 (PPIC), 1990.
U.S. Environmental Protection Agency. Industrial Pollution Prevention for the 1990s,
EPA/600/S-891/052, 1991.
Regulations
Federal Register Notices:
52 FR 42522 (November 5, 1987)
57 FR 11394 (April 2, 1992)
57 FR 41836 (September 11,1992)
58 FR 36872 duly 9, 1993)
59 FR 61488 (November 30, 1994)
40 CFR Parts 100 through 799.
Hazardous Waste Consultant, Volume 12, October/November 1994. RCRA Land Disposal
Restrictions: A Guide to Compliance, 1995 Edition.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. H- 5
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U.S. Environmental Protection Agency. Federal Regulations Potentially Affecting the
Commercial Printing Industry, Design for the Environment, EPA/744-B-94-001, March
1994.
U.S. Environmental Protection Agency. Toxic Chemical Release Inventory Reporting Form R
and Instructions, Revised 1994 Edition, March 1995.
Inspection
Benzene Waste Operations NESHAP - 40 CFR 61 SubpartFF: Guidance for Review of 90-
day Report.
Federal Audit Protocol Workgroup, Generic Protocol for Conducting Environmental Audits of
Federal Facilities, 2nd Edition, EPA # 300-B-95-002, February 1995.
U.S. Environmental Protection Agency. Industrial User Inspection and Sampling Manual For
POTWs, EPA/83l-B-94-001, April 1994.
U.S. Environmental Protection Agency. National Enforcement Investigations Center, Draft
Process-Based Inspection Guide, May 1995.
U.S. Environmental Protection Agency. NPDES Compliance Inspection Manual, EPA/300-B-
94-014, September 1994.
U.S. Environmental Protection Agency. RCRA Inspection Manual, OSWER Directive
9938.02b, October 1993.
U.S. Environmental Protection Agency. Toxic Substances Control Act, §§5/8 Inspection
Guidance, November 1992.
U.S. Environmental Protection Agency/OAQPS. Inspection Procedures and Safety, Air
Pollution Training Institute Course 446, November 1993.
U.S. Environmental Protection Agency/OAQPS/SSCD. Inspection Reporting Formats and
Inspection Working Files, September 1989.
Other
Office of Management and Budget. Standard Industrial Classification Manual, 1987.
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. H-fi
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U.S. Environmental Protection Agency. CERCLA Compliance with Other Laws Manual,
Draft, OSWER Directive 9234.1-01, May 6, 1988.
U.S. Environmental Protection Agency. National Pretreatment Program Report to Congress,
21W-4004, July 1991.
U.S. Environmental Protection Agency. Training Manual for NPDES Permit Writers, March
1993.
RESOURCES
Readers are referred to several Federal resources that provide a wealth of information
useful for performing facility self-assessments. Contact the resources identified below for
more information on specific titles available.
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650 (to order)
(703) 487-4680 (to identify a title for sale)
Center for Environmental Research Information (CERI)
26 West Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7562 (phone)
(513) 569-7566 (fax)
Pollution Prevention Information Clearinghouse (PPIC)
401M Street, SW (3404)
Washington, D.C. 20460
(202) 260-1023 (phone)
(202) 260-0178 (fax)
Federal Register/Code of Federal Regulations (Title 40 - The Environment)
New Orders
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. T-T-7
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This manual is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein. H-H
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