-------
been demonstrated extensively and is'not a common practice. The major
industrial application of air stripping has been in the removal of ammonia
from wastewater.23 In recent years, the use of air strippers has become a
widely used technology in the removal of volatile compounds from contami-
nated ground water.24,25
Packed towers can achieve up to 99.9 percent removal of volatiles from
water.26 the major factors affecting removal efficiency include the
equilibrium between the organics and the vapor phase (usually measured by
Henry's law constant for dilute aqueous wastes) and the system's design,
which determines mass transfer rates. Removal efficiency increases as the
equilibrium coefficient increases; consequently, the extent of removal is
strongly affected by the type of waste and the volatility of the individual
organic constituents. Mass transfer rates (and removal efficiency) are also
a function of the air-to-water ratio, height of packing, and type of pack-
ing.27 The operating temperature is also an important variable that affects
efficiency because of its direct effect on the vapor/liquid equilibrium.
Higher temperatures result in higher vapor-phase concentrations of organic
and higher removal rates. Air strippers have operational difficulties.in
freezing weather that may require heating the input waste stream, heating
and insulating the column, or housing the operation inside an enclosure.
Air strippers are typically designed to remove key or major constituents.
Compounds more volatile than the design constituent are removed at or above
the design efficiency, and less volatile compounds are removed at a lower
efficiency.
The air leaving the stripping column usually is treated by incineration
(thermal or catalytic) or carbon adsorption. The choice between incinera-
tion and carbon adsorption depends on the specific conditions at the facil-
ity. For example, high relative humidity in the airstream leaving the air
stripper may adversely affect the adsorption capacity of a carbon bed. This
problem could be avoided by choosing incineration. However, if the
airstream contains chlorinated organics, the incinerated airstream may need
to be scrubbed to remove HC1, leading to higher costs. In this case, it
might be better to choose carbon adsorption and design the system to avoid
potential humidity problems.
5-17
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5.2 PROCESS VENT EMISSION RATE CUTOFF DETERMINATION
After identifying all affected process vents, -the owner/operator must
determine whether the affected process vent's emission rate is below the
emission rate limits established by the regulation. To make this decision,
the owner/operator must determine emission rates for each vent and for the
entire facility through mass balance calculations or direct source test and
compare the rates to the short- and long-term process vent emission rate
limits (1.4 kg/h or 2.8 Mg/yr [3 Ib/h or 3.1 short tons/yr]). Example
applications of the emission cutoff for process vents are presented, in
Tables 5-1 and 5-2.
Alternative methods of estimating facility process vent emissions are
discussed in the following sections.
5.2.1 Mass Balance
Losses or emissions from any process can be estimated from an accurate
mass balance. Emission estimates, however, to determine if compliance has
been met should be based on the waste streams with the highest emission
potential allowed under the permit (or if no permit has been issued, allowed
under interim status). If all inlet and outlet process streams are pre-
cisely characterized with regard to flow rates, composition, and physical
properties, any difference between the total known amount of material enter-
ing the system and that known to be leaving would be emissions. This can be
expressed as:
Mass emissions = Mass in - Mass out . (5-1)
In practice, precise measurements of material volumes, flow rates, and
characteristics are often difficult to obtain. Most flow rates and material
rate measurements in chemical processing are made in terms of volume. Thus,
fluid densities must be known to convert volumetric measurements to mass
flows. A liquid material balance can be expressed as:
E. = EL,W. .P. - ZL.W.
' .jJ'fJJ ^ K 1
(5-2)
where:
E-J = Emission rate (losses) of component i, Ib/h
LJ = Volumetric flow rate of inlet stream j, gal/h
5-18
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-------
L|< =.Volumetric flow rate of outlet stream k, gal/h
W-j j = Weight fraction of component i in inlet stream j
Wi |< = Weight fraction of component i in outlet stream k
Pj, pk = Density of liquid stream j and k, respectively, Ib/gal.
All parameters in Equation 5-2 are measured. (For guidance on sample-
taking, see Chapter 6.0.) The emissions can also be expressed as a
percentage of the total organic throughput of the process.
5.2.2 Emission Test
A direct source or performance emission test is an alternative means of
determining the emission rate for a process vent. The direct source emis-
sion test should be conducted when wastes and process operating conditions
are at maximum emission potential. Methods for measuring emissions from
ducted sources are well documented.28 The approach requires that the volu-
metric, flow rate of the gas be determined, typically as-measurements of
velocity and duct cross-sectional area, and that the gas organic concentra-
tion be measured. The emission rate for each organic constituent can then
be calculated as:
Ei = CiU A , . (5-3)
where:
ET = Emission rate of component i, /tg/s
U = Gas velocity through vent, m/s
C-j = Concentration of component i in vent gas, /ig/m3
A = Cross-sectional area of vent, m2.
All parameters in Equation 5-3 are measured directly.
Emission testing is discussed in Chapter 6.0. Table 6-7 lists several
flow measuring methods that could be considered for the measurement of the
flow rate in the process vent stream of concern. In addition, Section 6.1.2
discusses the measurement of the organic content of the waste stream gases
(the preferred method of analysis is EPA Method 18).
Once the process vent organic content and gas flow rate have been meas-
ured, these data can be used to calculate the emission rate. The hourly
emission rate (kg/h) is equal to the flow rate (m3/s) multiplied by. the
5-21
-------
organic concentration (ppmv), the average molecular weight (kg/g mole), and
appropriate conversion factors (see Table 6-8). The emission rate for the
hourly value should be based on the maximum expected emission from the
source. Similarly, the yearly emission rate is based on the maximum total
emissions expected from the facility; therefore, the calculation will have
to be based on the maximum hourly emission and the yearly hours of
operation.
5.3 VENT CONTROLS
If the total facility process vent emission rate for hourly or yearly
emissions exceeds the limits in the regulation, then controls will have to
be used to reduce emissions below the limits or, if the emission rate limits
cannot be attained, by 95 percent or greater of the total vented mass.
These controls or control devices used to reduce the emissions from the
process vents affected by the regulation are by definition enclosed
combustion devices, vapor recovery systems, or flares, though process vent
controls are not limited to these devices. Any device for which the primary
function is to recover or capture solvents or other organics for use, reuse,
or sale (e.g., a primary condenser on a solvent recovery unit) is considered
to be a component of the process rather than a control device. The emission
reduction attained by a device that is part of the process should not be
included in the emission reduction calculation for the purpose of determing
compliance.
The vented emission must be transported to a control device by a
"closed-vent system." This system has already been discussed in the
equipment leak section because all "closed-vent systems" must be monitored
for leaks. The control device efficiency must be determined by calculating
the mass of organics entering the control device and the mass of organics
exiting the same control device.
As previously mentioned, any engineering judgment concerning control
device efficiency may put the owner/operator at risk if that judgment proves
erroneous. A performance test, if used to determine efficiency, will
consist of measuring the organic content and gas flow rate into and out of
the control device. The test procedures that have been referenced for gas-
phase organic concentration measurement and velocity (flow rate) measurement
5-22
-------
are appropriate for the performance -test. A performance test should include
at least three 1-h test periods under conditions that would exist when the
hazardous waste management u.nit is operating at the highest load or capacity
level reasonably expected to occur.. The organic reduction efficiency would
be estimated for each 1-h period, and an average of the three values would
represent the system performance at maximum conditions.
In addition to the performance test, the owner/operator will be
required to monitor continuously certain operational parameters of the
control device to ensure continued attainment of design organic reduction
efficiency. Table 6-8 lists possible controls, monitoring requirements, and'
monitoring methods. The relationship of the organic reduction performance
and control device operating parameter can be established during the per-
formance test or through engineering calculations, material balances, or
manufacturer/vendor certification (a documented agreement between the
owner/operator and the vendor to guarantee the meeting of a standard of
performance for a particular product).
The owner/operator must keep a logbook that provides data on the
.specified control device operating parameters that are required'to be
monitored under Subpart AA of the standards for process vents. Periods when
monitoring indicates that control device operating parameters exceed
established tolerances set forth by the regulation must also be recorded and
reported to the Regional Administrator (see Section 7.2.2, "Process Vent
Recordkeeping Requirements," for information regarding exceedances). This
log should also contain information and data identifying all affected proc-
ess vents, annual throughput and facility operating hours of each affected
unit, estimated emission rates'for each affected vent and for the overall
facility, and the approximate location within the facility of each affected
unit.
5.3.1 Condensation
Condensation is a process of converting all or part of the condensable
components of a vapor phase into a liquid phase. This is achieved by the
transfer of heat from the vapor phase to a cooling medium. If only a part
of the vapor phase is condensed, the newly formed liquid phase and the
remaining vapor phase will be in equilibrium. In this case, equilibrium
relationships at the operating temperatures must be considered. The heat
5-23
-------
removed from the vapor phase should be sufficient to lower the vapor-phase
temperature to (or below) its dewpoint temperature (temperature at which
first drop of liquid is formed).
Condensation devices are of two types: surface condensers and contact
condensers.29 Surface condensers generally are shell-and-tube type heat
exchangers. The coolant and the vapor phases are separated by the tube
wall, and they never come in direct contact with each other (see Figure
5-6). Vapors are coaled in contact condensers by spraying relatively cold
liquid directly into the gas stream. The coolant is often water, although
in some situations'another coolant may be used. Most contact condensers are
simple spray chambers, like the one pictured in Figure 5-7.
Contact condensers are, in general, less expensive, more flexible, and
more efficient-in removing organic vapors than surface condensers. On the
other hand, surface condensers may recover marketable condensate and mini-
mize waste disposal problems. Often, condensate from contact condensers
cannot be reused and may require significant wastewater treatment prior to
disposal. Surface condensers must be equipped with more auxiliary equipment
and have greater maintenance requirements. Surface condensers are consid-
ered in the discussion of control efficiency and applicability because they
are used more frequently in the hazardous waste management industry.
The major equipment components used in a typical surface condenser
system for organic removal are shown in Figure 5-8. This system includes
(1) shell- and-tube dehumidification equipment (2) shell-and-tube heat
exchanger (3) refrigeration unit, and (4) recovered organic storage tanks
and operating pumps. Most surface condensers use a shell-and-tube type of
heat exchanger to remove heat from the vapor.30 AS the coolant passes
through the tubes, the organic vapors condense outside the tubes and are
recovered. The coolant used depends on,the saturation temperature of the
organic vapor stream. Chilled water can be used down to 7 °C (45 °F),
brines to -34 °C (-30 °F), and chlorofluorocarbons below -34 °C (-30 °F).31
Temperatures as low as -62 °C (-80 °F) may be necessary to condense some
organic vapor.32
The design of surface condensers involves calculating the rate of heat
transfer through the wall of the exchanger per unit time, its "duty," or
5-24
-------
COOJ.AHTIHUT VAPO» OUTLET
I
VAPOR INUT
eOOLAHT OUTtCT COHOCNStO VOC
Figure 5-6. Schematic diagram of a shell-and-tube surface condenser.
VAPOR INLET.
VAPOR OUTLET
WATCH INLET
OtSTKltimOH
TUT
UGUIO UVIL
IIOUIO OUTLET
Figure 5-7. Schematic diagram of a contact condenser.
5-25
-------
Cleaned Gas Out
to Primary Control
Hare, Afterburner, etc.
Organic-Laden
Gas
Dehumldiflcation
Unit
To remove water
and prevent
freezing in
main condenser
Coolant
Return
(1)
Main Condenser
(2)
Coolant
Condensed
Organic
To Process
or Disposal
Figure 5-8. Condensation system.
5-26
-------
calculating the heat-transfer area. The rate of heat transfer for a surface
condenser is governed by the-following relationship:
' UoATm
or
(5-4)
where:
Q = Total heat load/rate of heat transfer, Btu/h
U0 = Overall heat-transfer coefficient, Btu/h °F ft2
Tm = Mean temperature difference, °F
A = Heat transfer surface area, ft2.
If the heat-transfer area, the overall heat-transfer coefficient and the
mean temperature difference are known, the condenser duty can easily be
calculated. . (See Appendixes C and D for sample calculations on the size and
rate of heat transfer of a condenser; for an analysis of the effect of
concentration on condenser efficiency, see Appendix E.) Calculation of
heat-transfer coeffici-ents, a tedious step in definitive design, is avoided
in predesign evaluations where approximate values are adequate. An
extensive tabulation of typical overall coefficients, based on industrial
practice, is found in Reference 1 (pp. 10-39 to 10-42). The appropriate
mean temperature difference can be calculated using the following
expression:
MTD =
co
-Tci>
'ci
)J
(5-5)
where:
Tni = Inlet temperature of hot fluid, K (°F)
Tno = Outlet of hot fluid
Tc-j = Inlet of cold fluid
Tco = Outlet of cold fluid.
If flow in the exchanger is not truly countercurrent, an appropriate correc-
tion factor must be applied.33 in practice, the vapor stream will contain
5-27
-------
multicomponents, air and at least one other gas, thus complicating the
design procedures.
To ensure that the condenser is operated and maintained within design
specifications, 40 CFR 264.1033(f) and 265.1033(f) require the owner/oper-
ator to monitor and inspect each condenser required to comply with the
facility process vent emission rates by implementing the following
requirements:
• Install, calibrate, maintain, and operate according to the
manufacturer's specifications a flow indicator that provides
a record of vent'stream flow to the control device at least
once every hour. The flow indicator sensor shall be
installed in the vent stream at the nearest feasible point to
the control device inlet, but before being combined with
other vent streams.
• Install a monitoring device equipped with a continuous
recorder to measure the concentration level of the organic
compounds in the exhaust vent stream from the condenser; or
• Install a temperature monitoring device equipped with a
continuous recorder. The. device shall be capable of moni-
toring temperature at two locations and have an accuracy of
±1 percent of the temperature being monitored in degrees
Celsius or ±0.5 °C, whichever is greater. One temperature
sensor shall be installed at a location in the exhaust vent
stream from the'condenser, and a second temperature sensor
shall be installed at a location in the coolant fluid exiting
the condenser.
A secondary parameter that can be monitored to give an indication of the
operating or removal efficiency is the quantity of organic removed over
time.
The volatile organic removal efficiency for a condenser is dependent
upon the gas stream organic composition and concentrations as well as the
condenser operating temperature. Condensation can be an effective control
device for gas streams having high concentrations of organic compounds with
high boiling points. However, condensation is not effective for gas streams
containing low organic concentrations or composed primarily of low-boiling-
point organics. At these conditions, organics cannot readily be condensed
at normal condenser operating temperatures. This point is demonstrated in
the results of a field evaluation of a condenser used to recover organics
from a steam stripping process treating wastewater at a plant manufacturing
5-28
-------
ethylene dichloride and vinyl chloride monomer. The measured condenser
removal efficiencies for specific organic constituents in the controlled
vent' stream ranged from a high value of 99.5 percent for 1,2-dichloroethane
to a low value of 6 percent for vinyl chloride.
5.3.2 Combustion Equipment
. There are basically three types of combustion equipment used in
controlling gaseous emissions: flares, thermal oxidizers (thermal inciner-
ators, boilers or process heaters), and catalytic oxidizers (catalytic
incinerators). Inside a flare, a flame is used to oxidize all the combust-
ible material. In a thermal oxidizer, combustible gases pass over or'around
the burner flame first and then into a chamber where the gas flow rate is
decreased, thus allowing an adequate time for complete oxidation. Catalytic
oxidizers are similar to thermal oxidizers. The major difference between
the two is that, after the combustible gases pass through the flame area,
the gas is sent through a catalyst bed that promotes oxidation at tempera-
tures lower .than the ones necessary in a thermal oxidizer. This reduces
fuel usage, and lighter construction can be used in catalytic units. The
main problem in catalytic oxidation is the reduction or loss of catalyst
activity due to fouling by particulate matter or suppression or poisoning by
sulfur and halogen compounds or certain metals. Control devices used to
reduce TSDF process vent emissions would be subject to these contaminants in
the waste gas stream; therefore, thermal oxidation is the most applicable
incineration technique.
5.3.2.1 Flares. Flaring is an open combustion process in which the
oxygen required for combustion is provided by the ambient air around the
flame. Good combustion in a flare is governed by flame temperature,
residence time of components in the combustion zone, turbulent mixing of the
components to complete the oxidation reaction, and oxygen for free radical
formation.
There are two types of flares: ground-level flares and elevated
flares. Kalcevic presents a detailed discussion of different types of
flares, flare design and operating considerations, and a method for estimat-
ing capital and operating costs for flares.34 The basic elements of an
elevated flare system are shown in Figure 5-9. Process off-gases are sent
to the flare through the collection header (1). The off-gases entering the
5-29
-------
(9)
Steaa
H022I6S
(6)
fiaiiitf
Helps prevent flash back
fhn
Stack
(5)
Gas Cotleeiiaa Header
and Tiaaslet Uae (1)
JC
Gu
(4)
1
Flare Tip (|
iiot
Buiaen (7 }
^
~K
Seai
•Uae
Air UK
3
Ocau
Rgure 5-9. Steam-assisted elevated flare system.
5-30
-------
header can vary widely in volumetric flow rate, moisture content, organic
concentration, and heat value. The knock-out drum (2) removes water or
hydrocarbon droplets that could create problems in the flare combustion
zone. Off-gases are usually passed through a water seal (3) before going to
the flare. This prevents possible flame flashbacks, caused when the off-gas
flow to the flare is too low and the flame front pulls down into the stack.
Purge gas (N2, C02, or natural gas) (4) also helps to prevent flashback
in the flare stack (5) caused by low off-gas flow. The total volumetric
flow to the flame must be carefully controlled to prevent low flow flashback
problems and to avoid a detached flame (a space between the stack and flame
with incomplete combustion) caused by an excessively high flow rate. A gas
barrier (6) or a stack seal is sometimes used just below the flare head to
impede the flow of air into the flare gas network.
The organic vapor stream enters at the base of the flame where it is
heated by already burning fuel and pilot burners (7) at the flare tip (8)
(see Figure 5-10A). Fuel flows into the combustion'zone where the exterior
of the microscopic gas pockets is oxidized. The rate of reaction is limited
by the mixing of the fuel and oxygen from the air. If the gas pocket has
sufficient oxygen and residence time in the flame zone, it can be completely
burned. A diffusion flame receives its combustion oxygen by diffusion of
air into the flame from the surrounding atmosphere. The high volume of fuel
flow in a flare requires more combustion air at a faster rate than simple
gas diffusion can supply so flare designers add steam injection nozzles (9)
to increase gas turbulence in the flame boundary zones, thus drawing in more
combustion air and improving combustion efficiency. This steam injection
promotes smokeless flare operation by minimizing the cracking reactions that
form carbon. Significant disadvantages of steam usage are the increased
noise and cost. The steam requirement depends on the composition of the gas
flared, the steam velocity from the injection nozzle, and the tip diameter.
Although some gases can be flared smokelessly without any steam, typically .
0.15 to 0.5 kg of steam per kg of flare gas is required.
Steam 'injection is usually controlled manually with the operator
observing the flare (either directly or on a television monitor) and adding
steam as required to maintain smokeless operation. Several flare manufac-
turers offer devices that sense a flare's flame characteristics and adjust
the steam flow rate automatically to maintain smokeless operation.
5-31
-------
Wane {as Steam injection
•burner >, point
Klot light
Figure 5-10A. Flare tip.
Burner*
f&* *-.."-J m El^fe...... >
»"*^.'* .IT' ' -• «* W«MM^MBrfita^b^^^lMHIBW^>MMh>Mi^iMta
fc ;-'(v—•vV_.- ~
Figure 5-10B. Ground flare.
5-32
-------
Some elevated flares use forced'air instead of steam to provide the
combustion air and the mixing required for smokeless operation. These
flares consist of two coaxial flow channels. The combustible gases flow in
the center channel, and the combustion air (provided by a fan in the bottom
of the flare stack) flows in the annulus. The principal advantage of air-
assisted flares is that expensive steam is not required. Air assistance is
rarely used on large flares because airflow is difficult to control when the-
gas flow is intermittent. About 597 W (0.8 hp) of blower capacity is
required for each 45 kg/h (100 Ib/h) of gas flared.35
Ground flares are usually enclosed and have multiple burner heads that
are staged to operate based on the quantity of gas released to the flare
'(see Figure 5-10B). The energy of the gas itself (because of the high
nozzle pressure drop) is usually adequate to provide the mixing necessary
for smokeless operation, and air or steam assist is not required. A fence
or other enclosure reduces noise and light from the flare and provides some
wind protection.
Ground flares are less numerous and have less capacity than elevated
flares. Typically, they are used to burn gas "continuously," while steam-
assisted elevated flares are used to dispose of large amounts of gas
released in emergencies.
A series of flare destruction efficiency studies have been performed by
EPA. Based on the results of these studies, EPA concluded that 98 percent
combustion efficiency can be achieved by steam-assisted and air-assisted
flares burning gases with heat contents greater than 11 MJ/m3 (300 Btu/ft3).
To achieve this efficiency level, EPA developed a set of flare design guide-
lines. The guidelines specify flare tip exit velocities for different flare
types and waste gas stream heating values.
To ensure that flares achieve the emission reductions required by the
standards, Sections 264.1033 and 265.1033 of the rules require the owner/
operator to design, monitor, and inspect each flare required to comply with
the facility process vent emission rate limits by implementing the following
requirements:
5-33
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Install, calibrate, maintain, and operate according to the
manufacturer's specifications a flow indicator that provides
a record of vent stream flow to the control device at least
once every hour. The flow indicator sensor shall be
installed in the vent stream at the nearest feasible point to
the control device inlet, but before being combined with
other vent streams.
Design and operate flares with no visible emissions as
determined by the methods specified in Sections 264.1033(e)
and 265.1033(e), except for periods not to exceed a total of
5 minutes during any 2 consecutive hours.
Operate flares with a flame present at all times, as deter-
mined by the methods specified in Sections 264.1033(f) and
265.1033(f) in paragraph (f)(2)(iii).
Use flares only if the net heating value of the gas being
combusted is 11.2 MJ/scm (300 Btu/scf)'or greater; if the
flare is steam-assisted or air-assisted; or if the net
heating value of the gas being combusted is 7.45 MJ/scm (200
Btu/scf) or greater if the flare is nonassisted,, The net
heating value of the gas being combusted shall be determined
by the methods specified in Sections 264.1033(e) and
265.1033(e).
Design and operate steam-assisted and nonassisted flares with
an exit velocity, as determined by the methods specified in
Sections 264.1033(e) and 265.1033(e), less than 18.3 m/s (60
ft/s), except as provided in Sections 264.1033(d) and
265.1033(d) in paragraphs (d) (4) (ii) and (iii),.
Design and operate steam-assisted and nonassisted flares with
an exit velocity, as determined by the methods specified in
Sections 264.1033 and 265.1033(e)(3), equal to or greater
than 18.3 m/s (60 ft/s) but less than 122 m/s (400 ft/s) if
the net heating value of the gas being combusted is greater
than 37.3 MJ/scm (1,000 Btu/scf).
Design and operate steam-assisted and nonassisted flares with
an exit velocity, as determined by the methods specified in
Sections 264.1033(e) (3) and 265.1033(e) (3)-, less than the
velocity, Vmax, as determined by the method specified in
Sections 264.1033(e)(4) and 265.1033(e)(4), and less than 122
m/s (400 ft/s).
Design and operate air-assisted flares with an exit velocity
less than the velocity, Vmax, as determined by the method
specified in Sections 264.1033(e)(5) and 265.1033(e)(5).
Flares used to comply with this section shall be steam-
assisted, air-assisted, or nonassisted.
5-34
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Use Reference Method 22 in-40 CFR Part 60 to determine the
compliance of flares with the visible emission provisions of
this subpart. The observation period is 2 hours and shall be
used according to Method 22.
Calculate the net heating value of the gas being combusted in
a flare using the following equation:
HT = K
' n.
E
Li-1
CiHi
(5-6)
where:
HT
K =
Net heating value of the sample, MJ/scm; where the net
enthalpy per mole of off-gas is based on combustion at
25 °C and 760 mm Hg, but the standard'temperature for
determining the volume corresponding to one mole is
20 «C;
Constant; 1.74 x 10'7 (1/ppm) (g mol/scm) (MJ/kcal)
where standard temperature for (g mol/scm) is 20 °C;
CT = Concentration of sample component i in ppm on a wet
basis, as measured for organics by Reference Method 18
in 40 CFR Part 60 and measured for hydrogen and carbon
monoxide by ASTM D1946-82 (incorporated by reference
as specified in Section 260.11); and
Hi = Net heat of combustion of sample component i, kcal/g
mole at 25 *C and 760 mm Hg. The heats of combustion
may be determined using ASTM D2382-83 (incorporated by
reference as specified in Section 260.11) if published
values are not available or cannot be calculated.
Determine the actual exit velocity of a flare by dividing the
volumetric flow rate (in units of standard temperature and
pressure), as determined by Reference Methods 2, 2A, 2C, or
2D in 40 CFR Part 60 as appropriate; by the unobstructed
(free) cross-sectional area of the flare tip.
Determine the maximum allowed velocity, Vmax, for flares
complying with Sections 264.1033(d)(4)(iiiJ and
265.1033(d)(4)(iii) by the following equation:
28.8)/31.7
(5-7)
where:
Maximum allowed velocity, m/s
28.8 = Constant
5-35
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31.7 = Constant
HT = The net heating value as determined in Sections
264.1033(e)(2) and 265.1033(e)(2).
Determine the maximum allowed velocity, Vmax, for air-
assisted flares by the following equation:
miv
UlaX
= 8.706 + 0.7084 (HT)
• I
(5-8)
where:
Vmax = Maximum, all owed velocity, m/s
» * p
8.706 = Constant
0.7084 = Constant
HT - The net heating value as determined in Sections
264.1033(e)(2) and 265.1033(e)(2).
5.3.2.2 Thermal Incineration. Any organic chemical heated to a high
enough temperature in the presence of enough oxygen will be oxidized to
carbon dioxide and water. This is the"basic principle of operation of a
thermal incinerator. The theoretical temperature required for thermal
oxidation to occur depends on the structure of the chemical involved. Some
chemicals are oxidized at .temperatures much lower than others. The organic
destruction efficiency of a-thermal oxidizer can be affected by variations
in chamber temperature, residence time, inlet organic concentration, com-
pound type, and flow regime (mixing). An efficient thermal incinerator
system must provide:
1. A chamber temperature high enough to enable the oxidation reaction
to proceed rapidly to completion
2. 'Enough turbulence to obtain good mixing between the hot combustion
products from the burner, combustion air, and organics
3. Sufficient residence time at the chosen temperature for the
oxidation reaction to reach completion.
A thermal incinerator is usually a refractory-lined chamber containing
a burner at one end. As shown in Figure 5-11, discrete dual fuel burners
(1) and inlets for the vent gas (2) and combustion air (3) are arranged in a
premixing chamber (4) to mix the hot products from the burners thoroughly
with the vent gas airstreams. The mixture of hot reacting gases then passes
"into the main combustion chamber (5). This section is sized to allow the
5-36
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Vent gas (2)
Auxiliary
?yei Earner-;—
.discrete)
(1)
Air
Ootionai
Heat , .
Recovery (6)
Figure 5-11. Discrete burner, thermal oxidizer.
(2)
Burner Plate- Flame Jets7 (1)
Auxiliary fuel
(natural gas)
Figure 5-12. Distributed burner, thermal oxidizer.
tec*
t
Ootjonai
Heat
Recovery
(4)
5-37
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mixture enough time at the elevated temperature for the oxidation reaction
to reach completion (residence times of 0.3 to 1 s are common). Energy can
then be recovered from the hot flue gases in a heat recovery section (6).
Preheating of combustion air or vent gas is a common mode of energy
recovery; however, it is sometimes more economical to generate steam.
Insurance regulations require that if the waste stream is preheated, the
organic concentration must be maintained below 25 percent of the lower
explosive limit (LEL) to prevent explosion hazards.
Thermal incinerators designed specifically for organic incineration
with natural gas as the auxiliary fuel may also use a grid-type (distrib-
uted) gas burner as shown in Figure 5-12.36 jhe tiny gas flame jets (1) on
the grid surface (2) ignite the vapors as they pass through the grid.- The
grid acts as a baffle for mixing the gases entering the chamber (3). This
arrangement ensures burning of all vapors at lower chamber temperature and
uses less fuel. This system makes possible a shorter reaction chamber yet
maintains high efficiency.
Other parameters affecting incinerator performance (i.e., organic vapor
destruction efficiency) are the vent gas organic vapor composition, concen-
tration, and heating value; the water content in the stream; the amount of
excess combustion air (the amount of air above the stoichiometric air needed
for reaction); the combustion zone temperature; the period of time the
organics remain in the combustion zone (i.e., "residence time"); and the
degree of turbulent mixing in the combustion zone.
The vent gas heating value is a measure of the heat available from the
combustion of the organic in the vent gas. Combustion of vent gas with a
heating value less than 1.86 MJ/Nm3 (50 Btu/scf) usually requires burning
auxiliary fuel to maintain the desired combustion temperature. Auxiliary
fuel requirements can be lessened or eliminated by the use of recuperative
heat exchangers to preheat combustion air. Vent gas with a heating value
above 1.86 mJ/Nm3 (50 Btu/scf) may support combustion, but may need
auxiliary fuel for flame stability.
A thermal incinerator handling vent gas streams with varying heating
values and moisture content requires careful adjustment to maintain the
proper chamber temperatures and operating efficiency. Water requires a
great deal of heat to vaporize, so entrained water droplets in a vent gas
5-38
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stream can substantially increase auxiliary fuel requirements because of the
additional energy needed to vaporize the water and raise it to the combus-
tion chamber temperature. Combustion devices are always operated with some
quantity of excess air to ensure a sufficient supply of oxygen. The amount
of excess air used varies with the fuel and burner type, but it should be
kept as low as possible. Using too much excess air wastes fuel because the
additional air must be heated to the combustion chamber temperature. A
large amount of excess air also increases flue gas volume and may increase
the size and cost of the system. Packaged, single unit thermal incinerators
can be built to control streams with flow rates in the range of 0.1 NmVs
(200 scfm) to about 24 Nm3/s (50,000 scfm).
To ensure that the thermal incinerator is operated and maintained
within design specifications, Sections 264.1033(f) and-265.1033(f) require
the owner/operator to monitor and inspect each thermal incinerator required
•to comply with the facility process vent emission rate limits by implement-
ing th£ following requirements:
• Install, calibrate, maintain, and operate according to the manu-
facturer's specifications a flow indicator that provides a record
of vent stream flow to the control device at least once every •
hour. The flow indicator sensor shall be installed in the vent
stream at the nearest feasible point to the control device inlet,
but before being combined with other vent streams.
*
• Install a temperature monitoring device equipped with a continuous
recorder. The device shall have an accuracy of ±1 percent of the '
temperature being monitored in degrees Celsius or ±0.5 °C, which-
ever is greater. The temperature sensor shall be installed at a
location in the combustion chamber downstream of the combustion
zone. .
Also, visible emissions from an incinerator indicate incomplete combustion,
i.e., inefficient operation.
5.3.2.3 Catalytic Incinerators. A catalyst is a substance that
changes the rate of a chemical reaction without being permanently altered.
Catalysts in catalytic incinerators cause the oxidizing reaction to occur at
a lower temperature than is required for thermal oxidation. Catalyst mate-
rials include platinum, platinum alloys, copper oxide, chromium, and cobalt.
These materials are plated in thin layers on inert substrates designed to
provide maximum surface area between the catalyst and the organic vapor
stream.
5-39
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Figure 5-13 presents a catalytic incinerator. The vent gas (1) is
introduced into a mixing chamber (3) where it is heated to approximately
320 °C (~600 °F) by the hot combustion products of the auxiliary burners
(2). The heated mixture then passes through the catalyst bed (4). Oxygen
arid organics diffuse onto the catalyst surface and are adsorbed in the pores
of the catalyst. The oxidation reaction takes place at these active sites.
Reaction products are desorbed from the active sites and diffuse back into
the gas. The combusted gas can then be routed through a waste heat recovery
device (5) before exhausting into the atmosphere.
Combustion catalysts usually operate over a temperature range of 320 to
650'°C (600 to 1,200 °F). Lower temperatures can slow down or stop the
oxidation reaction. Higher temperatures can shorten the life of the cata-
lyst or evaporate the catalyst from the inert substrate. Vent gas streams
with high organic concentrations can result in temperatures high enough to
cause catalyst failure. In such cases, dilution air may be required.
Accumulations of particulate matter, condensed organics, or polymerized
hydrocarbons on the catalyst can block the active sites and reduce effi-
ciency. Catalysts can also be deactivated by compounds containing sulfur,
bismuth, phosphorous, arsenic, antimony, mercury, lead, zinc, tin, or
halogens. If these compounds deactivate the catalytic unit, organics will
pass through unreacted or be partially oxidized to form compounds (alde-
hydes, ketones, and organic acids) that are highly reactive atmospheric
pollutants that can corrode plant equipment.
Catalytic incineration destruction efficiency is dependent on organic
composition and concentration, operating temperature, oxygen concentration,
catalyst characteristics, and space velocity. Space velocity is commonly
defined as the volumetric flow of gas entering the catalyst bed chamber
divided by the volume of the catalyst bed. The relationship between space
velocity and organic destruction efficiency is strongly influenced by
catalyst operating temperature. As space velocity increases, organic
destruction efficiency decreases, and as temperature increases, organic
destruction efficiency increases. A catalytic unit operating at about
450 eC (840 eF) with a catalyst bed volume of 0.014 to 0.057 m^ (0.5 to 2
ft3) per 0.47 scm/s (1,000 scfm) of vent gas passing through the device can
achieve 95 percent organic destruction efficiency.37- Destruction
5-40
-------
I
c
O
m
in
CD
il
5-41
-------
efficiencies of 98 percent or greater can be obtained on some streams by
utilizing the appropriate catalyst bed volume to vent gas flow rate.
To ensure that the catalytic incinerator is operated and maintained
within design specifications, Sections 264.1033(f) and 26i5.1033(f) require
the owner/operator to monitor and inspect each catalytic incinerator
required to comply with the facility process vent emission rate limits by
implementing the following requirements:
• Install, calibrate, maintain, and operate according to the manu-
facturer's specifications a" flow indicator that provides a record
of vent stream flow to the control device at least once every
hour. The flow indicator sensor shall be installed in the vent
stream at the nearest feasible point to the control device inlet,
but before being combined with other vent streams.
• Install a temperature monitoring device equipped with a continuous
recorder. The device shall be capable of monitoring temperature
at two locations, and have an accuracy of ±1 percent of the
. temperature being monitored in degrees Celsius or ±0.5 °C, which-
ever is greater. One temperature sensor shall be installed in the
vent stream at the nearest possible point to the catalyst bed
inlet, and a second temperature sensor shall be installed in the
vent stream at the nearest feasible point to the catalyst bed
outlet.
Also, as with thermal incineration, visible emissions from a catalytic
incinerator indicate incomplete combustion, i.e., inefficient operation.
5.3.2.4 Boilers or Process Heaters. Fired-process equipment or fur-
naces make up a category that includes boilers, heaters, and incinerators.
Such equipment are employed in most chemical plants to provide heat conven-
iently, efficiently, and at the temperature level required. Indirect-fired
furnaces (boilers and process heaters) are those where heating media are
separated from process streams.
Industrial boilers are of two types. Fire-tube unit:* are similar to
shell-and-tube heat exchangers with combustion gases flowing through the
tubes. The center tube of the bundle, much larger than the rest, comprises
the combustion chamber. Flow reverses at the end of the bundle and passes
back through numerous smaller outer tubes. Efficient and compact, fire-tube
boilers are always shop fabricated. Steam pressures are limited by the
strength of the large cylindrical shell. These, of course, are less than
could be contained in smaller tubes. Thus, fire-tube furnaces are employed
5-42
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primarily for generating modest amounts of low-pressure saturated steam.,
Because of geometry, the combustion chamber and flue gas.tubes are not
compatible with continuous cleaning. This, in addition to a limited combus-
tion residence time, restricts fire-tube boilers to fuels no dirtier or less
convenient than residual oil.
Water-tube boilers contain steam within the tubes while combustion
occurs in a box!ike open chamber. In large boilers, hundreds to thousands
of tubes, usually 7 to 12 cm (2.7 to 4.7 in.) in diameter, are installed
side by side, forming the walls of the combustion chamber and of baffles
that control flow of and remove heat from combustion gases. In the combus-
tion area, known as the radiant section, gas temperatures drop from about
1,930 °C {3,506 °F) to 1,030 °C (1,886 °F). After combustion products have
been thus cooled by .radiation to wall tubes, they pass at high velocity
through slots between more tubes suspended as large banks in the gas stream.
This is known as the convection section. In the radiant section, such
direct exposure to higher temperature gases would damage the tube metal.
Gas entering'the convection section at about 1,030 °C (1,886 °F) leaves near
330 °C (626 °F). Tubes in the radiant section are normally filled with
circulating, boiling liquid to avoid hot spots. When superheating is
desired, this occurs in the hot end of the convection system.
Because small tubes are capable of much higher pressures than is the
large shell of a fire-tube boiler, elevated steam pressures as well as
superheat are common in water-tube furnaces. Steam at 45 bar (652.7 psi)
pressure superheated to 400 °C (752 °F) is a typical maximum. Saturated
process steam is also commonly generated at pressures of 17 and 33 bar
(246.6 and 478.6 psi) in water-tube boilers. Pressures lower than this are
impractical because of distribution piping costs. If lower pressure process
steam is needed in substantial quantity (i.e., greater than 5 kg/s [11.023
lb/s]), it will probably prove practical to generate high-pressure steam at
45 bar (652.7 psi) and 400 °C (752 °F), pass it through an expansion turbine
to recover cheap power, and employ the exhaust for process needs. This is
known as cogeneration.
Because of the large, open combustion chambers, coal and wood fueling
is common in water-tube furnaces. Flyash and soot are cleaned from convec-
tion tubes by automatic "soot blowers" that direct high-velocity steam or
5-43
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air jets against outer surfaces of tubes while the boiler is operating.
Water-tube boilers can be shop fabricated with heating duties up to
100,000 kJ/s (94,860 Btu/s). Modern units burning coal arid wood or residual
oil are fitted with dust collectors for flyash removal.
Frequently, the need arises for process heat at temperatures above
those available from the systems -already described. In these situations and
even where an intermediate medium can be used, the process; fluid itself is
passed through tube coils in a fired furnace. The process; system may be
reactive, as with pyrolysis furnaces, which have been used extensively to
thermally crack hydrocarbons for ethylene and propylene manufacture. The
process stream may be nonreactive as well. Such is the case when a fired
furnace is us'ed as a reboiler in the distillation of heavy petroleum
liqui-ds.
Boilers and process heaters can be designed as control devices to limit
organic emissions by incorporating the vent stream (e.g., distillation) with-
the inlet fuel, or by feeding the stream into the boiler or process heater
through a separate burner. These devices are most applicable where high
vent stream heat recovery potential exists.
The primary purpose of a boiler is to generate steam,. Process heaters
are applied within a TSDF for a variety of reasons including preheating and
reboiling for some distillation operations. Both devices are important to
the operation of a TSDF, and as a result only streams that are certain not
to reduce the device's performance or reliability warrant use of a boiler or
process heater as a combustion control device. Note; Boilers and process
heaters can be used without a RCRA permit only if they burn gases, not
hazardous waste liquids (not even hazardous waste liquids coming from an air
vent). Variations in vent stream flow rate and/or heating value could
affect the heat output or flame stability of a boiler or process heater and
should be considered when using these combustion devices. Performance or
reliability may be affected by the presence of corrosive products in the
vent stream. Because these compounds could corrode boiler or process heater
materials, vent streams with a relatively high concentration of halogenated
or sulfur-containing compounds are usually not combusted in boilers or
process heaters. When corrosive organic compounds are combusted, the flue
gas temperature must be maintained above the acid dewpoint to prevent acid
deposition and subsequent corrosion from occurring.
5-44
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The introduction of a distillation vent stream into the furnace of a
boiler or heater could alter the heat transfer characteristics of the
furnace. Heat transfer characteristics are dependent on the flow rate,
heating value, and elemental composition of the distillation vent stream, as
well as the size and type of heat generating unit being used. Often, there
is no significant alteration, of the heat transfer, and the organic content
of the distill atit>n stream can, in some cases, lead to a reduction in the
amount of fuel required to achieve the desired heat production. In other
cases, the change in heat transfer characteristics after introduction of the
distillation stream may adversely affect the performance of the heat gener-
ating unit and increase fuel requirements. If for a given distillation vent
stream increased fuel is required to achieve design heat production to the
degree that equipment damage (e.g., tube failure due to local hot spots)
might result, then heat-generating units would not be applicable as an
organic control device for that vent stream. In addition to these relia-
bility problems, potential safety problems are»associated with ducting
distillation vents to a boiler or process heater. Variation in the flow
rate and organic content of the vent stream could, in some cases, lead to
explosive mixtures that could cause extensive damage. Another related
problem is flame fluttering that could result from these variations.
When a boiler or process heater is applicable and available, either is
an excellent control device because each can provide at least 98 percent
destruction of organics. However, to ensure a control efficiency of 98 >
percent, the waste must be introduced into the flame zone. Temperatures are
highest at the flame zone, and combustion kinetics are much more rapid, •
resulting in high destruction efficiencies. In addition, near complete
recovery of the vent stream heat content is possible.
The control efficiency or organic vapor removal efficiency can be
determined at any given time as follows:
Mi -
Mi
ER x 100 = % Removal
(5-9)
where:
Mi = Inlet organic mass flow rate, Ib/h,
5-45
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M0 s Outlet organic mass flow rate, Ib/h,
ER - Organic vapor removal/control efficiency.
1. Monitor the concentration of the inlet airstream and the outlet
airstream together with the volume flow rate and convert to a mass
flow rate.
2.. Place the mass flow rate values into the equation for
instantaneous removal efficiency (see above).
For an average removal efficiency over a defined time interval t, the
concentration of .the inlet and outlet airstreams should be monitored over
the time interval t and averaged by extrapolation or time integration.
The parameters that affect the efficiency of a thermal incinerator
(e.g., boilers and process heaters) are the same parameters that affect the
efficiency of these devices when they function as air pollution control
devices. These parameters are temperature, residence time, inlet organic
concentration, compound type, and flow regime (mixing). Accordingly, to
ensure that the boilers or process heaters are maintained within design
specifications, Sections 264.1033(f) and 265.1033(f) require the owner/oper-
ator to monitor, inspect, and maintain each boiler or process heater
required to comply with facility process vent emission rate limits by imple-
menting the following requirements:
• Install, calibrate, maintain, and operate according to the manu-
facturer's specifications a flow indicator that provides a record
of vent stream flow to the control device at least once every
hour. The flow indicator sensor shall be installed in the vent
stream at the nearest feasible point to the control device inlet,
but before being combined with other vent streams.
• For boilers or process heaters having a design heat input capacity
less than 44 MW, install a temperature monitoring device equipped
with a continuous recorder. The device shall have an accuracy of
±1 percent of the temperature being monitored in degrees Celsius
or ±0.5 °C, whichever is greater. The temperature sensor shall be
installed at a location in the furnace downstream of the combus-
tion zone.
• For boilers or process heaters having a design heat input capacity
greater than or equal to 44 MW, install a monitoring device
equipped with a continuous recorder to measure a parameter that
demonstrates good combustion operating practices are being used
(e.g., concentration of CO, 02, hydrocarbons).
5-46
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5.3.3 Adsorption
Adsorption is a mass-transfer operation involving interaction between
gaseous and solid-phase components. The gas-phase (adsorbate) surface is
captured on the solid-phase (adsorbent) surface by physical or chemical
adsorption mechanisms. Physical adsorption is a mechanism that takes place
when intermolecular (van der Waals) forces attract and hold the gas mole-
cules to the solid surface.38 Chemisorption occurs when a chemical bond
forms between the gas- and solid-phase molecules. A physically adsorbed
molecule can readily be removed from the adsorbent (under suitable tempera-
ture and pressure conditions), while the removal of a chemisorbed component
is much more difficult. .
The most commonly encountered industrial adsorption systems use acti-
vated carbon as the adsorbent. Activated carbon is effective in capturing
certain organic vapors by the physical adsorption mechanism. However,
activated carbon has a finite adsorption capacity. When the carbon becomes -
saturated (i.e., all of the carbon surface is covered with organic mate-
rial), there is no further organic removal; all vapors pass through the
carbon bed. At this point (referred to as "breakthrough"), the organic
compounds must be removed from the carbon before adsorption-can resume.
This process is called desorption or regeneration. The organics may be
released for recovery by regeneration of the adsorption bed with steam.
Oxygenated adsorbents such as silica gels, diatomaceous earth, alumina,
or synthetic zeolites exhibit a greater selectivity than activated carbon
for capturing some compounds. These adsorbents have a strong preferential
affinity for water vapor over organic gases and would be of little use for
the high moisture gas streams from some distillation vents.39
The two basic configurations for carbon adsorption systems are regen-
erative and nonregenerative systems. In regenerative systems, fixed-bed
carbon adsorbers are used for controlling continuous, organic gas streams
with flow rates ranging from 30 to over 3,000 m3/min (1,000 to over 100,000
ft^/min). The organic concentration can be as low as several parts per
billion by volume (ppbv) or as high as 25 percent of the lower explosive
limit of the vapor stream constituents. Fixed-bed carbon adsorbers may be
operated in either intermittent or continuous modes. For intermittent
operation, the adsorber removes organics only during a specific time period.
5-47
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Intermittent mode of operation allows a single carbon bed to be used because
it can be regenerated during the off-line periods. For continuous opera-
tion, the unit is equipped with two or more carbon beds so that at least one
bed is always available for adsorption while other beds are being regener-
ated. In nonregenerative systems, the spent carbon is replaced with fresh
carbon and is disposed of or reactivated off-site for eventual reuse.
Nonregenerative systems (e.g., carbon canisters) are applicable for control-
ling organic emissions that are expected to vary in types of organics and
concentrations and to occur at relatively low total mass rates. Carbon
canisters typically consist of a 0.21-m3 (55-gal) drum with inlet and outlet
pipe fittings. A typical canister unit is filled with 70 to 90 kg (150 to
200 Ib) of activated carbon. Use of carbon canisters is limited to
controlling low-volume gas streams with flow rates less than 3 m3/min
(100 ft3/min). Carbon cannot be regenerated directly in the canister. Once
the activated carbon in the canister becomes saturated by the organic
vapors, the carbon canister must be removed and replaced with, a fresh carbon
canister. The spent carbon canister is then recycled or discarded depending
on site-specific factors.
The design of a carbon adsorption system depends on the chemical char-
acteristics of the organic compound being recovered, the physical properties
of the vent gas stream (temperature, pressure, and volumetric flow rate),
and the physical properties of the adsorbent. The mass flow rate of organic
from the gas phase to the surface of the adsorbent (the rate of capture) is
directly proportional to the difference in organic concentration between the
gas phase and the solid surface. In addition, the mass flow rate of organic
is dependent on the adsorbent bed volume, the surface area of adsorbent
available to capture organic, and the rate of diffusion of organic through
the gas film at the gas- and solid-phase interface. Physical adsorption is
an exothermic operation that is most efficient within a narrow range of
temperature and pressure. A schematic diagram of a typical fixed-bed,
regenerative carbon adsorption system is given in Figure 5-14. The process
vent gases are filtered and cooled (1) before entering the carbon bed. The
inlet gases to an adsorption unit are filtered to prevent: bed contamination.
The gases are cooled to maintain the bed at optimum operating temperature
and to prevent fires or polymerization of the hydrocarbons. Vapors entering
5-48
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Organic-us«
Vent
FU.7S31KG
AXO
SMUKS
A8SQR8ES 1
lAOSORBlHG)
OEWKTOR
ma/or
OtSTltJUHC TOVES
Organic
(S)
law
Figure 5-14. Two-stage regenerative adsorption system.
5-49
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the adsorber stage of the system (2)'are passed through the porous activated
carbon bed.
Adsorption of inlet vapors occurs in the bed until the activated carbon
is saturated with organics. The dynamics of the process may be illustrated
by viewing the carbon bed as a series of layers or mass-transfer zones (3a,
b, c). Gases entering the bed are highly adsorbed first in zone (a).
Because most of the organic is adsorbed in zone (a), very little adsorption
takes place in zones (b) and (c). Adsorption in zone (b) increases as zone
(a) becomes saturated with organics and proceeds through zone (c). When the
bed is completely saturated (breakthrough), the incoming organic-laden vent
gases are routed to an alternate bed while the saturated carbon bed is
regenerated.
Typically, the duration of the adsorption cycle varies considerably
depending on the solvent being reclaimed and its regeneration characteris-
tics. To maximize performance of the carbon adsorber, the adsorption cycle
duration should be extended to just below the breakpoint of the bed. The
bed's breakthrough can be determined by using organic vapor analyzers simul-
taneously on the inlet and outlet streams of the adsorber bed. Breakthrough
history can be determined on the particular process being controlled, then
the regeneration of the bed can be started only when absolutely necessary.
Regeneration of the carbon bed is accomplished by heating the bed or
applying vacuum to draw off the adsorbed gases. Low-pressure steam (4) is
frequently used as a heat source to strip the adsorbent of organic vapor.
The steam-laden vapors are then sent to a condenser (5) and on to some type
of solvent recovery system (6). The regenerated bed is put back into active
service while the saturated bed is purged of organics. The regeneration
process may be repeated numerous times, but eventually the carbon must be
replaced.
The system variables that influence carbon adsorption system perform-
ance include temperature, pressure, gas velocity, bed depth, humidity, and
presence of contaminants in the gas stream. For physical adsorption
processes, the capacity of an adsorbent decreases as system temperature
increases. Adsorption capacity increases with an increase in the partial
pressure of the vapor, which is proportional to the total pressure of the
system. Residence time in the bed is a function of gas velocity. Capture
5-50
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efficiency, the percentage of organics removed from the inlet gas stream by
the adsorbent, is directly related to residence time. Gas velocity can be
determined for a given volume of contaminant gas as a function of the
diameter of the adsorber.
Providing a sufficient bed depth is very important in achieving effi-
cient organic removal. If the adsorber bed depth is shorter than the
required mass transfer zone (MTZ), breakthrough will occur immediately, thus
rendering the system ineffective. The MTZ i's a function of six factors:
the adsorbent particle size, gas velocity, adsorbate concentration, fluid
properties of the gas stream, temperature, and pressure of the system.' MTZ
can be estimated from experimental data as follows:
1
MTZ S
1 - X.
(5-10)
where:
D
CB
= Bed depth, m
= Breakthrough capacity, % (may be obtained from carbon suppliers
in some cases; usually determined experimentally)
= Saturation capacity, % (may be obtained from the carbon
supplier)
= Degree of saturation in the MTZ, % (usually assumed to be 50
percent)
MTZ
= Length of MTZ, m.
Actual bed depths are usually many times the MTZ to allow for adequate cycle
times.
Activated carbon preferentially adsorbs nonpolar hydrocarbons over
polar water vapor. However, at relative humidities over 50 percent, water
molecules will begin to compete with the hydrocarbon molecules for adsorp-
tion sites. Consequently, the carbon bed working capacity is'decreased.
Above an organic concentration of 1,000 ppm, high moisture does not signif-
icantly affect performance. Thus, obtaining good adsorber performance for
gas streams with a high relative humidity (i,e., >50 percent) and low
organic concentration (<1,000 ppm) requires preconditioning the gas stream
upstream of the carbon bed. This can be accomplished using a dehumidifica-
tion system, installing duct burners to heat the gas stream, or diluting the
5-51
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.gas stream with ambient air. In addition, contaminants such as particu-
lates, entrained liquid droplets, and organic compounds with high boiling
points can also reduce adsorber efficiency.
Carbon bed operating temperature can also affect carbon adsorber
performance. Excessive bed temperatures can result due to the release of
heat from exothermic chemical reactions that may occur in the carbon bed.
Ketones and aldehydes are especially reactive compounds that exothermically
polymerize in the carbon bed. If temperatures rise 'too high, spontaneous
combustion will result in carbon bed fires. To avoid this problem, carbon
adsorbers applied to gas streams containing these types of compounds must be
carefully designed and operated to allow sufficient airflow through the bed
to remove excess heat.
In determining the control efficiency for'a carbon adsorption system,
the entire system must be considered. If the carbon adsorption system is
nonregenerative, the control efficiency or organic vapor removal efficiency
can be determined at any given time as follows:
Mi - Mo
Mi
ER x 100 = % Removal
(5-11)
where:
Mi - Inlet organic vapor mass flow rate, Ib/h
M0 = Outlet organic vapor mass flow rate, Ib/h
ER - Organic vapor removal/control efficiency.
1. Monitor the inlet airstream and the outlet airstream simultan-
eously.
2. Place the mass flow rate values into the equation for instan-
taneous removal efficiency.
For an average removal efficiency over a defined time interval t, the
mass flow rate of the inlet and outlet airstreams should be monitored over
the time interval t and averaged by extrapolation or time integration. If
the carbon adsorption system is regenerative, and regeneration is conducted
on-site, the control efficiency can be calculated as follows:
5-52
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MI-(MO +MO )
ri 2- = ED ; ER x 100 = % Removal , (5-12)
rU
where:
MJ = Inlet organic vapor mass flow rate, Ib/h
M = Outlet organic vapor mass flow rate, Ib/h
M - Outlet organic vapor mass flow rate of uncondensed vapor from
regeneration, Ib/h
Organic vapor removal /control efficiency.
2
En
K
For gas-phase carbon adsorption applications, a fixed-bed, regenerate
carbon adsorption system typically involves two separate steps. The first
is the adsorption step where the organic (adsorbate) is adsorbed onto the
surface of the activated carbon, (adsorbent). The second step is .where the .
adsorbate is removed from the carbon (desorpti on) and recovered for reuse.
Both of these steps are equally important in the overall process, and any
organics released to the atmosphere in either step must be accounted for and
included in the control device efficiency determination. For example,
regeneration or desorption is usually accomplished by passing steam through
the bed countercurrent to the vent stream flow. Regeneration can also be
accomplished by applying heat to burn the adsorbate. When steam is used in
the regeneration process, the steam carries the desorbed organics from the
bed and is then condensed and decanted. Any organics that pass through the
i
condenser (i.e., not condensed) and are vented to the atmosphere should be
quantified and accounted for in the efficiency determination of the overall
carbon adsorption system. Also, if there are organics in the aqueous phase
of the steam condensate that go untreated and eventually escape to the
atmosphere, these too must be accounted for in the control device efficiency
determination. The TSDF owner/operator is expected to ensure that organic
emissions resulting from regeneration are also controlled and that condensed
organic waste is proper.ly disposed.
Emission source test data for full-sized, fixed-bed carbon adsorbers
operating in industrial applications has been compiled by EPA for a study of
carbon adsorber performance.40 The analysis of these data supports the
conclusion that for well -designed and operated carbon adsorbers, continuous
5-53
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organic removal efficiencies of at least 95 percent are achievable over long
periods. Several units have been shown to continuously achieve organic
removal efficiences of 97 to 99 percent. An equivalent level of performance
is indicated by results of emission source tests conducted on carbon
canisters.
To ensure that the carbon adsorption system is operated and maintained.
within'design specifications, Sections 264.1060(f) and 265.1060(f) require
the owner/operator to monitor, inspect, and maintain each carbon adsorption
tsystem required to comply with facility process vent emission rate limits by
implementing the following requirements:
• Install, calibrate, maintain, and operate according to the manu-
facturer's specifications a flow indicator that provides a record
of vent stream flow to the control device at least once every
hour. The flow indicator sensor shall be installed in the vent
stream at the nearest feasible point to the control device inlet,
but before being combined with other, vent streams.
• For carbon adsorption systems that regenerate the carbon bed
directly in the control device such as a fixed-bed carbon
adsorber, install a monitoring device equipped with a continuous
recorder to measure the concentration level of the organic
compounds in the exhaust vent stream from the carbon bed; or
• Install a monitoring device equipped with a continuous recorder to
measure a parameter that demonstrates the carbon bed is regener-
ated on a regular, predetermined time cycle.
• For a carbon adsorption system in which the carbon bed is regener-
ated directly on-site in the control device such as a fixed-bed
carbon adsorber, the owner/operator is to replace the existing
carbon in the control device with fresh carbon at a regular,
predetermined time interval that is no longer than the carbon
service life established as a requirement ,of Section
270.25(e)(3)(vi).
• For a carbon adsorption system in which the carbon bed is not
regenerated directly on-site in the control device such as a
carbon canister, replace the existing carbon in the control device
with fresh carbon on a regular basis by using one of the following
procedures:
Monitor the concentration level of the organic compounds in
the exhaust vent stream from the carbon adsorption system on
a regular schedule, and replace the existing carbon with
fresh carbon immediately when carbon breakthrough is indi-
cated. The monitoring frequency shall be at an interval no
5-54
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greater than 10 percent of the time required to consume the
total carbon working capacity established as a requirement of
Section 270.'24(e) (3) (vii).
~ Replace the existing carbon with fresh carbon at a regular, ^
predetermined time interval that is less than the design
service life of the carbon established as a requirement of
Section 270.24(d)(3)(vii).
The amount of organic recovered from the regenerated bed as a function of
cycle time provides a secondary indicator of system efficiency and must be
monitored.
-\
5.4 CONTROL DEVICE DESIGN CONSIDERATIONS REQUIRED BY THE REGULATION
Design analysis for air pollution control equipment is performed for a
variety of reasons, including (1) to anticipate compliance with applicable
air pollution codes, (2) to estimate performance of existing control equip-
ment, (3) to evaluate the feasibility of a proposed equipment design, or
(4) to assess the effect of process modification on control equipment
performance. Regardless of the reason for conducting the design analysis,
air pollution control systems are usually designed to control emissions at a
.minimum cost with maximum reliability. The basic tradeoffs involve
decisions between collection .efficiency (the percentage reduction in
pollutant concentration between the inlet and outlet of the control device),
installation cost, and operating cost.
Air pollution control equipment is often designed specifically for the
source on which it is installed. The regulation requires that a design
analysis be both conducted and documented through engineering calculations,
vendor certification, and/or emission testing (Sections 264.1035(b)(4)).
The design analysis, must establish values for certain key operating param-
eters that would be indicative of the control device operating at design
efficiency. The regulation then specifies operating limits for these key
operating parameters based on the design values established during the de-
sign analysis (Sections 264.1035(b)(4)(iii)(A)-(G) and 265.1035(b)(4)(iii)
(A)-(G)). The owner/operator must then report when any monitored key
parameter exceeds these limits for more than 24 hours (see Chapters 7.0 and
8.0 for details on and a discussion of the monitoring and recordkeeping
requirements of the regulation). The key operating parameters that must be
established during the design analysis are as follows:
5-55
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• Thermal Incinerator—The design minimum and average tempera-
ture in the combustion zone and the combustion zone residence
time.
• Catalytic Incinerator—The design minimum and average temper-
ature across the catalyst bed inlet and outlet.
• Boiler or Process Heater—The design minimum and average
flame zone temperatures, the flame zone residence time, the
description of method and location where the vent; stream is
introduced into the flame zone.
• Flare—Operating limits for key operating parameters have
already been determined for flares (see Sections 264.1033(d)
and 265.1033(d)); therefore, no design analysis is required.
* Condenser—The design outlet organic concentration level, the
design average temperature of the condenser exhaust vent
stream, the design average temperature of the coolant fluid
at the condenser inlet and outlet.
• ' Carbon Adsorption System (Regenerative)—Design exhaust vent
stream organic compound concentration level, the number and
capacity of carbon beds, the type and capacity of carbon
beds, the type and working capacity of activated carbon beds,
design total steam flow over the period of each complete
carbon bed regeneration cycle, the duration of the carbon bed
steaming and cooling/drying cycles, the design carbon bed
temperature after regeneration, the design carbon bed regen-
eration time, and the design service life of carbon.
• Carbon Adsorption System (Nonreqenerative)—The design outlet
organic concentration level, the capacity of carbon bed, the
type and working capacity of activated carbon, and the design
carbon replacement interval based on the total carbon working
capacity of the control device and source operating schedule.
Other operating parameters are required by the regulation to be
considered during the design analysis. However, the regulation does not
require design values for these parameters to be established. These
operating parameters are the same for all the control devices and'are as
follows: vent stream composition, constituent concentrations, and flow
rate. The condenser and carbon adsorber both have two additional param-
eters, relative humidity and temperature, that also must be considered in
the design analysis. Appendix F provides design checklists of all required
operating parameters for carbon adsorption, condensers, combustion devices,
and flares.
5-56
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Numerous procedures are used to design air pollution control systems.
These procedures range in difficulty from shortcut "rules of thumb" to in-
depth design procedures based on pilot plant data. The "rules of thumb" in
the following paragraphs can be applied when reviewing combustion and
noncombustion control device designs and can be used to "red flag"
parameters that appear out of the ordinary. .
5.4.1 Heat Exchanger Rules of Thumb41"43 °
1. Corrosive fluids are usually passed on the tube side.
2. High-pressure fluids usually pass on the tube side. Plate
exchangers are not recommended for a pressure above 10 bar.
3 Fouling or scaling fluids are placed on the tube side of fixed-
tube exchangers. If deposits can be removed by high-velocity
steam or water jets, fouling fluids may also pass on the shell
side of exchangers that can be exposed for cleaning.
4 High-viscosity fluids are usually placed in the shell side of
conventional shell-and-tube exchangers. Plate exchangers are
attractive for such service. For viscosities greater than 1
Pa • s, scraped-wall exchangers are attractive.
5. Condensing vapors are usually placed on the shell side.
6. Determine exchanger duty from an energy balance on one side.
Allow up to 10 percent losses depending on shell-side temperature.
7. Approach AT's (mean temperature difference) are .approximately
10 °C (18 °F) for liquids or systems with high heat transfer
coefficients.
8. Approach AT's (mean temperature difference) are approximately
50 °C (90 °F) for gases or systems with low heat transfer
coefficients.
9. Pressure drops are approximately 0.2 to 0.6 bar for liquid
heating, cooling, or boiling. For condensation or heat transfer
to or from gases, pressure drops are approximately 0.1 bar.
10. The EPA has published guidelines that provide condenser outlet gas
temperatures that should not be exceeded when condensing organics
with certain vapor pressures (see Table 5-3). These guidelines
are useful as an indicator of condenser performance but it .must be
noted that the guidelines'do not account for the molecular weight
or initial concentration of the organic to be condensed, each of
which has great bearing on how much organic is condensed. For
example, if the organic concentration is higher than the satura-
tion concentration at the condensing temperature, condensation is
5-57
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TABLE 5-3. RECOMMENDED OUTLET GAS TEMPERATURES
1. -25 °C when condensing VOC of vapor pressure
>40 kPa (5.8 psia)a
2. -15 °C when condensing VOC of vapor pressure
>20 kPa (2.9 psia)
3. 0 °C when condensing VOC of vapor pressure >10 kPa
(1.5 psia)
4. 10 °C when condensing VOC of vapor pressure >7 kPa
(1.0 psia)
5. 25 °C when condensing VOC of vapor pressure
>3.5 kPa (0.5 psia)
aVapor pressures as measured at 20 °C.
Source: U.S. Environmental Protection Agency.
Control of Volatile Organic Emissions from
Manufacture of Synthesized Pharmaceutical
Products'. OAQPS Guideline Series. -Publica-
tion No. EPA-450/2-78-029. December 1978.
p. 1-5.
expected to occur; however, if the initial concentration is below
the saturation concentration, little or no condensation is
expected.
5.4.2 Adsorption Rules of Thumb
1. Adsorber temperatures are usually kept below 55 °C (130 °F); inlet
gas temperature should not exceed about 37.7 °C (100 °F) for
sustained operations.
2. Some adsorbents will remove water vapor molecules as well as
molecules of the contaminated gas. Carbon systems should be
operated at relative humidities of 50 percent or less.
3. All particulate matter larger than about 5 /*m in size should be
removed before the gas enters the adsorber in a regenerate
system.
4. Solvents should have a boiling point less than 260 °C (500 °F) so
that they may be readily stripped from the adsorbent by the low-
pressure steam.
5. To achieve 90 percent or greater capture efficiency, most carbon
adsorption systems are designed for a maximum airflow velocity of
30 m/min (100 ft/min) through the adsorber. A lower limit of at
least 6 m/min (20 ft/min) is maintained to avoid flow distribution
problems such as channeling.
5-58
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6. Pressure drops in fixed carbon beds normally range from 750 to
3,730 Pa (3 to 15 in. H£0) depending on the gas velocity, bed
depth, and carbon particle size.
7 The optimum steam requirement for thermal swing regeneration
usually ranges from 0.25 to 0.35 kg of steam/kg (0.55 to .0.77 Ib
of steam/lb) of carbon. Steam in these systems is usually
supplied at pressures ranging from 21 to 103 kPa (3 to 15 psig).
8. Maximum bed depth for a fixed horizontal bed is recommended as
1.2 m (4 ft). The maximum adsorbent depth of 1.2 m (4 ft) is
based on pressure drop considerations;
9. Horizontal flow adsorbers are used for larger flow rates.
Adsorbers of this type are manufactured as a package system
capable of handling flow rates up to 1,150 nP/s (40,000 cfm).
5.4.3 Combustion Device Rules of Thumb
1.
2.
3.
4.
5.
6.
Thermal incinerators generally operate at 700 to 820 °C (1,300 to
1,500 °F) with residence times of approximately 0.1 to 0.6 s.
Tes.t results and combustion kinetics analyses indicated that
thermal vapor incineration destroys at least 98 percent of
nonhalogenated organic compounds in the vapor stream at a
temperature of 870 °C (1,600 °F) and a residence time of 0.75
seconds.44 If the vapor stream contains halogenated compounds, a
temperature of 1,100 °C (2,000 °F) and a residence time of .
1 second is needed to achieve a 98-percent destruction
efficiency.45 • . •
Catalytic incinerators generally operate at 370 to 480 °C (700 to
900 °F) with residence times of a few hundreths of a second.
Process boilers are normally designed to operate in excess of
980 8C (1,800 °F) with a flue gas residence time of 0.5 to 3.0 s.
Pressure drops in catalytic incinerators normally range from 62 to
125 Pa (0.25 to 0.5 in. H20).
Typical gas velocities for catalytic incinerators range from 20 to
200 feet per second (fps) (6 to 60 m/s).
Incinerator warmup usually begins with an outlet temperature of
93.3 °C (200 °F). This temperature is then held for 1 h. There-
after, the outlet temperature is increased at the rate of 93.3 °C
(200 °F) per hour until an outlet temperature of 315.5 °C (600 °F)
is reached. Then" the outlet temperature may be increased at the
rate of 93.3 to 204.4 °C (200 to 400 8F) per hour until the final
operating temperature is reached.
Typical maximum flare capacity is as follows: ground flare, 80 to
100 thousand lb/h; and elevated flare, 1,000 to 2,000
thousand Ib/h.
5-59
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5.5 ADDITIONAL CONTROLS FOR PROCESS VENTS
Permit writers, through the omnibus permitting authority of Section
a
270.32, are allowed to require emission controls that are more stringent
than those specified by a standard on a case-by-case basis. This authority
could be used in situations where the permit writer deems there is an
unacceptably high risk after application of controls required by an emission
standard.
Guidance to help permit writers identify facilities that would poten-
tially have high residual risk due to air emissions is being prepared by
EPA. This section provides a general discussion of the controls available
for process vents (i.e., condensers, carbon adsorbers, flares, incinerators,
boilers, and process heaters) that would result in control levels more
stringent -than the level achieved under the requirements of Subpart AA of
Parts 264 and 265. •
5.5.1 Condensers
Control devices involving vapor recovery (e.g., condensers) must be
designed and operated to recover the organic vapors vented to them with an
efficiency of 95 percent in order to satisfy the requirements of Subpart AA
of the standards unless the total organic emission limits of Sections
264.1032(a)(l) and 265.1032(a)(1) for all affected process vents can be
attained at efficiencies less than 95 percent. The regulation requires that
the design outlet organic concentration level, the design average tempera-
ture of the condenser exhaust vent stream, and the design average tempera-
ture of the coolant fluid at the condenser inlet and outlet be established
in addition to the vent stream flow rate and coolant and exhaust vent
temperature or concentration of organics in the exhaust vent being moni-
tored. This is to ensure that the condenser is operated and maintained
within design specifications and is therefore achieving an efficiency of 95
percent.
Additional control gre'ater than the 95 percent required by the regula-
tion can also be achieved in some situations. Condenser efficiency is
dependent on both the concentration and volatility of organics present-in
the vent stream. Compounds having lower volatilities tend to condense more
readily than those of higher volatility. As a result, higher efficiencies
are obtainable with vent gas streams containing the less volatile organic
5-60
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compounds. The efficiency of a condenser is directly related to the
concentration of the inlet vent gas stream. In general, as the concen-
tration increases, the efficiency of the condenser also increases. Con-
versely, low concentrations also result in low efficiencies. (See Appendix
E for an analysis of the effect of concentration on efficiency.) Therefore,
any .additional control beyond that set forth by the standard to achieve 95
percent control efficiency must be determined on a" case-by-case basis only
and will depend on the vent gas organic concentration and volatility of the
constituents in the vent stream.
5.5.2 Flares
Flaring, unlike heaters, boilers, and incinerators in which combustion
takes place in an enclosed chamber, is an open combustion process. For this
reason, it is very difficult and economically impracticable to measure
emissions from a flare. A standard of performance is therefore not feasible
for a flare. Subpart AA of the standard, however, does require that certain
conditions be met for process vent streams using flares in order to achieve
an efficiency of 95 percent or greater. These conditions are stated in
Sections 264.1033 and 265.1033 of the regulation. Because these conditions
were generated from test data that show flares meeting certain conditions
achieve 98 percent emission reduction, it is very likely that an owner or
operator who operates a flare to meet the conditions of Section 264.1033 and
265.1033 will achieve 98 percent destruction efficiency. It should be
noted, however, that the"conditions established from available test data are
the only conditions for which EPA has data supporting that flares achieve 98
percent emission reduction.
5.5.3 Thermal Incineration
The process vent rules require that a design-analysis be conducted on
control devices (i.e., thermal and catalytic incinerators) to establish key
operating parameters indicative of a control efficiency of 95 percent or
greater.. In the case of a thermal incinerator, the key operating parameters
that must be established are the design minimum and average temperature in
the combustion zone and the combustion zone residence time. The regulation
also requires that the vent stream flow rate as well as the temperature
downstream of the combustion zone be monitored to ensure that the thermal
incinerator is being operated within design specifications and therefore
5-61
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achieving a destruction efficiency of 95 percent or greater (see Sections
264.1033 and 265.1033 as well as Sections 264.1035 and 265.1035, respec-
tively, for monitoring requirements and key operating parameters for
catalytic incinerators). The level of control required by the standards
does not result in the highest level of emission control that could be
achieved by thermal incinerators. For example, all new incinerators can
achieve at least 98 weight percent reduction in total organics (minus
methane and ethane), provided that the total organic concentration (minus
methane and ethane) of the process vent stream being incinerated is greater
than approximately 2,000 ppmv (volume, by compound). However, the inlet
stream composition greatly affects the maximum achievable destruction
efficiency. Much -slower combustion reaction rates occur at. lower inlet
concentrations; therefore, the maximum achievable destruction efficiency
decreases as inlet concentration decreases. In summary, additional control
greater than the 95 percent required by the regulation can be accomplished
by thermal incinerators through proper design, but the inlet organic concen-
tration of the thermal incinerator feed steam must be maintained at greater
than 2,000 ppmv.
5.5.4 Boilers and Heaters
In the case of boilers and process heaters, the regulation requires
that a 95-percent organic reduction be achieved. In addition, the regula-
tion requires that this reduction be validated by establishing key operating
parameters in the design of the boiler or process heater and by monitoring
certain parameters to ensure the design specification is being maintained.
These key operating parameters are the design and average flame zone
temperatures, the flame zone residence time, and the description of method
and location where the vent stream is introduced into the flame zone. The
parameters that are required to be monitored are the vent stream flow rate
into the control device and the temperature downstream of the combustion
zone (if the design heat input capacity is less than 44 MW) or a parameter
that demonstrates good combustion operating practices are being used (if the
design heat input capacity is greater than 44 MW). Once these design opera-
ting parameters have been established and the specified operating parameters
have been monitored, emission reductions of 95 percent, as required by the
5-62
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standard, can be expected for the boiler or process heater. However,
greater control than that required by the regulation can be obtained.
Boilers and process heaters can achieve a 98 weight percent reduction,
provided that the waste stream is introduced into the flame zone where
temperatures are highest. Because higher temperatures are present in the
flame zone, more rapid combustion kinetics also occurs in the flame zone.
As a result, higher destruction efficiencies are attainable. In fact,
greater than 98 percent destruction efficiencies have been demonstrated in
tests of the combustion of organic compounds burned as fuels in boilers and
process heaters. Additional control greater than the 95 percent required by
the regulation can be accomplished, but the vent stream must be introduced
into the flame zone. •„••..
5.5.5 Carbon Adsorption
Subpart AA of the regulation requires that carbon adsorbers achieve a
control efficiency of 95 percent unless the total organic emission limits of
Sections 264.1032(a)(1) and 265.1032(a)(1) for all affected process vents
can be attained at efficiencies less than 95 percent. Subpart AA also
requires that this performance standard be demonstrated by conducting a
design analysis in which values are established for key operating parameters
that would be indicative of the carbon adsorber operating at the design
efficiency. For regenerative carbon adsorption systems, the key operating
parameters are design exhaust vent stream organic compound concentration
level, the number and capacity of carbon beds, the type and capacity of
carbon beds, the type and working capacity of activated carbon beds, design
total steam flow over the period of each complete carbon bed regeneration
cycle, the duration of the carbon bed steaming and cooling/drying cycles,
the design carbon bed temperature after regeneration, the design carbon bed
regeneration time, and the design service life of carbon. For nonregenera-
tive carbon adsorption systems, the key operating parameters are the design
outlet/organic concentration level, the capacity of carbon bed, the type and
working capacity of activated carbon, and the design carbon replacement
interval based on the total carbon working capacity of the control device
and source operating schedule.
To ensure that the carbon adsorption system is operated and maintained .
within these design specifications, the regulation also requires the
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monitoring of the vent stream flow rate, the concentration of organics in
the exhaust vent, and a parameter that demonstrates that the bed is
regenerated on a regular basis (for automatic regeneration) or that the bed
is replaced on a regular basis. After the design analysis has been
conducted and the carbon adsorber has satisfied the monitoring requirements,
emission reductions of 95 percent can be expected. As for additional
control using carbon adsorbers, the current evaluation of this control
technique indicates that 95 percent is the best short- and long-term
efficiency that can be expected on an industrywide basis. Therefore, no
recommendation for higher efficiencies can be made. That is not to say,
however, that higher efficiencies are unobtainable in certain circumstances
at individual facilities. .
5.6 REFERENCES
1,
4.
5.
6.
8.
9.
Perry, R. H. (ed.). Chemical Engineers' Handbook. 5th ed.
New York, McGraw-Hill Book Co;, 1973. p. 13-50 through 13-55.
Exner, J. H. Detoxification of Hazardous Waste.
Ann Arbor Science, 1980. p. 3-25.
Ann Arbor, MI,
Metcalf and Eddy, Inc. Briefing: Technologies Applicable to
Hazardous Waste. Prepared for U.S. Environmental Protection
Agency. Cincinnati, OH. May 1985. Section 2.9.
Allen, C. C., et al. (Research Triangle Institute). Field Evalua-
tions of Hazardous Waste Pretreatment as an Air Pollution Control
Technique. Prepared for U.S. EPA/ORD/HWERL. Cincinnati, OH.
Contract No. 68-03-3253. March 31, 1987. p. 23.'
Luwa Corporation. Product Literature—Luwa Thin-Film Evaporation
Technology. P.O. Box 16348, Charlotte, NC 28216.
U.S. EPA/ORD/IERL. Process Design Manual for Stripping of Organ-
ics. Cincinnati, OH. Publication No. EPA-600/2-84-139. August
1984.
Schweitzer, P. A. Handbook of Separation Techniques for Chemical
Engineers. New York, McGraw-Hill Book Co., 1979. p.' 1-147
through 1-178.
Reference 1, p. 13-1 through 13-60.
King, C. J. Separation Processes.
Co., 1971. 809 p.
New York, McGraw-Hill Book
5-64
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10 Treybal, R. E. Mass-Transfer Operations. New York, McGraw-Hill
Book Co., 1968. p. 220-406.
11 Berkowitz, J. B., et al. Unit Operations for Treatment of Hazard-
ous Industrial Wastes. Noyes Data.Corporation. Park Ridge, NJ.
1978. p. 369-405, 849-896.
12 U S. EPA/ORD/HWERL. Preliminary Assessment of Hazardous Waste
Pretreatment as an Air Pollution Control Technique. Publication
No. EPA 600/2-86-028, NTIS PB46-17209/A6. March 1986.
13. Reference 2, p. 1-39.
14. Reference 3, Sections 2.9, 2.15, 2.16. •
15. Reference 12, p. 45.
16. Reference 12, p. 43.
17. Reference 4, p. 63. " '
18. Reference 6. ;
19. Hwang, S. T., and P. Fahrenthold. Treatability of Organic Prior-
ity Polluants by Steam Stripping. In: AIChE. .
20. ICF Consulting Associates, Incorporated. Guide to Solvent Waste
Reduction Alternatives. 707 Wilshire Blvd., Los Angeles, CA
90017. October 10, 1986. p. 5-27, 5-28.
21. Reference 3, Section 2.17. :
22. Reference 14, Section 2.16.
23. Reference 11, Section 2.16.
24. Reference 14, p. 869.
25. U.S. EPA/Control Technology Center. Air Stripping of Contaminated
Water Sources—Air Emissions and Controls. Research Triangle
Park, NC. Publication No. EPA-450/3-87-017. August 1987. 125 p.
26. Reference 11, Section 2.16.
27. Reference 11, p. 869-880.
28. Code of Federal Regulations, Vol. 45, No. 9, Appendix A, January
1980. •
5-65
-------
29.
30.
31.
32.
33.
34.,
35.
36.
37.
38.
39.
40.
Erikson, D. G. (Hydroscience). Emission Control Options for the
Synthetic Organic Chemical Industry; Control Device Evaluation;
Condensation. Prepared for U.S. Environmental Protection Agency.
Research Triangle Park, NC. EPA Contract No. 68-02-2577. July
1980. p. II-l.
U.S. Environmental Protection Agency. Office of Air and Waste
Management. Control Techniques for Volatile Organic Emissions
from Stationary Sources. Research Triangle Park, NC. Publication
No. EPA-450/2-78-022. May 1978. p. 83.
Reference 29, p. IV-1.
Reference 29, p. II-3, III-3. .
Reference 1, p. 10-13 through 10-25.
Kalcevic, V. (IT Enviroscience). Control Device Evaluation--
Flares and the Use of Emissions as Fuels. 'In: Organic Chemical
Manufacturing. Volume 4: Combustion Control Device. U.S.
Environmental Protection Agency. Publication No. EPA-450/3-80-
026. December 1980. Report 4.
Klett, M. G., and J.B. Galeski (Lockheed Missiles and Space Co.,
Inc.). Flare System Study. Prepared for U.S. Environmental
Protection Agency. Huntsville, AL. Publication No. EPA-600/2-76-
079.
Reed, R. J. North American Combustion Handbook, Cleveland, North
American Manufacturing Company, 1979. p. 269.
Key, J. A. (Hydroscience). Emissions Control Options for the
Synthetic Organic Chemicals Manufacturing Industry; Control Device
Evaluation: Thermal Oxidation. Prepared for U..S. Environmental
Protection Agency. Research Triangle Park, NC. EPA Contract No.
68-02-2577.
Reference 30, p. 53.
Stern, A. C. Air Pollution. Volume IV.
Academic Press, 1977. p. 336.
3rd ed. New York,
41.
Radian Corporation. Carbon Adsorption for Control of VOC Emis-
sions: Theory and Full Scale System Performance. Draft.
Prepared for Office of Air Quality Planning and Standards, U.S.
Environmental Protection Agency. EPA Contract No. 68-02-4378/20.
June 6, 1988.
Ulrich, G. D. A Guide to Chemical Engineering Process Design and
Economics. New York, John Wiley & Sons, 1984. p. 426-438.
5-66
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42.
43.
44.
45.
U.S. Environmental Protection Agency, APTI Course 415 Control of
Gaseous Emissions Student Manual. Publication No. EPA. 450/2-81-
~005. Research Triangle Park, NC, December 1981.
i
Young, R. A., and F. L. Gross. Specifying Air Pollution Control
Equipment. New York, Marcel Dekker, Inc:, 1982. p. 123-185.
U.S. Environmental Protection Agency. Control Techniques for;
Volatile Organic Emissions from Stationary Sources. 3rd Edition.
Draft Report. Office of Air Quality Planning and Standards.
March 1986. pp. 3-1 - 3-83.
Reference 44.
5-67
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6.0 TESTING AND EVALUATION
The testing and evaluation of the TSDF facility for process vents and
equipment starts with an evaluation of the applicability of the regulation
to the sources. (See Chapter 3.0, Section 3.1, Figure 3-1, for a discussion
of applicability.) For affected process vents to require emission control
under the regulation, emissions from all affected process vents at the
facility must either be greater than or equal to 1.4 kg/h (3 Ib/h) or
greater than or equal to 2.8 Mg/yr (3.1 tons/yr). The specific criterion
for a leaking equipment component will depend on the organic content of the
waste material handled, the vapor pressure of the waste stream, and whether
the waste is a fluid (i.e., liquid or gas) at normal operating conditions.
Also, the control requirements for these streams will vary with the type of
source (i.e., valve, pump, compressor, flange, etc.) and the properties of
the material being handled (i.e., gas/vapor, light-liquid, and heavy-
liquid). Figure 6-1 illustrates the decisions and determinations that will
be made in addressing the applicability of the regulation to a process vent
or equipment component. .
For sources covered under the regulation, a monitoring program is
required to determine compliance with the regulation. For process vents
this will include routine monitoring of control device operating parameters.
For equipment, an LDAR program or specific equipment controls will be
required. The control equipment required under the rules of Subpart BB may
also require routine monitoring to ensure proper performance under specific
circumstances.
The following sections discuss allowable sampling and analytical proce-
dures that may be used to determine the above-mentioned applicability.
Guidance is given on the most appropriate measurement techniques and the
expected accuracy of the various measurement methods.
6-1
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SUBPART AA OR BB
Applies (See Fig. 3-1 & 3-2)
Equipment
Process vents
-
Type of equipment?
vent orgtnie emission
Compressors,
sampling connections,
•ad open-ended line*
facility process vent
organic emission rate 4 3.1
PRJOto
gas/vapor service?
program (LDAR)
No
emission
reduction
required
Is the
equipment in
gas service?
•OpanUdwfen
MdMwtabt*
Is the
VPMUkPa
@ 20°C for any
compound
Control
below emission
rate limit
•Monthly LDAR
wfch Meted 21
*CMnl device &
doMd-vent tyAem with
control dtvice monitoring
Is the total
coocentntion for compouods
j. 20% by weight?
Liquid @ operating
cooditioiu?
95% control efficiency
(minimum)
Equipment is in
heavy-liquid service
Equipment is in
light-liquid service
Control
device or
process
changes
required
to meet
emission
rate limit
Nocvounnt i
tf evidence of Ink found
• Monthly LDAR wife Method 21
or ittcmniv* mndirtk
Figure 6-1. Regulatory decision tree.
6-2
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6.1 EQUIPMENT LEAKS
The equipment leak standards, as defined in the regulation, apply to
any "leak" from a piece of piping or process equipment that results in the
release of organic emissions. The standards specifically apply to equipment
s-uch as valves, pumps, open-ended lines, sampling connections, flanges,
etc., that handle material that has an organic content equal to or greater
than 10 percent (by weight). If the organic content fluctuates or the
equipment handles more than one waste stream, determination will be based on
the maximum total organics content of a waste stream contained or contacted
by the equipment. Therefore, one of the first steps in determining applica-
bility of the equipment leak standard is to identify whether the hazardous
waste stream(s) contacting or contained by the equipment has (or is expected
to have) an organic content equal to or greater than 10 percent (by weight).
The owner or operator is responsible for making this determination for each
piece of equipment that contains or contacts a hazardous waste. This
determination may be based on knowledge of the hazardous waste stream or the
process by which it was produced (engineering judgment), or it may be based
on the results of sampling and analysis of the subject waste stream.
If engineering judgment is used as a basis for determining that the
total organic content of a waste stream is less than 10 percent (and thus
the equipment is exempt from the requirements of the regulation), then the
burden of proof is on the owner or operator. An owner or operator should
anticipate that waste stream organic concentration calculations based on
engineering judgment (without sampling and analysis) will require support
documentation, and such documentation should be furnished along with the
permit application and maintained in the operating record. Little or no
justification is required when an owner or operator uses engineering judg-
ment to determine that the total organic content of a waste is greater than
or equal to 10 percent by weight (and thus subjects the equipment to the
requirements of the regulation).
In some situations, it will be relatively easy to demonstrate (without
sampling and analysis) that the concentration of total organics in a waste
stream is less than 10 percent. For example, the wastewater from a metal
plating shop may contain only trace quantities of organics. A process flow
diagram along with a list of the feedstocks could be presented to support
6-3
-------
the conclusion that the total organic concentration in the waste will never
approach 10 percent.
Operators of some facilities, such as solvent recycling plants, will
likely use engineering judgment to determine that most of their waste
streams contain more than 10 percent total organics. Such facilities may,
however, have one or more waste streams that contain less than 10 percent
total organics. For example, a solvent recycling facility may remove water •
from waste solvents as a step in the recycling process. It is likely that
some of the equipment involved in this process may handle a waste stream
that is primarily water. In this case, sampling and analysis of the waste
stream as described in Sections 264.1063 and 265.1063 would be the most
straightforward way of determining if this portion of the facility would be
subject to the requirements of the equipment, leak standards. If no sampling
and analysis is performed, then process information in the form of process
flow diagrams, material balances, and process design specifications would be
required to demonstrate that the organic concentration in the waste stream
never exceeds 10 percent by weight.
The following subsections discuss sampling and analysis procedures that
may be used to determine the organic content of liquid and gaseous waste
streams.
6.1.1 Liquid Waste Streams '
Obtaining a representative sample of a liquid waste is critical in
measuring the stream's organic content. Liquid waste streams should be
sampled to minimize the loss of volatile organics from the sample. In
addition, when the waste is stratified, it is necessary to obtain and
integrate subsamples from all layers of the waste material.
The location where the waste total organic content is determined (i.e.,
where the sample is taken) can greatly affect the results of the deter-
mination. This occurs because.the concentration level can decrease
significantly after generation as the waste is transferred to various waste
management units.
If the waste is directly or indirectly exposed to ambient air at any
pointr a portion of the organics in the waste will be emitted to the
atmosphere, and the concentration of organics remaining in the waste will
decrease. For highly volatile organic compounds such as butadiene, all of
6-4
-------
the compound would evaporate within a few seconds of exposure to air.
Similarly, emissions o'f organics from open waste transfer systems (e.g.,
sewers, channels, flumes) are expected to be very significant. To ensure
that the determination of total organic concentration is an accurate
representation of the emission potential of a waste upon generation, it is
essential that the waste determination be performed at a point as.near as
possible to where the waste is generated, before any exposure to the
atmosphere can occur.
For the reasons stated, above, the waste determination must be based on
the waste composition before the waste is exposed, either directly or
indirectly, to the ambient air. Direct exposure of the waste to the ambient
air means the waste surface interfaces with the ambient air. Indirect
exposure of the waste to the ambient air means the waste surface interfaces
with a gas stream that subsequently is emitted to the ambient air. If the
waste determination is performed using direct measurement, the standards
would require that waste samples be collected from an enclosed pipe or other
closed system which is used to transfer the waste after generation to the
first hazardous waste management unit. If the waste determination is
performed using knowledge of the waste, the standards would require that the
owner or operator have documentation attesting to the volatile organic
concentration of the waste before any exposure to the ambient air.
The location where the waste determination would be made for any one
facility will depend on several factors. One factor is whether the waste is
generated and managed at the same site, or the waste is generated at one
site and transferred to a commercial TSDF for management. Another important
factor is the mechanism used to transfer the waste from the location where
the waste is generated to the location of the first waste management unit
(e.g., pipeline, sewer, tank truck). For example, if a waste is first
accumulated in a tank using a direct, enclosed pipeline to transfer the
waste from its generation process, then the waste determination could be
made based on waste samples collected at the inlet to the tank. In
contrast, if the waste is first accumulated in a tank using an open sewer
system to transfer the waste from its generation process, then the waste
determination would need to be made based on waste samples collected at the
6-5
-------
point where the waste enters the sewer before the waste is exposed to the
ambient air. For situations where the waste is generated off-site, the
owner or operator may make the determination at the inlet to the first waste
management unit at the TSDF that receives the waste provided the waste has
been transferred to the TSDF in a closed system such as a tank truck and the
waste is not diluted or mixed with other waste.
If a waste-determination indicates that the total organic concentration
is equal to or greater than the applicability criteria, then the owner or
operator would be required to comply with the standards.
Sampling methods are described in EPA's SW-846 manual on sampling and
analytical methodologies and in other analytical methods.1«2 in these
methods, emphasis is placed on taking a sample from throughout the waste
material to eliminate any possible effects of stratification.- The methods
also suggest that the most appropriate sampling method far volatile organics
is to take the sample from below the surface of the liquid waste (e.g., 30.5
to 45.7 cm [12 to 18 in]) nearest the source of the waste discharge. The
sample should be immediately stored in a vial such as a 40-mL volatile
organic analysis (VOA) vial with a TeflonR-l.ined septum or in a larger
container such as a 224 g (8-oz) widemouth glass container with a TeflonR
liner. The sample container should be filled completely with the waste to .
prevent volatile organics from partitioning into the heaclspace. The sample
should be preserved and stored at cold temperatures (i.e.,, less than or
equal to 4 °C [-15.5 °F]). Sample agitation should be minimized during
handling. The sample should be analyzed within 14 days of collection.
In some instances, it is unknown if a waste to be sampled is
stratified. In such cases, one should assume that the stream is stratified
and attempt to obtain the sample either at a location where stratification
would be minimized or at a point where the sample can be collected from the
full container depth. When sampling from pipes, it is recommended to sample
from a vertical stretch of the pipe when possible because the fluid here may
be more completely mixed than the fluid in long horizontal sections where
stratification may occur.
When sampling from either drums or tanks, one should attempt to obtain
a core sample from the container. SW-846 recommends the use of a composite
6-6
-------
liquid waste sampler (the Coliwasa) -to collect free-flowing liquids and
slurri.es from drums or shallow tanks. For deeper tanks, other means may be
required to extract the sample. For example, it may be necessary to place a"
weighted sample line into the tank and pump material through the line into a
collection container as the line is lifted through the height of the tank
volume.' This allows collection of an integrated sample of the free-flowing
material at different heights of the tank. Care must be exercised so that
the collection flow rate is low enough to minimize any mixing of the tank
contents. Efforts should also be made to identify the presence of and .
estimate the depth of solids on the tank bottom. Such solids may not be
collected by this sampling approach, especially if they have become well
compacted over a period of time.
Once.a representative sample is secured, an analytical method must be
chosen to measure the organic content of the waste. Several methods exist,
and in some cases the choice of one method over another is not clear. Table
6-1 presents a list of methods suggested by the EPA for determining the
organic content of waste liquids (Sections 264.1063[d] and 265.1063[d]).
Some can be considered screening techniques; others, specialty techniques.
The most universally applicable method is the gas chromatographic tech-
niques as described in ASTM E 260-85. With this method, the sample must be
prepared to allow direct injection into the analytical instrument. The
person responsible for the analysis needs to select the proper column and
column operating conditions. Also, the gas chromatographer (GC) should be
equipped with a detector that will give the best response to the particular
component(s) being analyzed. Therefore, it is helpful to know the approxi-
mate composition of the waste prior to conducting the analysis. Table 6-2
lists several GC detectors and the types of organics that can be readily
detected with each. For most purposes, a flame ionization detector (FID) is
the best option for analyzing organic-containing materials.
ASTM D-2267-88 is a specialty GC procedure for aromatics in other
organic solvents. Methods in SW-846 for GC analysis (8010 for halogenated
volatile organics and 8020 for aliphatic volatile organics) are considered
as an expansion of the general ASTM E 260-85 method and provide a good deal
of specificity. Standards are usually run with the samples to provide
6-7
-------
TABLE 6-1. APPLICABILITY OF ORGANIC CONTENT ANALYTICAL METHOD$3-8
Method
Compounds
most applicable
Comments
ASTM E 260-85
(General GC
analysis)
Multiple compounds
ASTM D 2267-88
(Aromatics by GC)
Benzene, toluene, Cg,
and heavier aromatics
Method 9060 (SW-846) Organic carbon
(Total organic carbon greater than 1
[TOC])
mg/L
Method 8240 (SW-846)
(Volatiles by gas
chromatographer/mass
spectrometer [GC/MS])
ASTM E 168-88
(Infrared [IR]
analysis)
ASTM E 169-87
(Ultraviolet [UV]
analysis)
Generally used to
measure Appendix VIII
compounds in waste
waters, sludges, and
soils
Single or double
component systems
Single or double
component system
Method can be applied to
many compounds, and analysis
can be done with several
diferent detectors. Possibly
the most universally applic-
able method for this applica-
tion.
Method was developed to
measure aromatics in aviation
gasolines, reformer products,
and reformer feed. Based on
GC techniques. Requires a
standard for quantification.
Uses a carbonaceous analyzer
to measure carbon content of
water and domestic and indus-
trial wastes. Could be used
as a screening technique to
determine approximate concen-
tration of organics.
Based on purge-and-trap,
GC/MS procedure. Only
volatile compounds will be
identified. Relatively
expensive test procedure.
Similar to UV technique
except sample can be a "mull"
mixture or a solid transparent
disk. May not provide the
quantitative information
required by the regulation.
Method requires that measured
compounds be soluble in a
"non-interfering" solvent.
The absorbance characteristics
of the compounds must be
known. May not provide the
information required by the
regulation.
6-8
-------
TABLE 6-2. APPLICABILITY OF ORGANIC ANALYTICAL DETECTORS
Detector
Organic compounds
most applicable
Comments
Flame ionization
Photoionization
Hall electrolytic
conductivity
device
Nondispersive
infrared
Mass spectrometer
All
Aromatics
Halogenated
Any compound with
C-H band
All
Certain substituted compounds,
like chlorinated compounds, have
low responses.
Works well for most aromatic
compounds. Will not detect low
molecular weight hydrocarbons.
Mostly chlorination and
brominated compounds; low
response for fluorinated
compounds.
Compounds need to absorb IR,
and IR wavelengths-need to be
known. Other compound such
as C0'2, S02, and water
can interfere.
Most expensive technique.
Usually used to confirm
identification of compounds.
6-9
-------
'quantitative data; however, the compound is identified only by retention
time, thus making possible false positive identifications.
An additional, more expensive analysis for volatile organics is GC/MS
according to EPA Method 8240. This method offers not only the reference of
retention time, but also the mass spectra for component confirmation. The
GC/MS analysis also provides quantitative information.
The TOC analysis (EPA Method 9060) provides an easy determination of
total organic content. When using this technique, samples with high con-
centrations of organics will require dilution with water or, a nonorganic
-\
solvent before being analyzed. Some TOC analyzers have an upper range of,
0.1 percent total organics; therefore, a 100:1 dilution with water (or other
appropriate nonorganic solvent) should result in a sample concentration that
is within the instrument range.
The UV and IR analysis methods presented in Table 6-1 (ASTM .E-169-87
'and ASTM E-168-88, respectively) are used as qualitative tools for compound
identification. The IR procedure appears to provide better aliphatic
organic.compound information; however, halogenated components may not be
identified from the IR analysis. Moreover, the IR analysis may not provide
the required quantitative information. The UV methodology is not used as
often and may require some investigation and review to confirm its appli-
cability. :
The procedures referenced in Table 6-1 provide specific compound iden-
tification capabilities for volatile organics with either GC or GC/MS. For
semivolatile component analysis, TOC and IR have been identified in the,
regulation. Other alternative procedures not identified in the regulation
(i.e., GC/MS [SW-846 Method 8240]) may be used. The choice of methods will
depend on the specific compounds to be analyzed for and the type of results
that are desired.
The location of a laboratory or the lack of on-site analysis equipment
t
may dictate the methodology to be used for analysis. GC/MS instrumentation
is expensive and less portable than other instrumentation available for
organic analysis. The method to be used should be chosen based on the
applicability to a particular waste stream and on any matrix limitations
specified in the method. If appropriate, cost may be used as a secondary
6-10
-------
criterion. Also, owners or operators may use engineering judgment to
determine total organic content, but they must be able to justify their
decisions and are at risk if their judgment is-incorrect.
The equipment leak rules do not specify the number of samples that must
be analyzed for the 10-percent organic content waste determination. This is
because the determination of Subpart BB applicability should not require
precise measurement of the 10-percent total organics by weight in most
cases. The EPA anticipates that most waste streams will have an organic
content much lower or much higher than 10 .percent. Furthermore, because the
regulation requires control if the orga'nic content of the waste stream ever
equals or exceeds the 10-percent value, EPA believes that few owners or
operators will claim that a waste stream is not subject to the requirements
of the standards based on a sample analysis with results near 10 percent.
Therefore, a precise measurement.of waste stream total organic content is
not likely to be needed to determine applicability of the equipment leak
standards.
6.1.2 Gaseous Waste Streams
The analysis of a gaseous waste stream can be performed on-site using a
real-time measurement, or off-site when grab samples are used. The on-site
approach is generally preferred when there is a continuous stream with a
significantly varied composition. In this case, the analyzer takes a con-
tinuous or nearly continuous sample, which is directly analyzed for total
organic concentration. The sample must be delivered to the analyzer through
a leak-free sample line and gas sample pump. For off-site measurement (and
sometimes on-site measurement), a vent gas/vapor grab sample will be col-
lected in a clean inert container. The most common containers are stainless
steel sampling bombs (2 to 5 L [0.5 to 1.3 gal] in size), glass bombs, or ,
TedlarR bags of similar or larger size. The sample can be taken instantane-
ously or as an integrated sample if a flow regulator is used to slowly bleed
the sample into the sample container. The containers must be sealed before
shipment to the off-site analytical laboratory. Also, the sample containers
should be routinely tested for leaks and contamination.
GC techniques are the most common analysis methods for gas-phase meas-
urement. The recommended method is EPA Method 18, Measurement of Gaseous
6-11
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Organics by Gas Chromatography.9 This method is applicable to 90 percent of
the types of gaseous organics emitted from an industrial or hazardous waste
source and has a precision of 5 to 10 percent (relative standard deviation).
This method, however, is not able to identify and measure trace amounts of
organic compounds, such as those found in indoor air and fugitive emissions..
As in the GC techniques for-liquid wastes, Method 18 allows the use of
the most appropriate detector. The detector selection guidelines presented
in Table 6-2 are applicable to gaseous waste stream measurements.
6.1.3 Liqht/Heavy-Liquid Determination
After the 10-percent organic determination has been made, all liquid
streams containing 10 percent or greater organics must undergo a light-
liquid/heavy-liquid determination, tight liquids,are those that contain one
or more compounds with a vapor pressure greater than 0.3 kPa (0.04 psia) at
20 °C (68 °F) and the total concentration of pure components having a vapor
pressure greater than 0.3 kPa at 20 *C is greater than 20 percent -and are a-
liquid "at operating temperatures (see Figure 6-1). All liquids that do not
meet these criteria are considered heavy liquids.
The light-liquid determination will require that compound-specific data
be known for the waste. Vapor pressures must be determined for each com-
pound in the waste. Vapor pressures are listed in the chemical literature
for most common compounds. An analysis method for determining the vapor
pressure of a compound for which the vapor pressure is not available in the
literature is ASTM D 2879-8. If the waste contains a compound or compounds
with vapor pressure greater than 0.3 kPa at 20 °C, such as the common
organic solvents shown in Table 6-3, the concentrations of the compounds
will have to be determined. For streams of unknown composition, the owner/
operator can either analyze the stream to make a complete determination or
make an engineering estimate of the stream composition. Complete analysis
is usually conducted using GC/MS, which is relatively sophisticated and
costly (i.e., $1,500 to $2,500 per sample).
Visual observation can be used to determine whether a waste is a liquid
at ambient temperature. This could be done by an experienced operator or
technician by examining flowability of the fluid or possibly by measuring
viscosity. The owner or operator may be required to provide documentation
to support engineering judgment used to determine material fluidity.
6-12
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TABLE 6-3. VAPOR PRESSURES OF COMMENT SOLVENTS
Halogenated Solvents
Methyl ene chloride
1,1,1-Trichloroethane
Trichloroethylene
Perchloroethylene
Methyl ethyl ketone
Methyl isobutyl ketone
Toluene
Acetone
Xylene(s)
Mineral spirits
Alcohols
Isopropyl alcohol
Methanol
Ethanol .
VP @ 20°C,
45.2
2.3
.7.8
1.7
9.4
2.1 "
5.1
24.6
1.3
0.27
4.1
12.7
5.9
kPa (mm Hg)
(340)
(17
(59
(13
(70.6)
(16)
(38)
(185)
(9.5)
.(2.0)
(31)
(96)
(44)
Most appropriate •
analytical method
EPA Method 8240
EPA Method 8240
EPA Method 8240
EPA Method 8240
EPA Metho'd 8240
EPA Method 8240
EPA Method 8240
EPA Method 8240
EPA Method 8240
ASTM E 260
ASTM E 260
ASTM E 260
ASTM E 260
VP = vapor pressure.
6-13
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6.1.4 Leak Detection Monitoring
Once a waste stream has been classified as gas/vapor, light liquid, or
heavy liquid, the next step will be to determine the proper leak detection
program for the source. The recommended screening-method is EPA Method 2111
(Section 264.1063[b]). See Appendix B for a description of Method 21. With
Method 21, a hand-held total organic analyzer is used to locate leaks from
sources such as valves, flanges, and pump seals. A leak is defined as a
certain concentration, based on a reference compound (methane or n-hexane),
and is specified for each source in the TSDF regulation. In addition, a
response factor must be determined for each compound that is to be measured,
either by testing or from reference methods.11 Appendix 6 presents the
results of a laboratory study on the sensitivity (i.e., response factors) of
two portable VOC analyzers to a variety of organic chemicals. The data from
the screening survey are recorded on sheets similar to the one shown in
Table 6-4.
Appendix H provides a general guide to portable VOC detection devices
that are being marketed for various uses. The instruments in this appendix
are classified as ionization detectors, infrared detectors, or combustion
detectors.
In the following subsections each source type is discussed and the
required monitoring program briefly presented.
6.1.4.1 Valves and Pumps in Light-Liquid Service. Valves-and pumps in
light-liquid service will require the use of Method 21 protocol. The moni-
toring instrument is calibrated in terms of parts per million by volume
(ppmv) of methane or n-hexane in the case of Subpart BB regulations. The
detection level for a leak is 10,000 ppmv as measured by the monitoring
instrument organic analyzer. In the case of pumps, the analyzer sample
probe is held 1 cm (0.4 in) from the emission source, usually at the pump
seal and shaft interface. For valves, emissions are measured directly on
the source, usually between the valve stem and the housing,,
Pumps with a dual mechanical seal and barrier fluid require only visual
inspection oh a weekly basis if the barrier fluid system meets the require-
ments of Section 264.1052(d). Sealless pumps are exempted from any monitor-
ing requirements if the instrument reading upon initial inspection is less
than 500 ppm above background (Section 264.1052[e]). Pumps that are
6-14
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DATE:
TABLE 6-4. EXAMPLE SOURCE SCREENING DATA SHEET
SOURCE SCREENING DATA SHEET:
PLANT: Screening Team:
FT ow
Seq. Comp. Sheet
No. Type No.
Location Process Service
I.D. Stream Type3
Screening Visible
Value Leak
(ppm) (Y/N)
Comments
aGas, light-liquid, heavy-liquid.
Component types:
Valve = VLV
Relief valve = RLV
Pressure sensitive valve = PSV
Pumps = PMP
Compressors = COM
Open-ended line = OEL
6-15
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equipped with a closed-vent system capable of capturing and transporting any
leakage to a control device are exempt from all monitoring requirements
(Section 264.1052[f]).
6.1.4.2 Valves in Gas/Vapor Service. Valves in gas/vapor service
(Section 264.1057) will require the use of EPA Reference Method 21 as out-
lined above for the valves and pumps in light-liquid service.
6.1.4.3 Pressure Relief Devices in Gas/Vapor Service. Pressure relief
devices in" gas/vapor service (Section 264.1054) require monitoring for "no
detectable emissions" as described in EPA Method 21. Pressure relief
devices are required to be preceded by rupture disks, which will con-
siderably reduce the possibility of leaks.' Good operating practice includes
the use of a "tell-tale" pressure gauge between the rupture disk and
pressure relief device to indicate the integrity of the rupture disk. The
final rule requires that pressure relief devices in gas/vapor service be
monitored within 5 days after each discharge.
6.1.4.4 Pipeline Flanges (and Other Connectors) and Pressure Relief
Devices in Light-Liquid Service and Equipment in Heavy-Liquid Service.
Pipeline flanges (and other connectors) and pressure relief devices in
light-liquid service and equipment in heavy-liquid service (Section
264.1058) are required to be monitored after an "audible, visual, olfactory,
or other detection method" indicates the presence of a leak. "Equipment" is
defined as each valve, pump, compressor, pressure relief device, sampling
connection system, open-ended valve or line, flange, or accumulator vessel,
and any control devices or systems required by the regulation. If a leak is
detected, the owner/operator must use EPA Method 21 to determine whether the
leak meets the regulatory definition (i.e., greater than 10,000 ppmv).
6.1.4.5 Closed-Vent Systems. Closed-vent systems (Section 264.1060)
are used to vent emissions to a control device such as a flare or carbon
adsorber. A closed vent must be monitored after construction to demonstrate
that the system operates with no detectable emissions (less than 500 ppmv).
6.1.5 Equipment Requirements for Minimizing Leaks
Certain pieces of equipment do not require leak detection monitoring;
rather, they require addition of specific control equipment for leak pre-
vention. These are shown in Table 6-5. In all cases, these requirements
apply only to sources that meet the 10-percent-by-weight organic content
6-16
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TABLE 6-5. EQUIPMENT REQUIREMENTS FOR REDUCING PROCESS LEAKS
Type of equipment
Control requirement
Compressors (Section 264.1053)
Sampling connection system
(Section 264.1055)
Open-ended valves or lines
(Section 264.1056)
Use mechanical seals with barrier fluid
systems and control degassing vents. The
degassing vent control must use a closed-vent
system and a control device that complies
with the process vent requirements of the
regulation.
The barrier fluid system must be equipped
with a sensor that will detect failure of the
system. The sensor must be equipped with an
audible alarm or inspected daily.
Closed purge sampling is the required
standard for sampling connection systems.
Collected purge material must be destroyed or
recovered in a system that complies with the
process vent requirements of the regulation.
Open-ended valves or lines require the use
of caps, plugs, or any other equipment that
will effect enclosure of the open end.
6-17
-------
criterion. The compressor requirement^applies to gas-service applications.
The regulations make no distinction on type of service for sample collection
systems or open-ended valves or lines.
6'.2 PROCESS VENTS
A process vent is defined as "any open-ended pipe or stack that is
vented to the atmosphere either directly, through a vacuum-producing system,
or through a tank (e.g., distil-late receiver, condenser, bottoms receiver,
surge control -tank, separator tank, or hot well) associated with
distillation, fractionation, thin-film evaporation, solvent, extraction, and
•air or steam stripping operations." The final rules require that each
affected TSDF (i.e., those with waste management units of the type specified
in the rules that manage hazardous waste with 10 ppmw or greater total
organics concentration on a time-weighted, annual average basis) (a) reduce
total organic emissions from all affected vents below 1.4 kg/hr (3 Ib/h) and
below 2.8 Mg/yr (3.1 ton/yr), or (b) reduce total organic emissions from all
affected vents at the facility by 95 weight percent, or, for enclosed
combustion devices, to a total organic compound concentration of 20 ppmv or
less (expressed as sum of actual compounds, on a dry basis corrected to 3
percent oxygen).
The following subsections discuss sampling and analysis"procedures that
may be used to determine the organic content of the waste stream and the
process vent emissions and how to calculate the maximum hourly and annual
emission rates from individual process vents.
6.2.1 Haste Stream Determination
To determine whether a particular hazardous waste management unit of
the type specified in the rule (e.g., a steam stripping or air stripping
unit) is subject to the provisions of Subpart AA of Parts 264 and 265, the
owner/operator is required to determine the total organic concentration of
the waste managed in the unit initially (by the effective date of the
standards or when the waste is first managed in the waste management unit)
and thereafter on a periodic basis (for continuously generated wastes). A
waste determination for Subpart AA applicability would not be necessary when
an owner/operator manages the waste in a distillation, fractionation, thin-
film evaporation, solvent extraction, or air or steam stripping unit that is
controlled for organic emissions and meets the substantive requirements of
Subpart AA.
,6-18
-------
Determination that the time-weighted, annual average total organic
concentration of the waste managed in the unit is less than 10 ppmw must be
performed by direct measurement or by knowledge of the waste as described
later in this section. Direct measurement of the waste's total organic
concentration must be performed by collecting individual grab samples of the
waste that are representative of the waste stream managed, in the potentially
affected unit and analyzing the samples using one of the approved reference
methods identified in the rule.
The EPA is requiring that analytical results for a minimum of four (4)
representative samples be used to determine the total organic concentration
for each waste stream managed in the unit. In setting the minimum number of
samples at four, EPA will obtain sufficient data to characterize the total
organic concentration of a waste without imposing an unnecessary burden on
the owner/operator to collect and analyze the samples.
Waste determinations must be performed under process conditions
expected to result in the maximum waste organic concentration. For waste
generated on-site, the samples must be collected at a point before the waste
is exposed to the atmosphere such as in an enclosed pipe or other closed
system that is used to transfer the waste after generation to the first
affected distillation/separation operation. For waste generated off-site,
the samples must be collected at the inlet to the first waste management
unit that receives the waste, provided the waste has been transferred to the
facility in a closed system such as a tank truck, and the waste is.not
diluted or mixed with other waste.
The location where the waste's total organic content is determined is
of importance since sampling location can greatly affect the results of the
determination. This occurs because the concentration level can decrease
significantly after generation as the waste is transferred to (and managed
in) various waste management units. If the waste is directly or indirectly
exposed to ambient air at any point, a portion of the organics in the waste
will be emitted to the atmosphere, and the concentration cf organics remain-
ing in the waste will decrease. For highly volatile organic compounds such
as butadiene, all of the compound would evaporate within a few seconds of
exposure to air. To ensure that the determination of total organic concen-
tration is an accurate representation of the emission potential of a waste,
6-19
-------
it is essential that the waste determination be performed at a point as near
as possible to where the waste is generated, before any exposure to the
atmosphere can occur.
For the reasons stated above, the waste determination must be based on
the waste composition before the waste is exposed, either directly or indi-
rectly, to the ambient air. Direct exposure of the waste to the ambient air
means the waste surface interfaces with the ambient air. Indirect exposure
of the waste to the ambient air means the waste surface interfaces with a
gas* stream that subsequently is emitted to the ambient air. If the waste
determination is performed using direct measurement, the standards would
require that waste samples be collected from an enclosed pipe or other
closed system which is used to transfer the waste after generation to the
first Hazardous waste management unit. If the waste determination is
performed using knowledge of the waste, the standards would require that the
owner or operator have documentation attesting to the organic concentration
of the waste before any exposure to the ambient air.
The location where the waste determination would" be made for any one
facility will depend on several factors. One factor is whether the waste is
generated and managed at the same site, or the waste is generated at one
site and transferred to a commercial TSDF for management. Another important
factor is the mechanism used to transfer the waste from the location where
the waste is generated to the location of the first waste management unit
(e.g., pipeline, sewer, tank truck). For example, if a waste is first
accumulated in a tank using a direct, enclosed pipeline to transfer the
waste from its generation process, then the waste determination could be
made based on waste samples collected at the inlet to the tank. In
contrast, if the waste is first accumulated in a tank using an open sewer
system to transfer the waste from its generation process, then the waste
determination would need to be made based on waste samples collected at the
point where the waste enters the sewer before the waste is exposed to the
ambient air. For situations where the waste is generated off-site, the
owner or operator may make the determination at the inlet to the first waste
management unit at the TSDF that receives the waste provided the waste has
been transferred to the TSDF in a closed system such as a tank truck and the
waste is not diluted or mixed with other waste. If a waste determination
6-20
-------
indicates that the total organic concentration is equal to or greater than
the applicability criteria, then the owner or operator would be required to
comply with the standards.
Methods used to measure the organic content of liquid and gaseous waste
streams are discussed in Sections 6.1.1 and 6.1.2, respectively; these
methods also apply to measurement of the waste for the 10 ppmw applicability
criterion of Subpart AA and the determination of the organic content of the
process vent emission stream.
As an alternative to using direct measurement, an owner/operator is
allowed to use knowledge of the waste as a means of determining that the
total organic concentration of the waste is less than 10 ppmw. Examples of
information that might be-considered by EPA to constitute sufficient
knowledge include: (a) documentation that organics are not involved in the
process generating the waste; (b) documentation that the waste, is generated
by a process that is identical to a process at the same or another facility
that has previously been determined by direct measurement to have a total
organic content less than 10 ppmw; or (c) previous speciation analysis
results from which the total concentration of organics in the waste can be
computed. The finals standards include the provision that EPA can require
that the waste be analyzed using Method 8240 if EPA believes that the
documentation is insufficient to determine an exception by knowledge of the
waste (Sections 264.1034, 264.1063, 265.1034, and 265.1063).
In order to address the temporal variability that can occur both within
a particular waste stream and within the various waste streams managed in a
hazardous waste management unit, the final rules require a time-weighted,
annual average concentration to characterize the waste managed in the unit.
An annual average organic concentration cutoff was judged by EPA to be
reasonable for minimizing increases in organic emissions resulting from
minor organic fluctuations in the waste stream. The final rules require
that an owner/operator repeat the waste determination whenever there is a
change in the waste being managed or a change in the process that generates
or treats the waste that may affect the regulatory status of the waste
management unit or, if the waste and process remain constant, at least
annually. For example, continuous processes are more likely to generate a
more homogeneous waste than batch operations; batch operations involve
6-21
-------
processes that may frequently involve change in materials or process condi-
tions. Batch operations, therefore, usually generate wastes with varying
characteristics, including such characteristics as organic;; content.
Ground-water concentrations would also be expected to show significant
variation if more than one well provides influent to a waste management unit
such as an air stripper and the wells that feed the unit are varied over
time or if the proportions from the wells that make up the influent are
changed. This is because there is typically considerable spatial variabil-
ity in contaminated ground-water concentrations. Situations where the feed
streams are changed and the change is not accounted for in the initial waste
determination would be considered a process change or change in the waste
managed that would- require a new determination.
With the time-weighted, annual average applicability criterion, a
hazardous waste management unit would not be subject to the process vent
rule if it occasionally treats wastes that exceed 10 ppmw if at other times
the wastes being treated in the unit were such that the weighted annual
average total organic concentration of all wastes treated is less than
10 ppmw. The time-weighted, annual average is calculated using the annual
quantity of each waste stream managed in the unit and the mean organic
concentration of the waste stream. For example, an air stripper located at
a TSDF treats an influent comprised of three hazardous waste streams. Two
of the feed streams are dilute aqueous waste streams (i.e., wastewaters)
with organic concentrations of X=7 ppmw and Y = 20 ppmw. The total volumes
requiring treatment in the unit during the year are 100 million gallons for
stream X and 75 million gallons for stream Y. The remaining stream treated
by the air stripper is a (hazardous waste) ground-water stream with an esti-
mated maximum organic concentration of Z = 1.0 ppmw and a maximum pumping
rate of 670 gallons per minute '(i-e., 350 million gallons per year require
treatment in the un.it). The total waste stream flow to the air stripper is
about 1,000 gallons per minute, and the unit is expected to run continuously
throughout the year. Calculation shows that the annual weighted average
organic concentration is about 5 ppmw. Since the waste managed in the unit
is less than 10 ppmw, this unit is not covered by the process vent standards
of Subpart AA. (Note; The unit would have organic emissions of about
2 Ib/h.)
6-22
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6.2.2 Emission Rate Estimate •
Determinations of process vent emissions and emission reductions or ,
total organic compound concentrations achieved by add-on control devices may
be based on either engineering calculations or source performance tests. If
performance tests are used to determine vent emissions, emission reductions,
or total organic compound concentrations achieved by add-on control devices,
they must conform to the requirements in Section 264.1034(c) -or Section
265.1034(c). Under these requirements, each performance "test must consist
of three separate runsr each run is to be conducted for at least 1 hour
under the conditions that exist when the hazardous waste management unit is
operated at the highest load or capacity level reasonably 'expected to occur.
To calculate the emission rate on an hourly (and yearly) basis, the
flow rate of each of the -affected process vent streams will have to be
determined. EPA Method 2 in 40 CFR Part 60 is the specified procedure for
velocity and volumetric flow rate measurement. Table 6-6 presents the
capabilities and limitations of this method. This table also lists several
alternative methods that may be used to comply with the continuous monitor-
ing requirement specified in Section 264.1033(f)(1). EPA Method 18 in
40. CFR Part 60 is the specified procedure for organic content measurements.
Once the process vent organic content and gas flow rate of the process
vent stream have been measured, these data can be used to calculate the
emission rate. Table 6-7 presents a general formula for the emission rate
calculation. The hourly emission rate should be based on the maximum
expected emission from the source. The yearly emission rate is based on the
total emissions expected from the facility; therefore, the calculation will
be based on the hourly emission and the yearly hours of operation.
The process vent organic content and gas flow rate must be measured
under conditions that result in the maximum total organic emissions from the
subject vent. Process conditions such as temperature, pressure, and flow
rate and the concentration of organics in the waste stream should be
adjusted to generate the maximum quantity of total organic emissions from
the process vent while still remaining within the range of normal antici-
pated operating conditions. For example, a solvent recycler may be per-
mitted to receive a wide variety of liquid solvent wastes for processing.
This recycler could have a process vent on a condenser located at the top of
6-23
-------
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TABLE 6-7. EXAMPLE EMISSION RATE CALCULATION
Hourly emission rate (Eft) = kg/h (Ib/h)
Hourly emission rate = Flow rate (m3/s) X Organic cone, (ppm) X Avg MW (kg/g-mole)
(maximum) X Conversion factors
= Qsd
n
Ci MWi
(0.0416) (lO"6]
Qsda = Volumetric flow rate of gases entering or exiting control device, as
determined by Method 2, dscm/h . .
Cia = Organic concentration in ppm, dry basis,"of compound i in the vent
gas, as determined by Method 18
n = Number of organic compounds in the vent gas
MWi = Molecular weight of organic compound i in the vent gas, kg/kg-mole
0 0416 = conversion factor for molar volume, kg-mole/m3 (@ 293 K and 760 mm
' Hg)
10~6 = Conversion from ppm, ppm~l
Eh = kg/h (X 2.205 = Ib/h) .
Yearly emission rate = Maximum hourly rate X Number of operating hours per
year
aTime-weighted average .of the three test runs required under Section 264.1034(c)
and Section 265.1034(c).
6-25
-------
a stripping column. The organic emissions from this vent would probably be
maximized when the column operates at the maximum anticipated feedrate and
processes a waste that has the maximum anticipated concentration of volatile
(i.e., low boiling point) organic constituents.
The facility's process vent emission rate determination must be
appropriate at all times to the facility's'current waste management unit
designs and wastes managed. If the owner/operator takes any action that
would result in the determination no longer reflecting the facility's
operations (e.g.", if a waste of different composition is managed, the
operating hours of the affected management units are increased beyond what
was originally considered, or a new affected unit is added), then a new
emission rate determination is required (Sections 264.1035, 264.1064,
265.1035, and 265.1064).
6.2.3 Control Device Performance Monitoring
If the facility hourly or yearly process vent emission rate exceeds the
limits in the regulation, then controls will be required to reduce emissions
to below the limit, or to reduce total organic emissions from all affected
vents at the facility by 95 weight percent. If an incinerator, boiler, or
process heater is used as a control device, the volume concentration
standard of 20 ppmv can be met instead of the 95-weight-percent reduction.
(Note; The provisions in this section also apply to vented emissions from
equipment leak controls on pumps, compressors, sampling connection systems,
etc.) The vented emissions must be transported to a control device by a
closed-vent system (see Section 6.1). The control device efficiency will be
determined by estimating the mass of organics entering and the mass of
organics exiting the same control device. The control device efficiency
determination can be made using engineering calculations (mass balance) or
an actual performance test.
An owner or operator should anticipate that performance calculations
based on engineering judgment will require support documentation, and such
documentation should be maintained in the operating record and furnished
along with the permit application. As an example, removal efficiency
calculations should use equations and procedures taken from accepted
engineering design publications. The details of the calculations should be
presented with appropriate references. Under some circumstances, vendor
.6-26
-------
performance guarantees may be accepted .in place of detailed engineering
calculations. As an example, a vendor may have a proven track record on
similar applications, or may be able t& substantiate guarantees with
performance data collected from tests on similar applications.
A performance test, if conducted, will require the measurement of the
total organic content and gas flow rate into and out of the control device.
The test procedures that have been presented for gas-phase total organic
content and velocity (flow rate) measurement should be used for the perform-
ance test (e.g., Method 2 for velocity and flow rate and Method 18 for
organic content). A performance test should include at least three 1-h test
periods during maximum system operation. The total organic.reduction effir
ciency would be estimated for each"1-h period, and an average'of the three
values would represent the system performance at maximum conditions.
The owner or operator also is required to continuously monitor the
control device to ensure that it is operating within design specifications.
Table 6-8 lists possible controls, required monitoring parameters, and moni-
toring methods. The relationship between the total organic reduction and
control device operating parameters can be established during the perform-
ance test or by engineering estimations. The owner or operator must keep a
logbook that includes the dates when the control device operated outside of
design specifications as indicated by the control device monitoring, the
duration of operation outside of design specifications, the cause, and cor-
rective measure(s) taken. This log should also contain information and data
identifying all affected process vents, annual facility throughput, annual
facility operating hours, and estimated emissions for each affected vent and
for the overall facility. •
6.3 QUALITY ASSURANCE AND QUALITY CONTROL
The initial steps for any sampling or analytical work should be to
define the objectives or goals of the' work. After these have been estab-
lished, a quality control (QC) and quality assurance (QA) program can be
developed to ensure that the data produced meet the goals and objectives of
the sampling/testing program. The responsibility of ensuring that the QA/QC
measures are properly employed must be assigned to a knowledgeable person
who is not directly involved in the sampling or analysis.
6-27
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-------
Some of the elements of a QA program that should be defined or estab-
lished before any sampling or analysis is conducted include: sampling .
procedures (including field QC); sample custody; calibration procedures and
frequency; analytical procedures (including laboratory QC); data reduction,
validation, and reporting; internal QC checks; performance and system
audits; and specific routine procedures used to assess data precision,
accuracy, and completeness. These elements along with additional QA ele-
ments are described in EPA's SW-846 manual. Also described in SW-846 are
general QC procedures for obtaining field samples -and for laboratory
analyses (e.g., duplicates, spikes, blanks).
Standard test methods generally contain information on specific QC
procedures that pertain to' that method. Careful adherence to these
procedures and others established as part of a site-specific QA/QC program.
will likely result in obtaining appropriate samples and accurate analysis of
these samples.
6.4
1.
2.
3.
4.
5.
6.
REFERENCES
U.S. EPA. Test Methods for Evaluating Solid Waste, SW-846, 3rd ed.,
revised. U.S. Environmental Protection Agency, Washington, DC.
September 1986.
U.S. EPA. EPA Reference Method, "Headspace Method" (Unpublished).
U.S. Environmental Protection Agency, Office of Air Quality Planning
and Standards, Emissions Measurement Branch, Research Triangle Park,
NC. October 1988.
ASTM. The ASTM Annual Book of Standards, Section 14, Volume 14.01.
ASTM E 169-63 (updated by ASTM D 169-87), "General Techniques of
Ultraviolet Quantitative Analysis." American Society for Testing and
Materials, Philadelphia, PA. 1984. p. 209-214.
ASTM. The ASTM Annual Sook of Standards, Section 14, Volume 14.01.
ASTM E 168-67 (updated by ASTM E168-88), "General Techniques of
Infrared Quantitative Analysis." American Society for Testing and
Materials, Philadelphia, PA. 1984. p. 200-208.
ASTM. The ASTM Annual Book of Standards, Section 14, Volume 14.01.
ASTM E 260-73 (updated by ASTM E 260-85), "General Gas Chromatography
Procedures." American Society for Testing and Materials, Philadelphia,
PA. 1984. p. 382-400.
ASTM. The ASTM Annual Book of Standards, Part 24. ASTM D 2267-68
(updated by ASTM D 2267-83), "Aromatics in Light Naphthas and Aviation
Gasolines by Gas Chromatography." American Society for Testing and
Materials, Philadelphia, PA. 1978.
6-29
-------
7. U.S. EPA. EPA Method 9060, "Total Organic Carbon," Test Methods for
Evaluating Solid Waste, SW-846, 3rd ed., revised. U.S. Environmental
Protection Agency, Washington, DC. September 1986. p. 9060-1 to -5.
8. U.S. EPA. EPA Method 8240, "GC/MS Method for Volatiles," Test Methods
for Evaluating Solid Waste, SW-846, 3rd ed., revised. U.S. Environ-
mental Protection Agency, Washington, DC. .September 1986. p. 8240-1
to -43.
9. U.S. ERA. EPA Reference Method 18, "Measurement of Gaseous Organic
Compound Emissions by Gas Chromatography." 40 CFR 60, Appendix A,
revised as of July 1, 1987. p. 740-769.
10. ASTM. The ASTM Annual Book of Standards, Section 5, Volume 05.02.
ASTM D 2879-83 (updated by ASTM D 2879-86), "Vapor Pressure -
Temperature Relationship and Initial.Decomposition Temperature of
Liquids by Isoteniscope." American Society'for Testing and Materials,
' • Philadelphia, PA. 1986. p. 610-617.
11. U.S. EPA. EPA Reference Method 21, "Determination of Volatile Organic
Compound Leaks." 40 CFR 60, Appendix A, revised as of July 1, 1987.
p. 504-511.
12. U.S. EPA. EPA Reference Method 1, "Sample and Velocity Traverses for
Stationary Sources.". 40 CFR 60, Appendix A, revised as of July 1,
1987. p. 504-511.
13. U.S. EPA. EPA Reference Method 2, "Determination of Stack Velocity and
Volumetric Flow Rate (Type S .Pitot Tube)." 40 CFR 60", Appendix A,
revised as of July 1, 1987. p. 511-529.
14. U.S. EPA. EPA Reference Method 1A, "Sample and Velocity Traverses for
Stationary Sources with Small Stacks or Ducts." Proposed addition to
40 CFR 60, Appendix A. 1988.
15. U.S. EPA. EPA Reference Method 2A, "Direct Measurements of Gas Volume
Through Pipes and Small Ducts." 40 CFR 60, Appendix A, revised as of
July 1, 1987. p. 529-532.
>
16. U.S. EPA. EPA Reference Method 2B, "Determination of Exhaust Gas
Volume Flow Rate from Gasoline Vapor Incinerators." 40 CFR 60,
Appendix A, revised as of July. 1, 1987. p. 532-533.
17. U.S. EPA. EPA Reference Method 2C, "Determination of Stack Gas
Velocity and Volumetric Flow Rate in Small Stacks or Ducts (Standard
Pilot)." Proposed addition to 40 CFR 60, Appendix A. 1988.
18. U.S. EPA. EPA Reference Method 2D, "Measurement of Gas Volumetric Flow
Rates in Small Pipes and Ducts." Proposed addition to 40 CFR 60,
Appendix A. 1988.
19. U.S. EPA. EPA Reference Method 22, "Visual Determination of Fugitive
Emissions from Material Sources and Smoke Emissions from Flares."
40 CFR 60, Appendix A, revised as of July 1, 1987. p. 790-794.
6-30
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7.0 INSPECTION, MONITORING, RECORDKEEPING, AND REPORTING
7.1 INSPECTION AND MONITORING
Under the general RCRA inspection requirements (Sections 264.15 and
265.15), the owner/operator of. a facility is required to inspect his facil-
ity for malfunctions^ deterioration, operator errors, and discharges that
could result in hazardous waste release or threat to human health. The
owner/operator is responsible for developing and following an inspection
schedule and for maintaining a copy of the schedule at the facility.
Each TSDF owner/operator subject to the provisions of Parts 264 and
265, Subparts AA and BB, must also comply with the inspection, monitoring,
and testing requirements of Sections 264.1034, 265.1034, 264.1063, and
265.1063. Leak detection monitoring is required in Sections 264.1052 to
264.1062 and Sections 265.1052 to 265.10.62 for the affected pieces of
equipment. This monitoring must be in accordance with Reference Method 21
in 40 CFR Part 60. The detection instrument used to determine if a leak is
present shall meet the performance criteria of this method. When checking
for a leak, the instrument probe must be traversed around and as close as
possible to all potential leak interfaces. The detection instrument shall
be calibrated before it is used each day using procedures and gases speci-
fied in EPA Reference Method 21.
When equipment is being tested for compliance with no detectable emis-
sions, the test must comply with the leak detection monitoring requirements
of Section 264.1063(b) and Section 265.1063(b). In addition, the background
level shall be determined as described in Method 21. The arithmetic differ-
ence between the maximum organic concentration indicated by the instrument
and the background organic concentration level is compared with 500 ppm for
determining compliance. If the difference between the two values is greater
than 500 ppm, then emissions are detected.
7-1
-------
7.1.1 Process Vents
A TSDF owner/operator is required by Sections 264.1033 and 265.1033 to
monitor and inspect each control device required to comply with the process
vent standards (Sections 264.1032 and 265.1032) to ensure proper^operation
and maintenance. As part of this requirement, the owner/operator is to
install, calibrate, operate, and maintain a flow indicator that provides a
record of vent stream flow from each affected process vent to the control
device at least once every hour. .The flow indicator is to be installed as
close as possible to the control device inlet, but before being combined
with other vent streams.
The owner/operator is also required to install, calibrate, maintain,
and operate an appropriate device to .monitor the operation of control
devices. For vapor incinerators, a temperature monitoring device equipped
with a continuous recorder is required. The monitoring desvice must have an
accuracy of ±1 .percent of the temperature being monitored in degrees Celsius
or ±0.5 °C, whichever is greater. For thermal vapor incinerators, the
temperature sensor is to be installed at a location in th« combustion
•chamber downstream from the combustion zone. The monitoring device required
for catalytic vapor incinerators must be able to monitor temperature at two
locations. These temperature sensors are required to be installed in the
vent stream as close as possible to the catalyst bed inlet and outlet.
For flares, a heat-sensing monitoring device equipped with a continuous
recorder that demonstrates continuous ignition of the pilot flame is
required.
Boilers and process heaters with a design heat input capacity of less
than 44 MW are required to have a temperature monitoring device. The device
is to have an accuracy of ±1 percent of the temperature being monitored in
degrees Celsius or, ±0.5 °C, whichever is greater. The temperature sensor
is to be installed at a location in the furnace downstream of-the flame
zone. Boilers and process heaters with a design heat input capacity greater
than or equal to 44 MW are required to be equipped with a monitoring device
with a continuous recorder to measure a parameter (e.g., combustion tempera-
ture) that demonstrates that good combustion operating practices are being
used.
When condensers are used, they are required to be equipped with either
a concentration level or temperature monitoring device and a continuous
7-2
-------
recorder. A concentration monitoring, device must be capable of monitoring
the concentration level of organic compounds in the condenser exhaust vent
stream. A temperature monitoring device must be capable of monitoring
temperature at two locations and have an accuracy of ±1 percent of the
temperature being monitored in degrees Celsius or, ±0.5 °C, whichever is
greater. One of the temperature sensors is required to be installed at a
location in the condenser exhaust vent stream, and the second temperature
sensor is to be installed at a location in the coolant fluid .exiting the
condenser.
Carbon adsorption systems that regenerate the carbon bed directly in
the control device are required to have a monitoring device with a contin-
uous recorder: The device can either measure the concentration level of the
organic compounds in the exhaust vent stream from the carbon bed or measure
a parameter that demonstrates that the carbon bed is regenerated on a regu-
lar, predetermined time cycle. -
Carbon adsorption systems that do not regenerate the carbon bed
directly on-site in the control device (e.g., carbon canisters) are required
to measure the concentration level of the organic compounds in the exhaust
vent stream on a regular schedule. It is also required that the existing
carbon be replaced with fresh carbon immediately after breakthrough is indi-
cated. The monitoring frequency is to be at an interval of 20 percent of
the time required to consume the total carbon working capacity or once a
day, whichever is less frequent. An example illustrating how to calculate
carbon canister monitoring frequency is presented in Appendix I.
The monitoring device used to indicate the concentration level of
organic compounds exiting a condenser or carbon adsorption system should be
based on a detection principle such as infrared detection, photoionization,
or thermal conductivity.
The TSDF owner/operator is required to inspect the readings from each
of the monitoring devices at least once each operating day to-check control
device operation and, if necessary, immediately implement the corrective
actions necessary to ensure that the control device operates in compliance
with Subparts AA and BB.
When a control device other than an incinerator, flare, boiler, process
heater, condenser, or carbon adsorption system is used, the owner/operator
is required to demonstrate the organic emission reduction achieved by the
7-3
-------
control device. This demonstration 'can be made by conducting a performance
or source test, by using engineering calculations, or with vendor certifica-
tion of equipment performance. If owners/operators elect to conduct a
performance test, they are required to develop and record a test plan as
specified in Sections 264.1035 and 265.1035. An additional requirement when
applying for a RCRA permit is that the Regional Administrator be provided
with sufficient information to describe the control device operation and
indicate the process parameter or parameters that demonstrate proper opera-
tion- and maintenance of the control device. The Regional Administrator may
request additional information and will specify the appropriate monitoring,
inspection,' and maintenance requirements.
Closed-vent systems must be. monitored to show that no detectable emis-
sions are present. This monitoring must be done initially, annually, and at
"other times as requested by the Regional Administrator. Leaks in closed-
vent systems, as indicated by an instrument reading of 500 ppm or greater or
by visual inspections, must be repaired as soon as possible, but not later
than 15 calendar days after the leak is detected. A first attempt at repair
must be made no later than 5 calendar days after the leak is detected.
7.1.2 Equipment Leaks
7.1.2.1 Pumps. Each pump in light-liquid service must be monitored
for leaks on a monthly basis in accordance with Reference Method 21 in 40
CFR 60. In addition, pumps in light-liquid service must be visually
inspected each calendar week for indications of liquid dripping from the
pump seal. If an instrument reading of 10,000 ppm or greater is measured or
if there are indications of liquid dripping from the pump seal, then a leak
is detected. When a leak is detected, it shall be repaired as soon as
possible, but not later than 15 calendar days after it is detected. A first
attempt at repair must be made no later than 5 days after the leak is
detected.
Pumps equipped with a dual mechanical seal system that includes a
barrier fluid system are exempt from the above monitoring requirements if
"each dual mechanical seal system is: (a) operated with a barrier fluid
pressure that is at all times greater than the pump stuffing box pressure;
(b) equipped with a barrier fluid degassing reservoir that is connected by a
closed-vent system to a control device that complies with the requirements
7-4
-------
of Section 264.1060 or Section 265.1060; or (c) equipped with a system that
purges the barrier fluid into a hazardous waste stream with no detectable
organic emissions to the atmosphere, (this system must be checked daily or
equipped with an audible alarm*) For such a system, the owner/operator must
also determine a criterion that indicates failure of the seal system, the
barrier fluid system, or both. Additionally, the barrier fluid system must
not be a hazardous waste with organic concentrations of 10 percent or
-greater by weight. Each barrier fluid system must also be equipped with a
sensor that will detect failure of the seal system, .the barrier fluid
system, or both. The sensor must be equipped with an audible alarm that
must be checked monthly to ensure that it is functioning properly. Each
pump must be visually inspected, each calendar week, for indications of
liquid dripping from the pump seals. .-.If liquid is.dripping.from the pump
seal.of if the sensor.indicates failure, a leak is detected. A first
attempt at repair of the leak must be.made within" 5 calendar days of
detection, and repair must be completed not later than 15 calendar days
after detection.
Any pump that is designated for no detectable emissions, as indicated
by an instrument reading of less than 500 ppm above background, is exempt
from the weekly and monthly monitoring requirements of Section 264.1052(a)
or Section 265.1052(a), the repair requirements of Section 264.1052(c) or
265.1052(c), and the requirements of Section 264.1052(d) or 265.1052(d).
For pumps with dual mechanical seal systems, exemption may be granted
provided that the pumps: (a) have no externally actuated shaft penetrating
the pump housing; (b) operate with no detectable emissions as indicated by
an instrument reading of less than 500 ppm above background as measured by
the methods specified in Section 264.1063(c) or 265.1063(c); and (c) be
visually inspected for indications of liquid dripping from the seal initi-
ally upon designation, annually, and at other times as requested by the
Regional Administrator.
Any pump that is equipped with a closed-vent system capable of
capturing and transporting any leakage from the seal(s) to a control device
that complies with the requirements of Section 264.1060 or 265.1060 is
exempt from the above requirements for pumps in light-liquid service.
7.1.2.2 Compressors. Compressors are required to be equipped with a
seal system that, includes a barrier fluid system and prevents leakage of
7-5
-------
total organic emissions to the atmosphere. Each compressor seal system must
be operated with the barrier fluid at a pressure that is greater than the
compressor stuffing box pressure, equipped with a barrier fluid system that
is connected by a closed-vent system to a control device that complies with
Section 264.1060 or Section 265.1060, or equipped with a system that purges
the barrier fluid into a hazardous waste stream with zero total organic
emissions to the atmosphere. In addition, the barrier fluid must not be a
hazardous waste with organic concentrations of 10 percent or greater by
weight.
Each barrier fluid system must be equipped with a sensor that will
detect failure of the seal system, barrier fluid system, or both. The
sensors must be checked daily or equipped with an" audible alarm unless the
compressor is located wjthin the boundary of an unmanned plant site, in .
which case the sensor must be checked daily. The audible alarm must be
checked monthly to ensure that it is functioning properly. The owner/
operator is responsible for determining a criterion that indicates system(s)
failure. If a failure 'occurs, a leak is detected. Repair is then required
to be initiated within 5 days and completed within 15 days of detection.
A compressor is exempt from the seal and barrier fluid system require-
ments described above if it is equipped with a closed-vent, system capable of
;capturing and transporting any leakage from the seal to a control device
that complies with the requirements of Section 264.1060 or 265.1060.
Any compressor that is designated for no detectable emissions as indi-
cated by an instrument reading of less than 500 ppm above background is
exempt from the above requirements if it is demonstrated to be operating
with no detectable emissions, as measured by the method specified in Section
264.1063(c) or 265.1063(c) and is tested initially upon designation, annu-
ally, and at other times requested by the Regional Administration to
determine that no detectable emissions are present.
7.1.2.3 Pressure Relief Devices. Pressure relief devices in gas/vapor
service are required to be operated with no detectable emissions except
during pressure releases. No detectable emissions are defined as an instru-
ment reading of less than 500 ppm above background, as measured by the
method specified in Section 264.1063(c) or Section 265.1063(c). As soon as
possible, but not later than.5 days after each pressure release, the
7-6
-------
pressure relief device must be returned to a condition of no detectable
emissions except as provided in Section 264.1054 or 265.1054. No later than
5 calendar days after the pressure release, the pressure relief device shall
be monitored to confirm the conditions of no detectable emissions. Any
pressure relief device that is equipped with a closed-vent system capable of
capturing and transporting leakage from the pressure relief device to a
control device as described in Section 264.1060 or 265.1060 is exempt from
the above requirements.
7.1.2o4 Valves. Valves.in light-liquid or gas/vapor service must be
monitored monthly to detect leaks in accordance with Reference Method 21 in
40 CFR 60. If an instrument reading of 10,000 ppm or greater is measured, a
leak, is detected. Any valve for which a leak is not detected for 2 succes-
sive months may be monitored the first month of every succeeding quarter,
beginning with the next quarter, until a leak is detected. If a leak is
detected, the valve must be monitored monthly until a leak is not detected
for 2 successive months. Repairs must be made as soon as possible and are
required to be initiated no later than 5 days after detection and completed
no later than 15 calendar days after detection. .
Any valve that is designated for no detectable emissions under the.
provisions of Section 264.1057(f) or 265.1057(f) is exempt from the above
monthly monitoring requirements if the valve has no external actuating
mechanism in contact with the process fluid; is operated with emissions less
than 500 ppm above background; and is tested for compliance with the no
detectable emission standards initially upon designation, annually, and at
other times as requested by the Regional Administrator.
Any valve that is designated under the provisions of Section
264.1057(g) or 265.1057(g) as unsafe-to-monitor is exempt from the monthly
monitoring requirements if the owner/operator demonstrates that the valve is
unsafe to monitor because monitoring personnel would be exposed to an imme-
diate danger, and if the owner/operator adheres to a written plan that
requires monitoring of the valve as frequently as possible during safe-to-
monitor times.
Valves designated under the provisions of Section 264.1057(h) or
265.1057(h) as difficult-to-monitor are exempt from the monthly monitoring
requirements if (a) the owner/operator demonstrates that the valve cannot be
.7-7
-------
monitored without elevating the monitoring personnel more than 2 m (6.6 ft)
above a support surface, (b) the hazardous waste management unit that the
valve is a part of is located in an existing hazardous waste management
unit, and (c) the owner/operator follows a written plan that requires moni-
toring of, the valve at least once per calendar year.
An owner/operator subject to the above requirements for valves in
gas/vapor or light-liquid service may elect to have all valves within a
hazardous waste management unit comply with an alternative standard that
allows no greater than 2 percent-of the valves to leak.- If this alternative
standard is chosen, the owner/operator must notify the Regional Administra-
tor. A performance test must also be conducted initially upon designation,
annually, and at other times requested by the Regional Administrator. The-
performance test requires all valves in the hazardous waste management unit
subject to the requirements in Section 264.1061 or 265.1061 to be monitored
within 1 week by the methods specified in Section 264.1063(b) or Section
265.1063(b). If an instrument reading of 10,000 ppm or greater is measured,
a leak is detected. If a leak is detected, it shall be repaired in accord-
ance with Section 264.1057(d) and (e) or Section 265ol057(d) and (e). The
leak percentage is determined by dividing the number of leaking valves
subject to the requirements in Section 264.1057 or 265.1057 by the total
number of valves that are subject to the requirements in Section 264.1057 or
Section 265.1057 within the hazardous waste management unit.
If an owner/operator decides to no longer comply with the alternative
standards for valves (Section 264:1061 or 265.1061), the Regional Adminis-
trator must be notified in writing that the standard described in Sections
264.1057(a) through (e) or Sections 265.1057(a) through (e) will be
followed.
Additional alternative standards for valves in gas/vapor or light-
liquid service may be elected by owners/operators subject to the require-
ments of Section 264.1057 or 265.1057. These alternative work practices
require the owner/operator to comply with the valve monitoring as described
in Section 264.1057 or 265.1057. However, if after two consecutive quarter-
ly leak detection periods when the percentage of valves leaking is equal to
or less than 2 percent, an owner/operator may begin to skip one of the
quarterly leak detection periods; or, if after five consecutive quarterly
7-8
-------
Teak detection periods when the percentage of valves leaking is equal to or
less than 2 percent, an owner/operator may begin to, skip three of the
quarterly leak detection periods. If the percentage of valves leaking is
greater than 2 percent, the owner/operator must monitor monthly in compli-
ance with Section 264.1057 or 265.1057, but may again elect to use this
alternative standard (Section 264.1062 or 265.1062) after meeting the
requirements of Section 264.1057(c)(1) or 265.1057(c)(1). The owner/oper-
ator must notify the Regional Administrator before implementing one of the
alternative work practices. .
7.1.2.5 Other .Equipment. Pumps and valves in heavy-liquid service,
pressure relief devices in light-liquid or heavy-liquid service, and flanges
and other connectors shall be monitored within 5 days by the method speci-
fied in Section 264.1063(b) or 265.1063(b). if evidence of a.potential-leak
is found by visual, audible, olfactory, or any other detection method. If
an instrument reading of 10,000 ppm or greater is measured, a leak is
detected. After a leak is detected, the first attempt at repair must be
made within 5 calendar days and the repair must be completed within 15
calendar days. First attempts at repairs include, but are not limited to,
the practices described in Section 264.1057(e) or 265.1057(e).
7.2 RECORDKEEPING
Each TSDF owner/operator subject to the provisions of Subparts AA
and/or BB must comply with the recordkeeping requirements of Sections
264.1035, 264.1064, 265.1035 or 265.1034. An owner/operator of more than
.one facility subject to these requirements may comply with the recordkeeping
requirements for these hazardous waste management units with one recordkeep-
ing system if the system identifies each record by each hazardous waste
management unit.
Table 7-1 summarizes the recordkeeping and reporting requirements of
the process vent and equipment leak air emission standards. The following
sections outline the general RCRA recordkeeping requirements and the
specific recordkeeping requirements of the process vent and equipment leak
air emission standards.
7.2.1 General RCRA Recordkeepinq Requirements
The general RCRA recordkeeping requirements for permitted and interim-
status facilities are contained in 40 CFR 264, Subpart E, and 40 CFR 265, ,
7-9
-------
TABLE 7-1. CROSS-REFERENCE BETWEEN SUBSTANTIVE
REQUIREMENTS AND RECORDKEEPING/REPORTING
REQUIREMENTS OF PARTS 264 AND 265, SUBPARTS AA* and BB
ItemM
Substantive requirement^
Recordkeeping/reporting
requirement
A.
Pumps in light-
liquid service
B.
C.
Pumps in light-
liquid service
(Dual seal
systems)0
Pumps in light-
liquid service
(Sealless)c
1. Monthly LDRPe §264.1052
and §265.1052.
2. Weekly visual inspection^
§264.1052(a)(2) and
§265.1052(a)(2).
1. Designed and operated
under certain conditionsQ
§264.1052(d)(l)-(6) and
§265.1052(d)(l)-(6).
2. Inspection of seals and
seal systems-S264.1052(d)
(4),(5),(6 and §265.1052(d)
. (4),(5).(6).
1. Designed and operated under
certain conditions -
§264.1052(e)(l),(2) and
§265.1052(e)(l),(2).
3. Tag leaking sources
only - §264.1064(c)
and §265.1064(c).
4. Record dates, repair
attempts and methods,
and reasons for delay
of repair etc. -
Ij264.1064(d) and
jj265.1064(d). •
3. Record seal system
design criterion -
IS264.1064(j) and
jj265.1064(j).
4. Same as A3 and A4.
Record results pf
compliance tests -
f!264.1064(g)
and §265.1064(g).
D. Pumps in light-
liquid service
(Hooded)c
E. Compressors '
(General)
2. Tested for "no detectable
emissions" - §264.1052(e)(3)
and §265.1052(e)(3).
1. Designed and operated under
certain conditions -
§264.1052(f) and
§265.1052(f).
1. Installation of seal system
§264.1053(a)-(d) and
§265.1053(a)-(d).
2. Inspection of seals -
§264.1053(e) and
§265.1053(e).
Record design crite-
rion - §264.1064(e)
and §265.1064(e)
3. Record seal system
design criterion -
Ij264.1064(j) and
|265.1064(j).
4. Same as A3, A4.
(continued)
7-10
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TABLE 7-1 (continued)
Substantive requirement^
Recordkeepi ng/reporti ng
requirement
F. Compressors
(Hooded)c
G. Compressors
(Sealless)c
H. Pressure relief
devices (gas
service) (General)
I. Pressure relief 1.
devices (gas
service) (Hooded)0
J. Sampling . 1
connection systems
(General)
K. Open-ended 1
valves or lines
2.
Designed and operated under
certain conditions -
6264.1053(h) and
•§265.1053 (h).
Designed and operated under
certain conditions -
§264.1053(0(0 and
§265.1053(0(1).
Tested for "no detectable
emissions - §264.1053(i)(2)
and §265,1053(0(2).
Designed and operated for
no detectable emissions -
§264.1054(a) and
§265.1054(a).
Tested for no detectable
emissions - §264.1054(b)
and §265.1054(b).
Designed and operated
under certain conditions -
§264.1054(c) and
§265.1054(c). .
Designed and operated
under certain conditions -
§264.1055(a),(b) and
§265.1055(a),(b).
Cap open-ended lines
§264.1056(a)(l) and
§265.1056(a)(l).
Operational requirements
§264.1056(a)(2),(b),(c)
and §265.1056(a)(2),(b),(c).
L. Valves in gas/ 1.
vapor service in
light-liquid service
Monthly LDRP - §264.1057 2,
(a)-(e) and §265.1057(a)-(e).
Same as D2,
Same as C3.
3. Same as C3
Same as D2.
Same as D2.
Same as A3, A4,
(continued)
7-11
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TABLE 7-1 (continued)
Iterate
Substantive requirement^
Recordkeep i ng/report i ng
requirement
M. Valves in gas/
vapor service in
light-liquid
service
(Leakless)0
Valves in gas/
vapor service in
light-liquid
serv-ice
(Unsafe to monitor)
Valves in gas/
vapor service in
light-liquid
service
(Difficult to
monitor)
P. Pumps and valves
in heavy-liquid
service
Q. Pressure relief
devices in liquid
service and
flanges and other
connectors
(General)
R. Delay of repair
(General)
1.
1.
1.
Designed and operated 3.
under certain conditions -
§264.1057(f)(l) and (2)
and §265.1057(f)(l) and (2).
Tested for "no detectable
emissions" - §264.1057(f)(3)
and §265.1057(f)(3).
Monitoring during safe-to- 2.
monitor times - §2644057
and §265.1057(g)(2).
2.
Annual monitoring -
§264.1057(h)(3) and
§265.1057(h)(3).
LDRP within 5 days
§264.1058(a) and
§265.1058(a).
LDRP within 5 days
§264.1058(a) and
§265.1058(a).
3.
2.
Repair infeasible without 2.
unit shutdown - §264.1059(a)
and 265.1059(a)
Same as C3.
Maintain record of
monitoring plan and
explain why valve
is unsafe to monitor-
§264.1064(h)(lj and
8265.1064(h)(l).
Maintain record of
monitoring schedule
and explain why valve
is difficult to
monitor - §264.1064
'h)(2) and §265.1064
2. Record heavy liquid
service determination
§264.1064(k)(2) and
§265.1064(k)(2).
Same as A3, A4.
Same as A3, A4.
Record reason for delay
repair, owner/operator
signature, expected
date of repair, dates
of shutdowns -
§264.1064(d)(6)-(9) and
§265.1064(d)(6)-(9).
(continued)
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TABLE 7-1 (continued)
Itemb-c
Substantive requirement^
Recordkeepi ng/report!ng
requirement
S. Delay of repair 1.
(Out of service)
T. Delay of repair
(Valves)
W.
1.
2.
U. Delay of repair 1.
(Pumps)
V. Closed-vent 1.
systems and control
devices (General)
Closed-vent
systems and
control devices
(Vapor recovery)
X.
Closed-vent
systems and
control devices
(Enclosed
combustion)
2.
Equipment isolated from 2.
process and not in
service - §264.1059(b)
and §265.1059(b).
Purged emissions greater 3.
than emissions from delay -
§264.1059(c) and §265.1059(c).
Beyond shutdown if stock of
valve bodies is depleted -
§264.1059(e)' and §265.1059(e).
If dual seal/barrier fluid 2.
system is used - §264.1059
(d), and §265.1059(d).
Designed and operated under 4.
certain conditions -
§264.1033, §264.1060,
§265.1033 and §265.1060. 5.
Tested for "no detectable 6.
emissions" ^ §264.1033(j)(2)
and §265.1033(j)(2).
Operate closed-vent systems
and control devices when
emissions are vented to them -
§264.1033(k) and §265.1033(k).
Designed and operated under 4.
certain conditions -
§264.1033(b) and 5.
§265.1033(b).
Monitor control devices -
§264.1033(f),(g),(h) and
§265.1033(f),(g)(h).
3. Same as V3.
1. Designed and operated under
certain conditions -
, §264.1033(c) and
§265.1033(c).
Same as R2.
Same as R2.
Same as R2.
Same as D2.
Same as C3.
Report exceedances
semi annually -
§264.1036(a)(2),
§264.1065(a)(4).
§265.1036(a)(2)
§265.1065(a)(4)
and
Same as D2.
Record exceedances -
S264.1035(c)(3)(vi),
§265.1035(c)(3)(vi),
(vii),(viii),(ix),
*264.1064(e), and
§265.1064(e).
Same as D2.
7-13
(continued)
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TABLE 7-1 (continued)
Itemb«c
Substantive requirement^
Recordkeeping/reporting
requirement
X. (con.)
Y. Closed-vent
systems and
control devices
(Flares)
Alternative
standards for
valves (allow-
able percent
leakingjc
AA. Alternative
standards for
Valves (skip
period LDRP)c
2. Monitor control devices - 5.
§264. 1033 (f) and
§265.1033(f).
3. Same as V3.
1. Designed and operated under .4.
certain conditions -
§264.1033(d)(l)-(6) and 5.
§265.1033(d)(l)-(6).
2. Monitor control devices -
§264.1033(f) and §265.1033(f).
3. Same as V3.
1. Elect to follow alternative
and notify Regional
Administrator - 3.
§264.1061(a),(b)(l), and
§265.1061(a),(b)(l).
2. Conduct performance test -
§264.1061(b)(2),(c)(l)-(3)
and 265. 1061 (b) (2),
1.
2.
Elect to follow one or two
alternative work practices
and notify Regional
Administrator -
§264. 1062 (a) and
§265. 1062 (a).
Comply initially with
routine valves standard -
§264.1062(b)(l) and
§265.1062(b)(l).
Follow one or two
alternative work practices
§264.1062(b)(2)-(3) and
§265.1062(b)(2)-(3).
Return to routine valve
standard if 2 percent
valves leaking is exceeded
§264.1062(b)(4) and
§265.1062(b)(4).
Record exceedances -
§264.1035(0 (3) (0,
(1i),(1ii),(1v) and
8265.1035(0(3)(i),
tli), (ill), (iv).
Same 02.
Record exceedances -
§264.1035(c)(3)(v) and
§265.1035(0(3)(v).
Notify if return to
routine work practice
§264.1061(d) and
§265.1061(d).
Record monitoring
schedule and percent
of valves leaking -
§264.1064(i) and ,
§265.1064(i).
(continued)
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TABLE 7-1 (continued)
Itemb.c
Substantive requirement^
Recordkeeping/reporting
requirement
A8. Process vents
1. Comply with facility emis-
sion limit or reduce organic
emissions from all affected
process vents - §264.1032
and §265.1032.
2. Control device designed
and operated under certain
conditions - §264.1033
- and-§265.1033.
3.. Monitor control device
parameters - Same as W2,
X2, Y2.
5.
6.
Same as D2.
Same as W5..X5, Y5.
Same as V6.
aThe requirements presented in this table are those for the process vents and
equipment covered by Subparts AA and 88.
bEach source covered by Subparts AA and BB is listed and the requirements for
that source are annotated mainly by indicating the substantive requirements for
that source,, the citation for those requirements, the associated recordkeeping/
reporting requirements and their citation. Each block (e.g., 'A. Pumps
(General)') is mutally exclusive of other blocks.
CA note 'c' indicates that the requirements are alternatives to the general
requirements. As such, these requirements take the place of the general
requirements. Accordingly, if a piece of equipment is covered by an alternative
requirement, it is not covered by the general requirements.
substantive requirements are summarized and a reference to the exact regula
tory language is provided if more detail is needed.
eLDRP means "leak detection and repair program." This generally includes the
use of a portable monitor to detect leaks and then, for those pieces of equip-
ment that are leaking, repair of the leak. Delay of repair is general to all
sources and is presented separately.
f Inspection generally means visual inspection of seal areas as well as seal-
barrier fluid system integrity. Inspection includes repair of leaking seals
and seal /barrier fluid systems.
9Designed and operated generally means .that specific equipment or designs are
allowed if they are- used in ways that result in emission reductions that are
at least equivalent to the general requirements.
7-15
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Subpart E. These subparts contain discussions on the use of a waste
manifest system (Sections 264.71 and 265.71), requirements for facility
operating records (Sections 264.73 and 265.73), availability of records
(Sections 264.74 and 265.74), and the facility biennial report (Sections
264.75 and 265.75). Information (with the exception of the results of
inspections) must be maintained in the operating record until facility
closure. In addition to submitting the biennial reports and unmanifested
waste reports, the owner/ operator is required to report to the Regional
Administrator specific occurrences as outlined, in Section:; 264.77(a)-(c) and
265.77(a)-(c).
7.2.2 Process Vent Recordkeepinq Requirements
For each process vent to which Subpart AA of Part 264 or 265 applies,
the-owner/operator must record .in the facility operating record: identifi-
cation number and hazardous waste management unit identification, type of
unit, percent by weight total organics in the hazardous waste managed in the
unit, state (e.g., gas/vapor or liquid) of hazardous waste at the unit, the
organic emissions from each process vent associated with the unit, and
method of compliance with the standard. »
The facility operating record must also include an implementation
schedule indicating dates by which the design and construction of any
control device and closed-vent systems required by the provisions of Section
264.1032 or 265.1032 will be completed. The implementation schedule may
allow up to 18 months after the effective date for completing engineering
design and evaluation studies and for installation of controls. The final
standards require that both permitted and. interim-status facilities maintain
the schedules and the accompanying documentation in their operating records.
The implementation schedule must be in the operating record on the effective
date of the regulation, which is 6 months after promulgation. No provisions
have been made in the standards for extensions beyond the 18-month
allowance.
Included in the facility operating record must be documentation that
demonstrates compliance with the process vent standards in Section 264.1032
or 265.1032. This documentation must include information and data identify-
ing all affected process vents, annual facility throughput, annual facility
operating hours, estimated emission rates for each affected vent and for the
overall facility, and information and data supporting estimates of vent
7-16
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emissions and emission reductions achieved by add-on control devices based
on engineering calculations or source tests. Also included in the operating
record must be documentation that demonstrates compliance with the equipment
standards in Sections 264.1052 to 264.1062 or Sections 265.1052 to 265.1062.
The Regional Administrator may request further documentation before deciding
if compliance has been demonstrated.
Documentation to demonstrate compliance with Section 264.1033 or
265.1033, must include a list of all .information, references, and sources
used in preparing the documentation; records required by Section 264.1035(b)
or 265.1035(b) that document the organic content of the liquids, gases, or
fumes emitted to the atmosphere; a design analysis .based on the appropriate
sections of "Control of Gaseous Air Pollutants" or other engineering texts;
a statement signed and dated by the owner/operator certifying that the
operating parameters.used in the design analysis represent the conditions
that exist when the hazardous waste management unit is operating at the
highest load or capacity level reasonably expected to occur; and a signed
and dated statement by the owner/operator certifying that the control device
is designed to operate at 95 or greater percent efficiency unless the total
organic emission limits of Section 264.1032 and 265.1032 for affected
process vents at the facility can be attained by a control device involving
vapor recovery at an efficiency less than 95 percent.
The facility's process vent emission rate determination must be appro-
priate at all times to the facility's current waste management unit designs
and wastes managed. If the owner/operator takes any action that would
result in the determination no longer being appropriate to the facility's
operations, then a new determination is required (e.g., if a waste of
different composition is managed, the operating hours of the affected
management units are increased beyond what was originally considered, or a
new affected unit is added).
Design and operating information for each closed-vent system and
control device required by Sections 264.1032 and 265.1032 shall be recorded
and kept up-to-date in the facility operating record. The operating infor-
mation described in (d) and (e) below need .only be kept for 3 years. The
required design and operating information includes: (a) detailed design
specifications, drawings, schematics, and piping and instrumentation
diagrams; (b) description and date of each modification that is made to the
7-17
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closed-vent system or control device'design; (c) identification of operating
parameter, description of monitoring device, and a diagram of monitoring
sensor location(s) used to comply with Section 265.1033(f)(2); (d) date,
time, and duration of each period when any monitored parameter identified
above exceeds the value established in the control device design analysis,
as well as an explanation of the cause for the exceedance and the measures
implemented lo correct the control device operation; and (e) the date of
each control device startup or shutdown.
For thermal vapor incinerators designed to operate with a minimum
residence time of 0.50 s at a minimum temperature of 760 °C (1,400 °F), tne
above information must be recorded for periods when the combustion tempera-
ture is below 760 °C (1,400 °F). For thermal vapor- incinerators designed to
operate with an organic emission reduction'efficiency of 95 percent or
greater, the owner/operator is required to record the period when the
combustion temperature is more, than 28 °C (82.4 °F) below the design average
combustion temperature established as a requirement of Section
264.1035(b)(4)(iii)(A) or 265.1035(b)(4)(iii)(A).
TSDF owner/operators with catalytic incinerators are required to record
the period when the temperature of the vent stream at the catalyst bed inlet
is more than 28 °C (82.4 °F) below the average temperature of the vent
stream or the temperature difference across the catalyst bed is less than 80
percent of the design average temperature difference established as a
requirement of Section 264.1035(b)(4)(iii)(B) or 265.1035(b)(4)(iii)(B).
For boilers or process heaters, the owner/operator is required to
record periods when the combustion temperature is more than 28 °C (82.4 °F)
below the design average combustion temperature or, when position changes
where the vent stream is introduced to the flame zone as a requirement of
Section 264.1035(b)(4)(iii)(C) or 265.1035(b)(4)(iii)(C). When flares are
used, the owner/operator must record periods when the pilot flame is not
ignited.
TSDF owner/operators that have condensers with a monitoring device
equipped with a continuous recorder, must record the period when the organic
compound concentration in the exhaust vent stream is more than 20 percent
greater than the design level established as a requirement of Section
264.1035(b)(4)(iii)(E) or 265.1035(b)(4)(iii)(E). For condensers that
7-18
-------
comply with Section 264.1033(f)(2)(vi)(B) or 265'. 1033(f) (2) (vi) (B), the
owner/ operator is required to record the period when the temperature of the
exhaust vent stream is more than 6 °C (42.8 °F) above the design average
exhaust vent stream temperature established as a requirement of Section
264.1035(b)(4)(iii)(E) or 265.1035(b)(4)(iii)(E) or the period when the
temperature of the coolant fluid exiting the condenser is more than 6 °C
(42.8 °F) above the design average coolant fluid temperature established as
.a requirement of Section 264.1035(b) (4) (iii) (E) or 265.1036.(b) (4) (I'M) (E).
For carbon adsorption systems that regenerate the carbon bed directly
on site in the control device and comply with Section 264.1033(f)(2)(vii)(A)
or 265.1033(f)(2)(vii)(A), the owner/operator is required to record any
periods when the organic compound concentration level or reading of organic
compounds in the exhaust vent stream is more than 20 percent greater'than
the design exhaust vent stream organic compound concentration level estab-
lished as a requirement of Section 264.1035(b)(4)(iii)(E) or 265.1035(b)(4)
(iii)(F). For similar types of carbon adsorption systems that comply with
Section 264.1033(f)(2)(vii)(B) or 265.1033(f)(2)(vii)(B), it is required
that the owner/operator record any periods when the vent stream continues to
flow through the control device beyond the predetermined carbon bed regen-
eration time established as a requirement of Section 264.1035(b)(4)(iii)(F)
or 265.1035(b)(4)(iii)(F).
Additional requirements for carbon adsorption systems are that those
systems operated subject to the requirements of Section 264.1033(g),
265.1033(g), 264.1033(h)(2), or 265.1033(h)(2j must record the date when
existing carbon' in the control device is replaced with fresh carbon. For
carbon adsorption systems operated subject to the requirements specified in
Section 264.1033(h)(l) or 265.1033(h)(l), the owner/operator is required to
maintain a log that records the date and time when the control device is
monitored for carbon breakthrough, the monitoring device reading, and the
date when existing carbon in the control device is replaced with fresh
carbon.
When either carbon regeneration or removal takes place, there is an
opportunity for organics to be released to the atmosphere unless the carbon
removal or regeneration is carried out under controlled conditions. There
would be no environmental benefit in removing organics from an exhaust gas
7-19
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stream using adsorption onto activated carbon if the organics are subse-
quently released to the atmosphere during desorption or during carbon
disposal. The EPA therefore expects that owners or operators of TSDF using
carbon adsorption systems to control organic emissions take steps to ensure
that proper emission control of regenerated or disposed carbon occurs. For
on-site regenerable carbon adsorption systems, the owner or operator must
account for the emission control of the desorption and/or disposal process
i
in the control efficiency determination. In the case of off-site regenera-
tion or'disposal, the owner or operator should supply a certification, to be
placed in the operating file of the TSDF, that all carbon removed from a
carbon adsorption system used to comply with Subparts AA arid BB is either:
(1) regenerated or reactivated by a process that prevents the release of
organics to the atmosphere ('Note; The EPA interprets "prevents" as used in
this paragraph to include the application of effective control devices such
as those required by these rules), (2) incinerated in a device that meets
the performance standards of Subpart 0, or (3) .disposed in compliance with
Federal and State regulations.
For control devices other than thermal or catalytic incinerators,
flares, boilers, process heaters, condensers, or carbon adsorption systems,
owners/operators of interim status facilities must record information
indicating proper operation and maintenance of the control device in the
facility operating record. The Regional Administrator (or Director) will
specify the appropriate recordkeeping requirements for facilities with final
permits as a part of the permit negotiation process.
7.2.3 Equipment Leak Recordkeepinq Requirements
Information pertaining to equipment subject to the requirements in
Parts 264 and 265, Subpart BB, must be recorded in a log that is kept in the
facility operating record. This information includes:
1. ' Equipment identification number and hazardous waste manage-
ment unit identification,
2. Approximate locations within the facility (e.g., identify the
hazardous waste management unit on a facility plot plan),
3. Type of equipment (e.g., a pump or pipeline valve),
4. Percent-by-weight total organics in the hazardous waste
stream at the equipment,
7-20
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5. Hazardqus waste state at the equipment (e.g., gas/vapor or
liquid)", and
6. Method of compliance with the standard (e.g., "monthly leak
detection and repair" or "equipped with dual mechanical
seals").
In addition, for a facility that takes up to 18 months after the effective
date to install a closed-vent system and control device, an implementation
schedule must be in the operating log. If the owner or operator demon-
strates the control device effectiveness with a performance test, the
performance test pTan and test results must be in the log. Otherwise,
detailed design documentation supporting the control device effectiveness
must be in the operating log. The log also must contain the monitoring,
operating, and inspection information required by the standards. . .
To help identify equipment not subject to monthly-UDAR, the following
-information is recorded in a log that is kept in the facility operating
record: ,
1. A list of identification numbers for equipment (except welded
fittings) subject to the requirements of Subpart BB;
2. A list of identification numbers and signed (by the owner/op- .
erator) designations for equipment that the owner/operator
elects to designate for no detectable emissions;
3. A list of equipment identification numbers for pressure
relief devices;
4. The date of, measured background level, and maximum
instrument reading measured at the equipment during each
compliance test; and
5. A list of identification numbers of equipment in vacuum
service.
.Information pertaining to valves subject to the requirements of Sec-
tions 264.1057(g) and (h) or 265.1057(g) and (h) must.be recorded in a
logbook that is kept in the facility operating record. This information
includes: a list of identification numbers for valves that are designated
as unsafe or difficult to monitor; an explanation for each valve stating why
it is unsafe or difficult to monitor; and the plan for monitoring each
valve. For valves complying with Section 264.1062 or 265.1062, a schedule
7-21
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of monitoring and the percent of valves found leaking during each monitoring
period is required to be recorded in the facility operating record.m
When each leak is detected (as specified in Sections 264.1052,
264.1053, 264.1057, and 264.1058 or Sections 256.1052, 265.1053, 265.1057,
and 265.1058), a weatherproof and readily visible identification, marked
with the equipment identification number, must be attached to the leaking
equipment. The identification on a valve may be removed after it has been .
monitored for 2 successive months and no leak is detected during this time.
The identification on equipment,^except a valve, may be removed after it has
been repaired.
When a leak is detected as specified in the above paragraph, specific
information must be recorded in an inspection log and kept in the facility
operating record. This includes the instrument, operator, and equipment
identification numbers; the date that the leak'was detected and the dates of
attempted repairs; attempted repair methods; the statement "above 10,000" if
the maximum instrument reading measured by the methods specified in Section
264.1063(b) or 265.1063(b) after each repair attempt is equal to or greater
than 10,000 ppm; the statement "repair delayed" and the reason for the delay
if the repair is not made within 15 calendar days after discovery of the
leak; the signature of the owner/operator whose decision it was that the
repair could not be effected without a hazardous waste management unit
shutdown; the expected date of successful repair of the leak if the leak is
not repaired within 15 calender days; and the date of the successful repair
of the leak.
Criteria for barrier fluid system sensors required in Sections
264.1052(d)(5) and 264.1053(e)(2) or Sections 265.1052(d)-(5) and
265.1053(e)(2), an explanation of the criteria, any changes to the criteria,
and reasons for the changes must be recorded in a log that is kept in the
facility operating record.
Information used for determining exemptions as provided in the applica-
bility section of this subpart or other specific subparts must be recorded
in the log kept in the facility operating record. This information in-
cludes: (a) an analysis demonstrating the design capacity of the hazardous
waste management unit; (b) a statement listing the hazardous waste influent
and effluent from each hazardous waste management unit subject to the
7-22
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requirements in Sections 264.1051-1060 or Sections 265.1051-1060 and an
analysis demonstrating whether these hazardous wastes are heavy liquids; and.
(c) an analysis demonstrating that equipment is not subject to the require-
ments in Sections 264.1051-1060 or Sections 265.1051-1060.
Information and data that are used to identify and demonstrate that a
piece of equipment is not subject to the requirements in Sections 264.1052-
1060 or Sections 265.1052-1060 shall be recorded in a log that is kept in
the facility operating record.1 . .
Records of monthly equipment leak monitoring and repair, detectable
emission monitoring, and closed vent system and control device operating
information need be kept only 3 years.
The owner/operator of any facility subject to this subpart and to
'regulations in 40 CFR Part 60, Subpart VV, or 40 CFR Part 61, Subpart V, may
elect to demonstrate compliance with the regulations by documentation in
accordance with Section 264.1064 or 265.1064 .o.f this subpart or pursuant to
provisions of 40 CFR Part 60 or 61 (Section 264..1064(1) or 265.1064(1). For
cases when the documentation requirements of 40 CFR Part 60 or 61 duplicate
the documentation required under this.subpart,. multiple copies of identical
records are not required. In these instances, the documentation under the
regulation in 40 CFR Part 60 or 61 shall be kept with or made readily
available with the facility operating record.
7.3 .REPORTING REQUIREMENTS
The.standards for process vents and equipment leaks for RCRA-permitted
facilities subject to the provisions of 40 CFR Part 264, Subparts AA and/or
BB, require that control device exceedances (i.e., periods when monitoring
indicates that operating parameters exceed established tolerances for design
specifications) that go uncorrected for more than 24 hours be reported to
the Regional Administrator on a semiannual basis. (See Section 7.2.2 for a
discussion of control device exceedances.) The reports must include the
dates, duration, cause, and corrective measures taken. For equipment leaks,
a report is required if a leak is not repaired within the designated time .
period. If a facility does not have any exceedances during the reporting
period, no report is required. There are no reporting requirements for
interim status facilities subject to these air rules.
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8.0 IMPLEMENTATION AND COMPLIANCE
8.1 STATE AUTHORIZATION
8.1.1 Applicability of Rules in Authorized States
Under Section 3006 of RCRA, EPA may authorize qualified States to
administer and enforce the RCRA program within the State. (See 40 CFR Part
271 for the standards ,and requirements for authorization.) Following
authorization-, EPA retains enforcement authority under Sections 3008, 7003,
and 3013 of RCRA, although authorized States have primary enforcement
responsibility under Section 7002.
Prior to the HSWA of 1984, a State with final authorization adminis-
tered its hazardous waste program entirely in lieu of EPA administering the
Federal program in that State. The Federal requirements no longer applied
in the authorized State, and EPA could not issue permits for any facilities
in the State that the State was authorized to permit. When new, more
stringent Federal requirements were promulgated or enacted, the State was
obliged to enact equivalent authority within specified timeframes. New
Federal requirements did not take effect in an authorized State until the
State adopted the requirements as State law.
In contrast, under Section 3006(g)(l) of RCRA, 42 U.S.C. 6926(g), new
requirements and prohibitions imposed by HSWA take effect in authorized
States at the same time that they take effect in nonauthorized States. The
EPA is directed to carry out those requirements and prohibitions in author-
ized States, including the issuance of permits, until the State is granted-
authorization to do so. While States must still adopt HSWA-related provi-
sions as State law to retain final authorization, the HSWA requirements
apply in authorized States in the interim.
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8.1.2 Effect on State Authorizations
The Subpart AA and -BB rules are promulgated pursuant to Section 3004(n)
of RCRA, a provision added by HSWA. Therefore, EPA has added the require-
ments to Table 1 in 40 CFR 271.l(j), which identifies the Federal program
requirements that are promulgated pursuant to HSWA and take effect in all
States, regardless of authorization status. States may apply for either
interim or final authorization for the HSWA provisions identified in 40 CFR
271.l(j).
The EPA will implement the process vent and equipment leak rules in
authorized States until (1) they modify their programs to adopt these rules
and receive final authorization for the modification or (2) they receive
interim authorization as described below. Because these rules- are promul-
gated pursuant "to HSWA, a State.submitting a program modification may apply
* * i,
to receive either interim or final authorization under Section 3006(g)(2) or
Section 3006(b), respectively, on the basis of requirements that are
substantially equivalent or equivalent to EPA's. The procedures and sched-
ule for State program modifications for either interim or final authoriza-
tion are described.in 40 CFR 271.21. It should be noted that all HSWA
interim authorizations.will expire automatically on January 1, 1993 (see 40
CFR 271.24(c)).
Section 271.21(e)(2) requires that authorized States must modify their
programs to reflect Federal program changes and must subsequently submit the
modifications to EPA for approval. The deadline for State program modifi-
cations for this rule is July 1, 1991 (or July 1, 1992, if a State statutory
change is needed). These deadlines can be extended in certain cases [40 CFR
271.21(e)(3)]. Once EPA approves the modification, the State requirements
become Subtitle C RCRA requirements.
A State that submits its official application for final authorization •
less than 12 months after the effective date of these standards is not
required to include standards equivalent to these standards in its appli-
cation. However, the State must modify its program by the deadlines set
forth in 40 CFR 271.21(e). States that submit official applications for
final authorization 12 months after the effective date of the process vent
and equipment leak standards must include standards equivalent to these
standards in their applications. Section 271.3 sets forth the requirements
a State must meet when submitting its final authorization application.
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States that are authorized for R'CRA may already have requirements under
State law similar to those in the process vent and equipment leak rules.
These State regulations must be assessed against the Federal regulations
(i.e., Subparts AA and BB) to determine whether they meet the tests for
authorization. Thus, a State is not authorized to implement these require-
ments in lieu of EPA until the State program modification is approved. Of
course, States with existing standards may continue to administer .and
enforce their standards a-s a matter of. State law. In implementing the
Federal program, EPA will work with States under cooperative agreements to
minimize duplication of efforts. In many cases, EPA will be able to defer
to the States in their efforts to implement their programs rather than take
separate actions under Federal authority.
8.2 IMPLEMENTATION (THE RCRA PERMITTING PROCESS)
The final process vent and equipment leak standards limit organic emis-
sions at new and existing hazardous waste TSDF that need authorization to
operate under RCRA Section 3005 and are required to have a permit under
RCRA, 40 CFR Part 270. This applicability includes all hazardous waste
management units that require RCRA permits and hazardous waste recycling
units that are located on hazardous waste management facilities; if a RCRA
permit is needed for another part of the facility's operations independent
of the process vent and equipment leak rules (i.e., Subparts AA and BB of
Parts 264 and 265).
Implementation of these air rules is through incorporation of the rules
into the existing RCRA permitting process. The applicability of these
standards with respect to their incorporation into the RCRA permitting
process is discussed below. Figure 8-1 presents a flow diagram of the RCRA
permitting process. Chapter 3.0 of this document presents a flow diagram
and several examples that may be used as an aid to determining applica-
bility. '
8.2.1 Facilities with Permits
Facilities are not required to reopen their permits as a result of the
process vent and equipment leak standards. Under the current RCRA permit-
ting system, a facility that has received a final permit must comply with
all of the following requirements as specified in 40 CFR 270.4: (1) the
specific conditions written into the permit (including conditions that
8-3
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8
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8-4
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demonstrate compliance with Part 264 regulations); (2) self-implementing
statutory requirements; and (3) regulations promulgated under 40 CFR Part
268 restricting the placement of hazardous waste in or on the land. When
new regulations are promulgated after the issuance of a permit, EPA may
reopen the permit to incorporate the new requirements as stated in Section
270.41. Otherwise, the new regulatory requirements are incorporated into a
facility's permit at the time of permit reissuance (Section 124.15), or at
the 5-year review (Section 270.50) for land disposal facilities.
Although EPA has the authority to reopen permits to incorporate the
requirements of new standards, it is concerned about the resource burdens of
this approach. To reopen permits for each new regulation at the time it is
promulgated would impose a Targe administrative burden on both EPA and the
regulated community because a major permits modification would generally
require the same administrative procedures as are required for initial
permits (e.g., development of a draft permit, public notice, and opportunity
for public hearing). As a consequence, the requirements of new standards
•are usually incorporated into a permit when it is renewed. For standards
implemented through the RCRA permit system, the effect of this policy is to
"shield" facilities that have been issued a final permit from any require-
ments promulgated after the issuance of the permit until the time that the
permit must be renewed and the new requirements are written into the permit.
Thus, this policy is often referred to as the "permit-as-a-shield" policy.
Although this policy is generally applied, EPA may evaluate the need to
accelerate the implementation of standards developed under RCRA and, if
warranted, make exceptions to-the permit-as-a-shield policy. However, the
permit-as-a-shield provision applies to control of air emissions from
process vents and equipment leaks regulated under Section 3004(n).
Facilities issued permits prior to the effective date of these rules do
not have to comply with the 40 CFR 264, Subparts AA and BB, standards, or
modify their permits to incorporate these rules, until their permit is
reissued (40 CFR 124.15) or reviewed (40 CFR 270.50) by the Regional
Administrator. Facilities that are issued permits after the effective date
of these rules must comply with the requirements of Part 264, Subparts AA
and BB, for process vents and equipment leaks.
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8.2.2 Interim-Status Facilities
Facilities that meet RCRA interim-status requirements (i.e., compliance
with the requirements of Section 3010[a] of RCRA pertaining to notification
of hazardous waste activity and the requirements of 40 CFR 270.10 governing
submission of Part A applications) are subject to the Part 265, Subparts AA
and BB, standards on the effective date. Owners or operators of interim-
status facilities must make the appropriate determinations regarding applic-
ability and compliance and keep the required records and documentation in
their operating records. Interim-status facilities that have submitted
their Part B application prior to the effective date are required to modify
their Part B applications to incorporate the requirements of the Part 264
air rules.
8.2.3 New Facilities and Newly Regulated Units
The following paragraphs describe various RCRA permit scenarios and how
implementation of Subparts AA and BB occurs for newly regulated units.
With regard to newly constructed, regulated hazardous waste management
units, the effective date of Subparts AA and/or BB will vary depending on
the situation, including whether the TSDF is operating under RCRA interim
status. For owners or operators of noninterim-status facilities, new
hazardous waste management units may occur at newly constructed TSDF, at
currently permitted TSDF, or at existing facilities not previously requiring
a RCRA permit under Section 3005, e.g., formerly a Subtitle D operation or a
Subtitle C operation with RCRA-exempt units only.
Newly constructed TSDF and existing operations not previously permitted
are required to submit Parts A and B permit applications to receive a final
RCRA permit prior to construction of the new unit(s) (as required under
Section 270.10[f]). If these facilities meet the applicability requirements
of Subparts AA and/or BB, the rules become effective on the effective date
of the final RCRA permit, (i.e., to operate the hazardous waste management
unit, the owner or operator must have control equipment installed and oper-
ating and comply with all other requirements of the subparts upon startup of
the affected units). Part B applications for new facilities submitted prior
to the effective date will require modification to include the Part 264,
Subparts AA and BB, rules for process vents and equipment leaks. New
facilities that submit the Parts A and B application after the effective
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date must demonstrate in the Part B application how the air rules for
process vents and equipment leaks will be met.
For currently permitted facilities, permit modification is necessary if
a new hazardous waste management unit is to be added. For this situation,
the effective date of Subparts AA and BB, where applicable, is the effective
date of the permit modification.
Owners and operators of interim^status TSDF adding a new hazardous
waste management unit (Section 270.72[c]) must submit a revised Part A
application along with a justification explaining the need for the addition.
If this unit meets the applicability requirements of Subparts AA and/or BB,
these rules become effective on the date the Regional Administrator approves
the changes contained in the revised Part A application.
An existing solid waste management unit may become a hazardous waste
management unit when a solid waste becomes newly listed or identified as
RCRA hazardous. If "these units meet the applicability requirements of
Subparts AA and/or BB, the effective date of the rule will also vary depend-
ing on the facility's permit status. For example, owners and operators of
facilities not previously requiring a RCRA permit who have existing units
handling newly listed or identified RCRA hazardous wastes can submit a Part
A application and gain RCRA Subtitle C interim.status (Section 270.70[a]).
In this case, the effective date of Subparts AA and/or BB is the submittal
date of the Part A application.
For interim-status TSDF handling newly listed.or identified RCRA wastes
(Section 270.72[a]), the owner or operator must submit a revised Part A
application. If there are operations at the TSDF where Subparts AA and/or
BB applies for the first time, the effective date of the rules will be the
date the owner or operator submits the revised Part A application.
RCRA-permitted facilities are currently required to obtain a permit
modification before managing wastes not listed in the permit (e.g., wastes
that a facility is already handling that are newly listed or identified as
RCRA hazardous). However,'EPA has recently promulgated regulations to
reduce the level of detail to obtain such a permit modification (53 FR
37912, September 28, 1988). The effective date of this type of permit
modification will also be the effective date for applicable Subparts AA
and/or BB regulations. •
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For facilities with hazardous waste management units that previously
were not subject to control requirements because the wastes in the units did
not contain organics in concentrations greater than the applicability
criterion of 10 ppmw or 10 percent, whichever applies, the owner or operator
would be required to comply with all Subpart AA or BB requirements on the
date that the facility or waste management units become affected by the
rules (i.e., the date the facility begins to manage wastes in the units with
organic concentrations greater than 10 ppmw for Subpart AA or greater than
10 percent for Subpart BB), irrespective of any change -in permit status that
is required by the change in concentration. For the process vent emission
rate limit, the situation is somewhat different. TSDF process vents associ-
ated with the distillation/separation operations specified in the rule that
manage waste with organics. concentrations of 10 ppmw or greater are affected
by the regulation regardless of whether the facility emissions are above or
below the emission rate limit. Therefore, any change in the facility
operations that results in a TSDF going above or below the emission rate
limit "does not cause a change in the applicability of the facility to
Subpart AA. The final rules for process vents require that owners or oper-
ators of TSDF subject to the provisions of Subpart AA: (a) reduce total
organic emissions from all affected vents at the facility to below 1.4 kg/h
(3 Ib/h) and 2.8 Mg/yr (3.1 ton/yr), or (b) install control devices that
reduce total organic emissions from all affected vents at the facility by 95
weight percent or, in the case of enclosed combustion devices, to a total
organic compound concentration of not more than 20 ppmv, expressed as the
sum of actual compounds, on a dry basis corrected to 3 percent oxygen. One
of these conditions must be met at all times; the facility's emission rate
determination also must at all times reflect current design and operation
and wastes managed in the affected units.
8.2.4 Omnibus Permitting Authority
The permitting authority cited by Section 3005 of RCRA and codified in
Section 270.32(b)(2) states that permits issued under this section "...shall
contain such terms and conditions as,the Administrator or State Director
determines necessary to protect human health and the environment." This
section, in effect, allows permit writers to require, on a case-by-case
basis, emission controls that are more stringent than those specified by a
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standard. This omnibus authority should be used in situations where, in the
permit writer's judgment, there is an unacceptable high residual risk after
application of controls required by an emission standard. The EPA intends
to prepare a risk guidance document to be used by permit writers to help
identify facilities that would.potentially have high residual risk. The
guidance will include procedures to be used to identify potentially high
risk facilities and will include guidance for making a formal, site-specific
risk assessment. , ,
8.2.5 Part B Information .Requirements
In reviewing the Part B application, permit writers should verify that
the information required by the air rules and other RCRA rules is included
in the application and'that acceptable methods (appropriate test methods
and/or engineering judgment) have been used to generate the information.
The application is required to include documentation of the determinations
of hazardous waste management unit equipment and process vents at the facil-
ity not affected by these standards (e.g.,'equipment that will not contain
or contact hazardous wastes with concentrations equal to or greater than
10-percent organics). Test methods for determining the total organic
content of the hazardous waste stream that is managed in a unit or is
contained in or contacts equipment, as well as the process vent emissions,
are referenced in Sections 264.1063 and 265.1063 and are discussed in
Chapter 6.0 of this document. The application also should contain an imple-
mentation plan and schedule (discussed further in Section 8.3) indicating
dates by which design and construction of any control devices required to
comply with the standards will be completed.
The Part B application also must include information and data document-
ing that the process vent emission rate limit is or will be met with the
" installation of controls that will reduce the total organic emissions from
all affected vents at the facility to below 1.4 kg/h (3 Ib'/h) and 2.8 Mg/yr
(3.1 ton/yr) or that reduce the total organic emissions from all affected
vents at the facility by 95 weight percent. The process vent emission rate
can be determined by engineering calculations or source tests.
As required by the equipment leak provisions, analyses documenting that
equipment is in heavy-liquid service and documentation verifying compliance
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with the equipment leak standard must be submitted with the Part B applica-
tion. This documentation includes the reports and records required under
the equipment leak provisions as well as other applicable RCRA information
requirements.
The permit writer'.s review of the Part B information specific to these
air rules is estimated to require from 8 to 16 labor hours per facility
application. Th'is includes the completeness check, technical evaluation,
and permit preparation.
8.3 COMPLIANCE '
Both the process vent provisions (i.e., determination of waste organic
content, emission rates, and control device efficiencies) and the equipment
leak provisions are "self-implementing"; i.e., it is clear from the language
of the standards what facilities are affected and what the; requirements are
for each affected facility. As a result, site-specific negotiations between
facility owner/operators and .RCRA permit writers are not necessary to imple-
ment the standards.
Therefore, interim-status facilities can comply with the rules without
awaiting permit action. The self-implementing nature of the rules is
achieved by including specific criteria for facility owners and operators to
identify waste management units that are subject to the regulations and by
clearly specifying the emission control and administrative requirement of
the rules.
The criteria for applicability are that certain hazardous waste manage-
ment units at new and existing TSOF that need authorization to operate under
RCRA Section 3005 are covered by the rules. The applicability includes all
hazardous waste management units and recycling units at facilities that
require RCRA permits. For the equipment leak standards to apply, the equip-
ment must contain or contact hazardous wastes with a 10-percent or more
total organics concentration. For the process vent standards to apply, the
vents must be associated with specific hazardous waste management units,
i.e., distillation, fractionation, thin-film evaporation, solvent extrac-
tion, and air on steam stripping operations, that manage wastes with 10 ppmw
or greater total organics concentration.
• Control requirements in the regulations include specific design
requirements for equipment and specific performance criteria (i.e., a
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weight-percent reduction and a volume concentration limit) for emission
control devices. Provisions of the standards also list specific types of
equipment required. Owners and operators who use one of the listed types of
equipment within the specified design and operational parameters would
therefore be in compliance with the regulation as long as the required
design, inspection, monitoring, and maintenance provisions were met. Speci-
fications for emission controls that achieve at least a 95-weight-percent
reduction in organic emissions are somewhat less specific, but engineering
design practices are-sufficiently established that..the combination of a good
control device design and subsequent monitoring of operating parameters, as
required by the final regulation, would offer reasonable assurance that the
specified emission reduction is being achieved.. Regardless of the type of
control selected, owners and operators must maintain their own records of
control device design, installation, and monitoring and must submit reports
identifying exceedances of monitored control device parameters. Periodic
review of the required reports and records by EPA may be used to ensure
compliance.
Consistent with Section 3010 of RCRA, the effective date of the process
vent and equipment leak rules is 6 months following promulgation. Owners
and operators of TSDF with existing waste management units subject to the
provisions of Subparts AA and BB must achieve compliance with the process,
vent and equipment leak control and monitoring requirements on the effective
date of .these rules (i.e., 6 months following promulgation) except where
compliance would require the installation of a closed-vent system and con-
trol device. Information developed under other EPA regulations has shown
that, in some cases, the design, construction, and installation of a closed-
vent system and control device can take as long as 24 months to complete.
As a result, EPA is allowing up to 24 months from the promulgation date of
the regulation for facilities to complete installation if they are required
to install a closed-vent system and control device and if they can document
that installation of the emission controls cannot reasonably be expected to
•
be completed earlier. In these circumstances, owners/operators are required
to develop an implementation schedule that indicates dates by which the
design and construction of the necessary emission controls will be complet-
ed. This implementation schedule must show that compliance with the final
standards would be achieved within a period of no more than 2 years from.
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promulgation and must be included as.part of the facility's operating record
on the effective date of these final rules. Changes in the implementation
schedule are allowed within the 24-month timeframe if the owner or operator
documents that the change cannot reasonably be avoided.
If installation of a control device is 'necessary for existing, regu-
lated units to comply with either Subpart AA or BB, up to 24 months may be
allowed from the promulgation date for the installation. This extension
would also apply to those" facilities that are brought under regulation
because new statutory or regulatory amendments under RCRA that render the
facility subject to the provisions of Subparts AA and BB (e.g., units
handling wastes newly listed or identified as hazardous by EPA). That is,
the owner or operator may be allowed up to'18 months fronu the effective
date of the statutory or regulatory amendment (24 months from the date the
new listing is published) to complete installation of a control device.
However, for facilities adding new waste management units,, EPA believes that
the lead time involved in such actions provides adequate time for owners and
operators to design, procure, and install the required controls. Therefore,
all new units must comply with the rules immediately (i.e., must have
control equipment installed and operating on startup of the unit).
The implementation/compliance schedule for the air emission standards
for process vents and equipment leaks at existing TSDF is as follows:
• 180 days following promulgation, the new Subpart AA and BB
standards become effective; all facilities become subject to
the new standards.
• On the effective date of the standards, compliance with the.
standards is required. Each facility that does not have the
control devices required by the standards in place must have
one of the following in the facility's operating record: (1)
an implementation schedule indicating when the controls will
be installed, or (2) a process vent emission rate determina-
tion that documents that the emission rate limit is not
exceeded (therefore, controls are not required).
• No later than 18 months following the effective date (2 years
following promulgation), any control devices required by the
standards for process vents and equipment leaks must be
installed at all facilities.
• All permits issued after the effective date must incorporate
the standards. • * •
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' Implementation/compliance of the air emission standards at newly
regulated facilities not previously requiring a RCRA permit (e.g., those who
have existing units handling newly listed or identified hazardous wastes) is
as follows:
* 180 days following the date the new statutory or regulatory
amendment is promulgated (e.g., the date a managed waste is
listed or identified as hazardous), the standards become
effective; facilities become subject to the Subpart AA and/or
BB standards. •
On the effective date of the standards, each facility that-
does not have the control devices required by the standards
in place must have one of the following in the facility's
operating record: (1) an implementation schedule indicating
when the controls will be installed, or (2) a process vent •
emission rate determination that documents that the emission
rate limit is not exceeded (therefore, controls are not
requi red).
• No later than 18 months following the effective date, the
controls required by the standards must be installed at all
facilities.
The requirements for facility compliance with the air emission stand-
ards for process vents and equipment leaks are summarized in Chapter 3.0 of
this document. Section 7.1 presents the inspection, monitoring, and testing
requirements. Section 7.2 presents the recordkeeping requirements. Report-
ing requirements are outlined in Section 7.3. Information on enforcement is
contained in Section 8.4.
To demonstrate compliance, facilities must document their waste
determinations, emission estimates, and control device efficiencies with
design/engineering analyses based on criteria contained in the rules (e.g.,
either engineering calculations or source tests can be used to document
compliance with the emission cutoff); facilities must maintain these
analyses and also monitoring, leak detection, and repair records in their
operating record. It is important to point out that the facility's process
vent emission rate determination must at all times reflert the facility's
current waste management unit designs and wastes managed. If the owner/
operator takes any action that would result in the determination no longer
being appropriate to the facility's operations, then a new waste and/or
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emission rate determination is required (Sections 264.1035 and 265.1035)
(e.g., if a waste of different composition is managed, the operating hours
of the affected management units are increased beyond what was originally
considered, or a new affected unit is added that may impact regulatory
status).
8.4 AGENCY ENFORCEMENT
The EPA's Regional RCRA Enforcement Officials and the Headquarters RCRA
Enforcement Division have the primary responsibility for enforcement of the
standards.
The Part B permit application information (Section 270.24) will
•establish the specific process .vents and equipment that are affected by the
rule, whether process vent controls'and/or an LDAR program are needed, and
will identify the control devices that have been selected to achieve compli-
ance as well as establish the compliance schedule. The Part B permit
application information for most facilities will be available to the RCRA
inspector for examination before the initial inspection and will include all
of the information required (with the exception of monthly LDAR records) to
determine initial compliance. LDAR monitoring and the recording of monitor-
ing results are required to be performed monthly. Through examination of
the Part B application and any exceedance reports submitted by the owner/
operator, the inspector should be able to prepare before the inspection
(e.g., examine analyses of the achievable emission reductions), thereby
minimizing the time required at the facility.
During the initial and subsequent followup inspections, enforcement
personnel should inspect the records that the facility is required to
maintain by these and other RCRA rules to determine compliance. The initial
inspection of the facilities affected by the requirements of the process
vent and equipment leak standards can begin immediately after the effective
date of these rules (i.e., 6 months after promulgation).
A checklist of items that should be inspected at the facility during
the initial and followup inspections is included in this technical guidance
document (Table 8-1). Followup inspections for this standard can be
performed concurrently with the annual inspection of the facility under .
other RCRA standards. Each initial and followup inspection, including
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writing a report, is estimated to range from about 11 labor hours for a
small commercial recycling facility up to about 38 labor hours for a large
TSDF with numerous management processes with equipment subject to the
standards.
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TABLE 8-1. CHECKLIST FOR INITIAL AND FOLLOWUP INSPECTIONS
A. Initial Inspection:
• Verify determination of processes and equipment at the facility
subject to and not subject to the standards. Assess how the
determinations are made.
Process Vent Requirements
• Verify that the waste stream determination of organics content is
documented for each distillation/separation process unit.
• Evaluate whether the emission rate limit is being met or will be
met.
* — Are the facility throughput estimates justifiable?
— ' Are emission estimates reasonable given chemical charac-
. teristics and throughputs?
Are source test results available?
Are the controls identified in the compliance plan applicable
and well designed?
• Verify that the compliance schedule, if needed, is in the
facility's operating log, and determine whether the compliance
schedule is being followed.
Equipment Leak Requirements
• Evaluate analyses of equipment in heavy-liquid service.
Is the hazardous waste management unit design capacity
reasonable? .
Are all hazardous waste feed and effluent streams identified?
Is the analysis of hazardous waste streams consistent with the
facility waste'manifest records?
• Check records of monthly leak detection monitoring.
• Verify that leaking equipment has been tagged.
• Review records of repair attempts, delay of repair, etc.
(continued)
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TABLE 8.-1 (continued)
• Verify the determination of valves that are .difficult or unsafe to
monitor.
• Review records for equipment covered by alternative requirements.
B. Followup Inspection: ..
• Follow-up to see that deficiencies identified in initial inspection
have been corrected.
Process Vent Requirements
• Verify that controls identified in the compliance plan have been
installed and are operating.
• Review the monitoring records to determine that controls are oper-
ating within design specifications.
' • Evaluate whether the emission rate limit is being met.
Are there any new process vents subject to the standards at
the facility?
Are the original facility wastes and throughput rates still
applicable?
Are source test results available?
Equipment Leak Requirements (same checklist as for initial inspection)
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9.0 TRAINING
9.1 INTRODUCTION -
The objectives of any training program for personnel responsible for
the implementation of the RCRA process vent and equipment leak organic air
emission standards, including RCRA permit writers/reviewers, RCRA enforce- .
ment personnel," general RCRA staff (new hires), and operators/owners of
TSDF, should be: ' v
• To make personnel aware of applicable process vent and equip-
ment leak emission sources they may encounter
• To provide the knowledge.and skills necessary to determine if
the owner/operator is complying with the process vent and
equipment leak organic air emission standards
• To make personnel aware of the capabilities and limitations
of the various emission control techniques.
RCRA permit writers/reviewers, RCRA enforcement personnel, general RCRA
staff (new hires), and operators/owners of TSDF must recognize and under-
stand the potential emission sources associated with the management of
organic containing waste at hazardous waste TSDF and the various emission
control techniques available. In particular, personnel actively involved
with and/or responsible for compliance should be thoroughly familiar with
the regulation and its requirements and the information contained in this
guidance document, as well as have a basic understanding of RCRA and its
objectives. .
The level of necessary and required training should be consistent with
a person's job function and responsibilities. The training program should
involve classroom instruction on topics involving process vent emissions,
fugitive emissions from equipment (e.g., pumps and valves), and control
techniques for these emission sources. Films, tapes, slides, etc., can also
be used. Some training classes provide onsite instruction and may include
9-1
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hands-on experience, which is also recommended. All involved persons should
complete refresher training, when possible, to reinforce their initial
training and to receive an update on any new information.
9.2 TRAINING PROGRAMS
Personnel should be adequately trained to a level commensurate with
their job function and responsibilities. Specific course recommendations
and areas to be covered in training sessions are included in Tables 9-1 and
9-2. A list of recommended literature is also prov.ided below:
Equipment Leak Fugitive Emissions
EPA
•November 1980.-
VOC Fugitive Emissions in Synthetic Organic Chemicals Manufactur-
ing Industry—Background Information for Proposed Standards.
EPA-450/3-.80-033A. PB-81-152167.
• • EPA:ESD/OAQPS
Noyember 1980.
Benzene Fugitive Emissions—Background Information for Proposed
Standards. Draft EIS. EPA-450/3-80-032a. PB-81-151664.
EPA
December 1980.
Organic. Chemical Manufacturing—Volume 3:
Sources. EPA-450/3-80-025. PB81-220527.
Storage, Fugitive, and
EPA:ESD
November 1982.
VOC Fugitive Emissions in Petroleum Refining Industry—Background
Information for Proposed Standards. EPA-450/3-81-015a.
PB-83-157743.
EPA/QAQPS/ESD
April 1982.
Fugitive Emissions Sources of Organic Compounds—Additional
Information on Emissions, Emission Reductions, and Costs.
EPA-450/3-82-010.- PB-82-217126.
EPA/QAQPS
March 1984.
Guideline Series—Control of Volatile Organic Compound Leaks for
Synthetic Organic Chemical and Polymer Manufacturing Equipment.
EPA-450/3-83-006. PB-84-189-372.
9-2
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Table 9-1. Recommended Training (EPA sponsored)
Course
No.
Course Title
Emphasis of Training
415
Control of Gaseous
Emissions
Students successfully completing this course will be able to evaluate systems typically
employed for controlling emissions of gaseous pollutants, including systems operation
and review of permit applications. Evaluation may be associated with inspection or for
judging whether a planned system will meet regulatory standards. A primary focus of
the course is on calculations that are needed to check system design. The course helps
students to develop an understanding of the process factors that guide selection of control
devices for various abatement requirements; it also helps students to develop an ability to
select and size a gaseous pollutant control device. A scientific calculator is required for
class exercises.
Course Sponsor: Air Pollution Training Institute
Desired Background: Engineering or Scientific degree •
Availability: All courses offered by the Air Pollution Training Institute are offered
on an annual basis. '
Contact: Betty Dodson (919) 541-2497
445 Baseline Source This advanced course in air pollution control equipment inspection and problem
Inspection diagnosis is designed for Agency inspectors and control system operating personnel. This
Techniques course presents discussions on the baseline techniques for equipment inspection and
evaluation. These techniques utilize site-specific information to facilitate the identification
of shifts in significant operating variables. The techniques presented in the course will be
useful in diagnosing complex control system operating problems that are often due to a
combination of factors. It will also be helpful in the early identification of problems, before
excess emissions or serious equipment damage occurs. Operating problems of a number
of control systems are reviewed to illustrate the baseline technique.
Course Sponsor Air Pollution Training Institute
Desired Background: Course 413 (Control of Paniculate Emissions), 415 (Control of
Gaseous Emissions), and 427 (Combustion Evaluation) or
equivalent field experience are required.
Availability: All courses offered by the Air Pollution Training Institute are offered
on an annual basis.
Contact: Betty Dodson (919) 541-2497
456 Fugitive VOC
Leak Detection
This course is intended for engineering and field monitoring personnel. It presents an
overview of the organic chemicals, fugitive emission points, monitoring equipment, quality
assurance procedures, and the design of inspections. Hands-on demonstrations of the
most commonly used monitoring equipment are included.
Course Sponsor Air Pollution Training Institute
Desired Background: Successful completion of courses 31:445 (Introduction to Baseline
Source Inspection Techniques) and/or APTI445 (Baseline Source
Inspection Techniques) and APTI 446 (Inspection Procedures and
Safety).
Availability: All courses offered by the Air Pollution Training Institute are offered
on an annual basis.
Contact: Betty Dodson (919) 541-2497
(continued)
9-3
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Table 9-1. (con.)
Court*
No,
Course Title
Emphasis of Training
482 Sources and Control
of Volatile Organic Air
Pollutants
S1:412D Problem VVbrkbook-
for Control of
' Gaseous and
Paniculate Emissions
Si:417 Controlling VOC
Emissions from
Leaking Process
Equipment
The student successfully completing this course will be able to evaluate systems typically
employed for the control of volatile organic emissions, including systems in operation and
as represented in VOC control plans. Evaluation of systems in operation identifies sub-
optimal features and is for the purpose of guiding regulatory action. Evaluation of planned
systems is for the purpose of determining whether a VOC control plan is likely to meet the
control objective it addresses. The course emphasizes calculations needed to cheek
system efficiency. Course content draws from EPA Control Technique Guidelines and
includes recent NSPS regulations.
Course Sponsor Air Pollution Training Institute
Desired Background: Course Sl:422 (Air Pollution Control Orientation Course;
3rd Edition) or have a minimum of six months of applicable
work experience.
teailability: All courses offered by the Air Pollution Training Institute are offered
on an annual basis.
Contact- Betty Dodson (919) 541-2497
This self-instructional course is designed for engineers and other technical personnel
responsible for making and reviewing calculations concerning air pollution control
equipment. The problems workbook contains three parts: a glossary of common terms
with explanations; a units operations section containing the basic principles of chemistry,
physics, and thermodynamics that are required in air pollution control equipment
calculations; and a problem section with solutions.
Cow/se Sponsor: Air Pollution Training Institute
Availability: No tuition fees are currently applicable to the Self-Study Courses (SI).
The materials for these courses are provided on a loan basis.
Contact: Betty Dodson (919) 541-2497
This course is designed for technical people involved in monitoring industries for VOC
emissions from leaking process equipment The course reviews in detail the sources of
fugitive VOC emissions and the procedures and equipment used to detect the leaks.
Course Sponsor Air Pollution Training Institute
Availability: No tuition fees are currently applicable to the Self-Sl:udy Courses (SI).
The materials for these courses are provided on a lean basis.
Contact: Betty Dodson (919) 541-2497
(continued)
9-4
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Table 9-1. (con.)
Course
No,
Course Title
Emphasis of Training
SI:428A Introduction to
Boiler Operation
Sl:431
Air Pollution Control
Systems for Selected
Industries
Designed for engineers and other technical persons responsible for inspecting boilers,
this course presents an introduction to the operation of boilers. This will be the first in a
series of four (or five) courses on inspecting and/or operating different types of boilers-
small package boilers, commercial boilers, industrial boilers, and utility boilers.
Course Sponsor Air Pollution Training institute
Availability: No tuition fees are currently applicable to the Self-Study Courses (SI).
The materials for these courses are provided on a loan basis.
Contact: Betty Dodson (919) 541-2497
This course is an introduction to the fundamental operating characteristics of participate
and gaseous pollutant emission control systems. It reviews physical, chemical, and
engineering principles of control devices and the application of control systems to several
types of industrial processes.
Course Sponsor: Air Pollution Training Institute
Availability: No tuition fees are currently applicable to the Self-Study Courses (SI).
The materials for these courses are provided on a loan basis.
Contact: Betty Dodson (919) 541-2497
Sl:445 Introduction to This course was designed for the air pollution field inspector and industrial air pollution
control equipment operators. It covers the basics of the baseline inspection technique for
air pollution control equipment. This technique is based on the use of site-specific data to
evaluate shifts in operating conditions. Most major types of air pollution control devices
and auxiliary systems are covered. Inspection procedures, data collection, data recording,
and interpretation are explained. Review problems and questions are presented.
Course Sponsor Air Pollution Training Institute
Availability: No tuition fees are currently applicable to the Self-Study Courses (SI).
The materials for these courses are provided on a loan basis.
Contact Betty Dodson (919) 541-2497
Core Training The Core Training Program is designed for entry-level State inspectors at RCRA sites. The
Program program is composed of three courses: RCRA orientation, inspector training, and permit
writers training.
Course Sponsor: EPA/ASTSWMO
Availability: The inspector course and the permit writers course are available on an
annual basis. The orientation course is currently under development.
Contact: Mary Anthony (202) 624-5828
Introduction to
Baseline Source.
Inspection
Techniques
Workshop on
Hazardous and Toxic
Air Pollutant Control
Technologies and
Permitting Issues
Information presented in this workshop should be of interest to Federal, State, and local
officials, industry personnel, and consultants involved in the hazardous and toxic air
pollution field. The purpose of this workshop series is to transfer technical information on
hazardous and toxic air pollutant control technologies and permitting issues. Topics
discussed include: combustion-related technologies; carbon adsorption; absorption;
fugitive equipment leaks; and paniculate control technologies.
Course Sponsor: STAPPA/ALAPCO
Availability: The availability of this workshop depends on the availability of funds from its
sponsor to support its existence
Contact: Kirt Cox (919) 541-5399
SI » Self-Instructional
' 9-5
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Table 9-2. Recommended Training (Non-EPA sponsored)
Cours* Till*
Emphasis of Training
VOC Inspection . The YPC Inspection Techniques workshop provides inspectors with background information on
Techniques various VOC-emitting industries, technical control strategies, and inspection techniques. A three-
hour site visit, included in the workshop, demonstrates some of the inspection techniques.
. Demonstrations of several VOC detection instruments provide hands-on opportunity for the
inspectors. Short lectures on control device inspection techniques and operating principles for
carbon adsorbers and incinerators'are presented. VOC source categories include solvent metal
cleaning, drycleaning, surface coating, gasoline marketing, petroleum refining, pharmaceutical
manufacturing, synthetic organic chemical manufacturing, pneumatic rooter tire making, the use
of cutback asphalt, graphic arts, etc.
Course Sponsor PEI
Availability: This workshop is available when requested by a significant number of persons. •
Contact: Dave Dunbar (919) 688-6338
RCRA Facility
Compliance Training'
Permit Review
Fwkl Training
This three-day workshop summarizes RCRA interim-status standards, inspection protocols, and
safety procedures. The workshop describes hazardous waste treatment, storage, and disposal
facilities and requirements for the design of a management program for such facilities. Inspection
protocols are discussed that are compatible with EPS's RCRA inspection manual.
Course Sponsor: PEI
ftmSabiSty, This workshop is available when requested by a significant number of persons.
Contact- Dave Dunbar (919) 688-6338
This three-day workshop is designed for Agency engineers and personnel who are responsible for
permit review. The workshop covers administrative and technical consideralfons in depth. It
discusses manpower requirements for various levels of review; optimum utilization of Agency
personnel; permit processing mechanics; fabric filters; scrubbers; mechanical collectors; operating
features and design criteria for control equipment; operating and maintenance considerations;
modeling of control equipment performance; corrosion prevention; compliance testing provisions-
siting requirements; and information retrieval systems.
Course Sponsor: PEI
AmilabiUty: This workshop is available when requested by a significant number of persons.
Contact: Dave Dunbar (919) 688-6338
As a folJowup to classroom instruction, many agencies have requested personalized instruction in
the use of the inspection equipment and analysis methods in actual field applications.- In coopera-
tion with the host agency, the course sponsor selects representative industrial sources and nego-
tiates with those sources to conduct inspections that demonstrate various inspection techniques.
Course Sponsor PEI
Availability: This workshop is available when requested by a significant number of persons.
Contact: Dave Dunbar (919) 688-6338
9-6
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Table 9-2. (con.)
Course Title
Industrial Control
Equipment for
Gaseous Pollutants
Emphasis of Training
Air Pollution In this course, air pollution causes, transport, effects, and monitoring are reviewed as well as
Control principles and terminology of air pollution control engineering. A major emphasis is on methods for
prevention, control, and solution of atmospheric environmental problems. Process design and selec-
tion of both paniculate and gaseous collection equipment are emphasized. Methods of avoiding
common operating problems are discussed. A background knowledge of general chemical and
petrochemical processes is assumed, but a high degree of mathematical sophistication is not
required. .
Course Sponsor AlChE
Availability: This course is offered on an annual basis.
., Contact: AlChE Continuing Education Registrar (212) 705*7526
This course reviews the design criteria for control equipment and presents the underlying principles
and mechanisms involved. The course content includes: activated carbon and molecular sieve
adsorption columns; condensers; and thermal and catalytic incinerators.
Course Sponsor APCA
Availability: This course is offered on an annual basis.
Contact Dan Russsl (412) 232-3444
9-7
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Process Vent Emissions
EPA
December 1980.
Organic Chemical Manufacturing—Volume 4.: Combustion Control
Devices. EPA-450-3-80-026. PB-81-220535.
EPA
December 1980.
Organic Chemical Manufacturing—Volume" 5: Adsorption, Condensa-
tion, and Absorption Devices. EPA-450/3-80-027. PB-81-220543.
EPA .
December 1983.
Distillation Operations in Synthetic Organic Chemical Manufac-
turing—Background Information for Proposed Standards.
EPA-450/3-83-005a. PB-84-214006.
EPA/QAQPS/ESD ' •
June 6, 1988o
Carbon Adsorption for Control of VOC Emissions: Theory and Full
Scale System Performance. EPA 450/3-88-012.
APCA Publications
December 1981.
Control of Gaseous Emissions.
(412) 232-3444.
EPA-450/2-81-005
'Haste Stream Test Methods
Note:
EPA/OSW
Second Edition,
Revised December 1987.
Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846. PB87-120-291.
These documents are available through the EPA library and
through the National Technical Information Service (NTIS).
Literature having a EPA number (e.g., EPA-450/3-80-033A) is
available at the following address and phone number:
Environmental Protection Agency
Library Services Office
MD-35
Research Triangle Park, NC 27711
(919) 541-2777
Literature having a PB number can be obtained through NTIS at
the following address and phone number:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
9-8
-------
Control of Gaseous Emissions can be obtained through APCA
Publications at the following address and phone number: .
APCA Publications
P.O. Box 2861
Pittsburgh, PA 15230
(412) 232-3444
ASTM methods are available from the Annual Book of ASTM
Standards at the following address and phone number:
American Society for Testing and Materials
1916 Race St. .
Philadelphia, PA 19103
(215) 299-5400
EPA Reference Method 21, "Determination of Volatile Organic .
Compound Leaks," contained in Appendix A of 40 CFR 60 (Stock
No. 869r004-00137-l), is available from the following office:
U.S. Government Printing Office
Washington, DC 20402-9325
(202) 783-3238
9-9
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APPENDIX A
FEDERAL REGISTER NOTICE
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25454
Federal Register / VoL 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
46 CFR Parts 260,261.264,265,270.
and 271
[FHL-3814-31
Hazardous Wast* Treatment, Storage,
and Disposal Facilities-Organic Air
Emission Standards for Process Vents
and Equipment Leaks
AOSNCY: Environmental Protection
Agancy (EPA).
ACTIOHS Final rule.
SUMMARY: The-EPA is today
promulgating standards that limit
organic air emissions as a class at
hazardous waste treatment storage, and
disposal facilities fTSDF] requiring a
permit under subtitle C of the Resource •
Conservation and Recovery'Act
(RCRAL.Today's action is the first part
of a multiphased regulatory effort to
control air emissions at new and
•existing hazardous waste TSDF. The
rule establishes final standards limiting
organic emissions from (1) process vents
associated with distillation.
fractionation. thin-film evaporation.
solvent extraction, and air or steam
stripping operations that manage
hazardous wastes with 10 parts per
million by weight (ppmw) or greater
total organic! concentration, and (2)
leaks from equipment that contains or
contacts hazardous waste streams with
10 percent by weight or greater total
organic*. These standards were
proposed in the Federal Register on
February 5.1967 (52 FR 3748).
The final standards are promulgated
under the authority of section 3004 of the
Hazardous and Solid Waste
Amendments (HSWAJ to the RCRA. The
EPA is required by section 3004(n) of
RCRA to promulgate standards for the
monitoring and control of air emissions
from hazardous waste TSDF as
necessary to protect human health and
the environment The EPA plans to
promulgate additional standards under
this section in two further phases. Phase
n will consist of air standards for
organic emissions from surface
impoundments, tanks, containers, and
miscellaneous units. These standards
are scheduled for proposal later this
year. In Phase in. the residual risk from
the first two phases will be assessed
and. if necessary, EPA will develop
further regulations or guidance to
protect human health and the
environment from the effects of TSDF
air emissions.
EFFECTIVE BATE This final rule is
effective on December 21,1990. The
incorporation by reference of certain
publications listed in the regulations to
approved by the Director of the Federal
Register as of September 5 and October
11,1988.
Aoemsscs: The official record for this
final rulemaking is contained in Docket
No. F-90-AESF-FFFFF. This docket and
the proposal docket (Docket No. F-88-
AESP-FFFFF) an available for public
inspection at the EPA RCRA Docket
Office (OS-300) in room 2427M of the
U»S Environmental Protection Agency.
401M Street SW.. Washington. DC
20460. Additional information
concerning the development of the
equipment leak standards is contained
in Docket No. A-79-27. which ie
available for public inspection at EPA's
Central Docket Section, room 2903E
Waterside Mall. 401M Street SW,
Washington. DC 20460. For further
information, see the discussion of
supporting documentation for the rules
under section X of this preamble.
Background information document:
The background information document
(BID) for the final standards may be
obtained from the U.S. EPA Library
(MD-35). Research Triangle Park. North
Carolina 27711, telephone (919) 541-
2777. Please refer to "Hazardous Waste
Treatment Storage, and Disposal
Facilities (TSDF)—Background
Information for Promulgated Organic
Emission Standards for Process Vents
and Equipment Leaks" (EPA-450/3-89-
OOB). The EPA has prepared a technical
guidance document to aid in
implementation of these rules. This
document may also be obtained from.
the US. EPA Library (see above
address). Please refer to "Hazardous
Waste TSDF—Technical Guidance
Document for RCRA Air Emission
Standards for Process Vents and
Equipment Leaks" (EPA-4SO/3-89-21J.
ran FURTHER INFORMATION CONTACT:
The RCRA Hotline, toll-free at (800) 424-
9346. For further information on
regulatory aspects of these standards.
contact Rick Colyer, Standards
Development Branch. Emission
Standards Division (MD-13). US.
Environmental Protection Agency.
Research Triangle Park. North Carolina
27711. telephone number (919) 541-5282.
For further information on the technical
aspects of these standards, contact
Robert Lucas, Chemicals and Petroleum
Branch, telephone number (919) 541-
0884. at the same address. For further
information on test methods associated
with these standards, contact Terry
Harrison. Emission Measurement
Branch, telephone number (919) 541-
5233. at the same address as above.
SUPPLEMENTARY INFORMATION! The
contents of today's preamble are listed
in the following outline:
L Authority
D, Summary of Final Standards
A. Vents on Hazardous Waste
Management Process Units
B. Equipment Leaks on Hazardous Watte
Management Process Units
EL Background
A. Regulatory Authority
E Regulatory Scope of Today's Standard*
C Air Standards under RCRA Section
3004{n)
D. Other RCRA Air Standards
E, Relationship of Air Standards to Other
Subtitle C Rules
P. Relationship of Today's Final Standards
to the Comprehensive Environmental
Response. Compensation, and Liability
Act(CERCLA)
IV. Applicability and Requirements of
Proposed Process Vent and Equipment
Leak Standards
V. Applicability and Requirements of Today's
Final Standards
A. Scops of Final Standards
B, Standards for Process Vents
C Equipment Leak Standards
D. Summary of Changes from Proposal
E. Relationship of RCRA Exemptions to
Final Standards ,
VL Summary of Comments and Responses
A. Regulatory Issues
B. Standards and Applicability
C Control Technology
a Impact Analyse* Methodologies
E. Implementation and Compliance
Vtt. Summary of Impacts of Final Standards
A. Overview of the Source Category
' B. Uw of Models in the Regulatory
Development Process
C Emission Impacts
D. Ozone Impacts •
E. Health Risk Impacts
F. Cost Impacts
Vnt State Authorization
A. Applicability of Rules in Authorized
States
B. Effect on State Authorizations
DC. Implementation •
X, Administrative Requirements
A. Regulatory Impact Analysts
B. Regulatory Flexibility Act
C Paperwork Reduction Act
O. Supporting Documentation
E, List of Subjects
L Authority
These regulations are promulgated
under the authority of sections 1006.
2002.3001-3007,3010. 3014. and 7004 of
the Solid Waste Disposal Act of 1970. as
amended by RCRA. as amended (42
U.S.C. 8905. 8912,8921-6927, 6930. 6934.
and 6974).
H. Summary of Final Standards
The standards limit emissions of
organic* from certain process vents and
equipment leaks at new and existing
hazardous waste'TSDF requiring a
permit under RCRA subtitle C (i.e..
-------
Federal Register / Vol. 55. No. 120 / Thursday. June 21, 1990 / Rules and Regulations 25455
permitted TSDF and TSDF that need
authorization to operate under RCRA
section 3005{o)). This applicability
include* all hazardous waste
management units that require RCRA
oermits and recycling units that are not
subject to RCRA permit requirements, if.
Independent of today's final rules, a
RCRA permit is needed for another part
of the facility operation*.
A. Vents on Hazardous Waste
Management Process Units
Today's final standards are applicable
to vents on wast* management units
that manage hazardous waste with an
_ annual average total organics
* concentration of 10 ppmw or greater
(hereafter referred to as "process
vents") and specifically include (1)
process vents on distillation.
fractionatioo. thin-film evaporation.
solvent extraction, and air or steam
stripping operations and vents on
condensers serving these operations:
and (2) process vents on tanks (e.g_
distillate receivers, bottoms receivers.
surge control links, separator tanks, and
hot wells) associated with distillation.
fractionation. thin-film evaporation.
solvent extraction, and air or steam
stripping processes if emissions from
these process operations are vented
through the tanks. Up-to-date
information and data used to determine
whether or not a hazardous waste
management unit and Us associated
process vent(s) are subject to the
subpart AA standards must be
maintained in the facility operating
record (i 264.1035(0 and 126S.103S(f)).
For example, documentation of a waste
analysis showing that the waste
managed in the unit is less than the 10-
ppmw applicability criterion must be
kept in the facility operating record.
The final rules for process vents
require that owners or operators of
TSDF subject to the provisions of new
subpart AA: (1) Reduce total organic
omissions from all affected process
vents at the facility to below 1.4 kg/h (3
Ib/h) and £S Mg/yr (3.1 ton/yr). or (2)
Install and operate a control device(s)
that reduces total organic emissions
from all affected process vents at the
facility by 95 weight percent. The owner
or operator of the facility must
determine through test data or
engineering judgment and calculations
that the facility is not expected to
exceed the emission rate limit of 1.4 kg/
h and 23 Mg/yr. Facilities with organic
emissions from affected vents that never
exceed the emission rate limit will not
be required to install controls or monitor
• process vent emissions under this rule.
For all other affected facilities, the
owner or operator must install controls
to reduce total facility process vent
emissions from all affected vents below
the emission rate limit or to reduce total
facility process vent organic emissions
after primary recovery by 95 percent; if
enclosed combustion devices are used.
the owner/operator has the option of
reducing the organic concentration of
each affected vent stream at the facility
to no more than 20 parts per million bv
volume (ppmv). Selection of the
emission rate limit is addressed further
hi section- VLB below and in chapters 4.0
and 7a of the BID.
The final standards for process Vents.
do not require the use of any specific
types of equipment or add-on control
devices. Condensers, carbon adsorbers.
incinerators, and flares are
demonstrated emission control
equipment for the regulated processes.
although the choice of control is not
limited -to these.
To demonstrate compliance with the
process vent provisions, TSDF owners/
operators must document process vent
emissions and emission reductions
achieved by add-on control devices and
certify the emission reduction capability
of the control equipment
Documentation must (1) identify
affected process vents, provide the
throughput and operating hours of each
affected unit and provide emission rate
determinations for each affected vent
and for the overall facility (i.e.. the total
emissions for all affected vents at the
facility]: and (2) show whether installed
add-on control devices achieve the
emission rate limit by design and during
operation. Where the emission rate limit
is not attained, documentation must
show whether the add-on control
devices achieve a 95-percent reduction
in organic*, or the 20-ppmv organics
concentration limit by design and during
operation. The documentation must
include the basis for determining the
design emission reduction.
The rules for process vents require
. that specific control device operating
parameters be monitored continuously
and the monitoring information be
recorded in the facility operating record
to ensure that the devices perform
according to their design and are
properly operated and maintained. For
facilities with final RCRA permits.
periods when monitoring indicates that
control device operating parameters
exceed established tolerances for design
specifications must be reported
scmiannually. The records and reports
must include dates, duration, cause, and
corrective measures taken. There are no
reporting requirements for interim status
facilities. These monitoring and
recordkeeping requirements are
discussed below in section V.B and in
the BIO in chapter 11.0, section 11.4.
B. Equipment Leaks on Hazardous
Waste Management Process Units
The equipment leak standards apply
to emissions from valves, pumps.
compressors, pressure relief devices,
sampling connection systems, and open-
. ended valves or lines. Under the final
standards, controls for these sources are
required; at TSDF where the equipment
contain!! or contacts hazardous waste
streams with organic concentrations of
10 percent by weight or greater. The
owner or operator of a facility may
choose any of the applicable test
methods, identified in the final rules for
determining the organic content.
To comply with the equipment leak
standards, the facility owner/operator
must identify all affected equipment
(i.e_ pumps, valves, compressors, etc.,
that contain or contact hazardous waste
streams with at least 10-parcent-by-
weigbt organics). establish which of the
affected equipment is in heavy liquid
service, and determine which valves are
unsafe or difficult to monitor. By the
effective date of this regulation, the
facility owner/operator must conduct
the initial monthly monitoring survey of
pumps and valves in gas/vapor OF light
liquid service. A number of portable
volatile organic monitoring devices are
capable of detecting equipment leaks..
Any analyzer can be used, provided it'
meets the specifications and
performance criteria set forth in EPA
Reference Method 21 (contained in
appends* A of 40 CFR part 60).
Affect ad compressors must hava a
dual mechanical seal system that
includes a barrier fluid system or must
be designated as having "no detectable
emissions," which means an instrument
reading of less than 500 ppm above
background using EPA Reference
Method XI. Sampling connections must
have a closed-purge system. Open-
ended vsiives or lines must have a cap.
blind flange, plug, or second valve.
Pressure relief devices must operate
with "no detectable emissions."
Recordkeeping and monitoring are
also required by the equipment leak
provisions. For example, leaking
equipment as determined by Method 21
must be tagged as specified in the rule.
and records of repair attempts, delay of
repair, etc., must be recorded in a log
and included as part of the facility's
operating; record. Monitoring of control
device operating parameters is also '
required if a closed-vent system and
control device are installed as a result of
the equipment leak standards. The
standards and recordkeeping
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
requirement* are discussed below at
section V.C.
IIL Background
A. RegulatoryAuthority
In 1964. Congress passed HSWA.
amending RCRA. Section 3004(n) of
RCRA, as amended by HSWA. directs
EPAto"* * * promulgate such
regulations for the monitoring and
control of air emissions at hazardous
waste treatment storage, and disposal
facilities, including but not limited to
open tanks, surface impoundments, and
landfills, as may be necessary to protect
human health and the environment."
The standards being promulgated today
address, in part, this congressional
directive and are applicable to all TSDF
that require authorization to operate
under section 3005 of RCRA. These
regulations are being promulgated under
the authority of sections 1006,2002.
3001-3007.3010.3014. and 7004 of the
Solid Waste Disposal Act of 1970, as
amended by RCRA. as amended (42
U.S.C. 6905,6912.6921-6927. 6930.8934.
and6974).
• B. Regulatory Scope of Today's
Standard*
• Today's final rules apply to facilities
that treat store, or dispose of hazardous
wastes as defined in 40 CFR 261.3 and.
specifically, to certain hazardous waste
management units at facilities requiring
RCRA subtitle C permits. This includes
facilities with permit* and those
operating under interim status. Today's
rules, codified in new subparts AA and
BB of 40 CFR parts 264 and 265. are
applicable to the following units at
TSDF: (1) Hazardous waste management
units subject to the permitting
requirements of part 270 (i.e.. not 90-day
accumulation tanks at TSDF). and (2}
hazardous waste recycling units located'
on hazardous waste management
facilities otherwise subject to the
permitting requirements of part 270.
Under 40 CFR 280.10. the term "facility"
means ail contiguous Sand, and
, structures, other appurtenances, and
improvement! on the land, used for
treating, storing, or disposing of
hazardous waste, (Note: This definition
differs from the definition of "facility"
for purposes of corrective action under
RCRA section 3004fu). See 50 FR 28712.
July 15,1985.)
C. Air Standards Under RCRA Section
3OH(nl
Air emissions from hazardous wastes
• are generated or released from
numerous sources at TSDF, including
distillation and other organic separation
units, surface impoundments, tanks.
containers, landfills, land treatment.
facilities, wastepiles. and leaks from
equipment associated with these
operations.
In considering the regulation of air
emissions under RCRA section 3004(n)
and within the RCRA regulatory
framework, EPA has concluded that air
emission* from hazardous waste
management facilities that are subject to
RCRA subtitle C should be regulated
under the authority of RCRA section
3004(n). Air emissions from facilities or
units that manage solid wastes that are
not regulated as hazardous wastes
pursuant to 40 CFR part 261 (e.g.. cement
kiln dust waste) and air emissions from
hazardous waste from units or facilities
that are exempt from the permitting
provisions of 40 CFR 270.1(c)(2) (e.g.,
wastewaier treatment units with
National Pollutant Discharge
Elimination System (NPDES) permits)
will be subject to control techniques
guidelines or standards developed as
needed under either the Clean Ate Act
(CAA) or RCRA authority. Air emissions
from wastes managed in units subject to
subtitle D (nonhazardous solid wastes
such as those managed in municipal
landfills) also will be subject to
guidelines or standards issued under
CAA or RCRA authority as appropriate.
Air emissions from hazardous wastes
include pfaotochemically reactive and
nonphotochemically reactive organics,
some of which are toxic or carcinogenic.
and also may include toxic or
carcinogenic inorganic compounds.
Depending on the source, particuiates
(including metals, aerosols of organics.
dust a* well as toxics and carcinogens)
also may be released or generated.
These emissions, which are released to
the atmosphere from a wide variety of
sources within TSDF. present diverse
health and environmental risks.
Therefore. EPA has developed a
multiphased approach for regulating
TSDF organic air emissions. This
approach, described generally below.
reflect* EPA's understanding of the
problem and knowledge of applicable.
effective controls at this time
Organic emissions from TSDF
managing hazardous wastes contribute
to ambient ozone formation and
increase cancer and other health risks.
' Phases I and II of EPA's TSDF
regulatory approach will significantly
reduce emissions of ozone precursors
and air toxics and carcinogens from
TSDF by controlling emissions of
organics a* a class rather than
controlling emissions of individual
waste constituents. The regulation of
organics a* a class ha* the advantage of
. being relatively straightforward because
it can be accomplished with a minimum
number of standards, whereas the
control of individual toxic constituents
will require multiple standards.
Regulating organics as a class also
makes efficient use of EPA resource.
avoids many of the complexities of
having multiple standards, and reduce-
the number of constituents for which
separate standards may be required.
The health and environmental effects
of ambient ozone are well documented-
measured in terms of monetary losses.
they total hundreds of millions of dollars
each year. Other health impacts of TSDF
organic emissions are summarized in
section VTLD of this preamble and are
discussed in more detail in the BID that .
accompanies this final rule and in the
draft BID for Phase Q organic standards
titled. "Hazardous Waste TSDF—
Background Information, for Proposed
RCRA Air Emission Standards."
available in Docket F-90-CESP-FFFFF.
The substantial .reductions in organic
emissions achievable through
implementation of Phase I and Phase II
controls will reduce atmospheric ozone
formation as a result of reductions in
TSDF emissions of ozone precursors and
will reduce nationwide cancer incidence
and maximum individual risk due to
exposure to air toxics and carcinogens
emitted from TSDF.
Specifically, Phase I (which is being
promulgated as final rules today) entails
the promulgation of standards for the
control of organic air emissions from
selected hazardous waste management
processes and equipment leaks. As
discussed in the February 1987 proposal.
EPA chose to develop this portion of its
TSDF rulemaking first to prevent
uncontrolled air emissions from land
disposal restriction (LDR) treatment
technologies. The technologies used in
lieu of land disposal include the
distillation/ separation processes
subject to the Phase I rules. Publication
of today's final rules for air emissions
from hazardous waste management unit
process vents from distillation.
fractionation. thin-film evaporation.
solvent extraction, and air or steam
stripping processes and from leaks in
piping and associated equipment
handling hazardous wastes marks the
completion of this first phase.
In the second phase. EPA will propose
(in 1990) additional standards under
section 3004(n) to control organic air
emissions from other significant TSDF
air emission sources not covered-or not
adequately controlled by existing
standards. These sources include
surface impoundments, tanks (including
vents .on closed, vented tanks).
containers, and miscellaneous units.
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 25457
The analyse* of impacts indicate that
at some facilities, residual cancer risk to
the roost exposed individuals after
implementing the first two phases of
regulation will remain outside tha risk
range for other regulations promulgated
under RCRA (which historically has
been in the range of lxi
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rulea and Regulation
25458
nonwastewater spent solvents include
distillation and other separation
processes subject to the requirements of
the Phase I rules. Today's standards are
designed to protect human health and
the environment by reducing air
emissions from technologies expected to
be used to treat wastes prior to land
disposal
Under the authority of RCRA section
3004(u). EPA is developing rules to
address releases of hazardous waste or
hazardous constituents from solid waste
management units (SWMU) that pose a
threat to human health and the
environment Because this authority
applies to contamination of soil water.
and air media, organic air emissions
from SWMU at some TSDF would be .
addressed by the corrective action
program EPA intends to propose under a
' separate rulemaking. The draft rules
would establish health-based trigger
levels measured at the TSDF boundary
for determining whether further
remedial studies are required to assess
air emissions from a particular SWMU.
Health-based cleanup standards would
then be set .for air emission levels that
exceed acceptable health-based levels
at the point at which actual exposure
occurs. When such exposure is
determined either through monitoring or
modeling techniques, corrective action
will be required to reduce such
emissions at the point of compliance.
The corrective action program is
designed to achieve site-specific
solutions based on an examination of a
particular TSDF and its environmental
setting. It is not intended to set national
standards that regulate organic air
emissions from all TSDF. At sites where
there are releases from SWMU to the
atmosphere, organic emissions will be
controlled based on site-specific
'exposure concerns. Furthermore.
releases from the SWMU that contain
hazardous solid wastes will also be
subject to corrective action. Therefore.
for air emissions, corrective action is in
part designed to expeditiously address
threats to human health and the
environment that are identified prior to
implementation of more comprehensive
air emission standards. In addition.
• because corrective action can address a
wider universe of SWMU. it will
address, in some respects, exposure
concerns that today's final standards do
not address.
F. Relationship of Today's Final
Standards to CERCLA
The CERCLA. as amended by the
Superfund Amendments and
Reauthorization Act (SARA). 42 U.S.C
9801 et seq.. authorizes EPA to
undertake removal and remedial actions
to clean up releases of hazardous.
substances, pollutants, or contaminants.
Removal actions typically are
immediate or expedited activities
necessary to minimize exposure or
danger to human health and the
environment from the release of a
hazardous substance, pollutant, or
contaminant Remedial actions are
longer term, planned activities
performed at sites listed on the National
Priorities List to permanently clean up
hazardous substances, pollutants, or
contaminants and any soils, surface
waters, or ground waters contaminated
by these materials. On-site remedial
actions arerequired by CERCLA section
121(d)(2) to comply with the
requirements of Federal and more
stringent State public health and
environmental laws that have been
identified by EPA or the delegated State
authority as applicable or relevant and
appropriate requirements (ARAR) to the
specific CERCLA site. In addition, the
National Contingency Plan (NCP)
provides that on-site CERCLA removal
actions "should comply with Federal
ARAR to the extent practicable
considering the exigencies of the
circumstances" (40 CFR 300.65(f))-
Today's final standards may be
considered ARAR for certain on-site
remedial and removal actions.
A requirement under a Federal or
State environmental law may either be
"applicable" or "relevant and
appropriate." but not both, to a remedial
or removal action conducted at a
CERCLA site. "Applicable
requirements." as defined in the
proposed revisions to the NCP. means
those cleanup standards, standards of
control, and other substantive
environmental protection requirements.
criteria, or limitations promulgated
under Federal or State law that
specifically address a hazardous
substance, pollutant contaminant
remedial action, location, or other
circumstance found at a CERCLA site
(40 CFR 3003 (proposed). 53 FR S1475
(December 21.1988)). "Relevant and
appropriate requirements" means those
Federal or State requirements that
while not applicable, address problems
or situations sufficiently similar to those
encountered at the CERCLA site that
their use is well suited to the particular
site (S3 FR 51478).
Some waste management activities
used for remedial and removal actions
to clean up hazardous organic
substances use the distillation/
separation operations regulated under
subpart AA of today's rules. For
example, hazardous organic liquid
wastes and ground and surface waters
contaminated with hazardous wastes
may be treated on site using air
stripping processes. Therefore, the
organic emission control requirements of
today's subpart AA rules may be
"applicable" for on-site remedial and
removal action activities that use
distillation, fractionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operations that treat
substances that are identified or listed
under RCRA as hazardous wastes and
have a total organic concentration of 10
ppmw or greater. In addition, off-site
storage, treatment and disposal of all
wastes classified under RCRA as
hazardous waste must be performed at a
TSDF permitted under RCRA subtitle C.
Thus, CERCLA wastes that are defined
as hazardous under RCRA, contain more
than 10 ppmw of total organics, and are
shipped off site for management in
• distillation, fractionation, thin-film
evaporation, solvent extraction, and air
or steam stripping operations, would be
subject to today's final standards like
any similar RCRA hazardous waste. The
new subpart AA control requirements1
for process vents may also be "relevant
and appropriate" to on-site CERCLA
removal and remedial actions that use
distillation, fractionation. thin-film
evaporation, solvent extraction, and air
or steam stripping operations to manage
substances that contain organics that
are not covered by this rule (e.g.,
organics less than 10 ppmw or organics
from nonhazardous wastes).
Today's'final rules do not include
control requirements for process vents
on operations not associated with
organics distillation/separation but
typically associated with CERCLA
remedial or removal actions such as soil
excavation, in situ soil vapor extraction.
in situ steam stripping of soil soil
washing, stabilization, bioremediation
(in situ or otherwise), dechlorination.
and low temperature thermal
desorption. Therefore, the final rule for
process vents would not be "applicable"
to remedial or removal actions involving
these processes at CERCLA sites. Also.
the final process vent standards may not
be considered "relevant and
appropriate" for these same activities at
CERCLA sites. Waste management
operations involving soil excavation, in
situ soil vapor extraction, in situ steam
stripping of soil, soil washing.
bioremediation. dechlorination. and low
temperature thermal desorption can be
considerably different from the waste
management operations (i.e..
distillation/separation processes)
regulated in subpart AA. Control
technologies for reducing organic
emissions from these types of processes
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Federal Register / VoL 55. No. 120 / Thursday. June 21, 1990 / Rules and Regulations 254S8
went not evaluated a* port of today's
rukmaking. However, the air emission
potential of remedial and removal
actions requiring excavation, land
treatment, land farming, in situ
treatment activities, and other treatment
activities involving landfills and
WMtepUes should be determined, and. if
necessary, th« proper emission controls
should be applied to these activities.
The organic emission control
requirements of subpart BB for TSDF
equipment leaks may also be considered
a* an ARAR for the equipment
components (e.g^ pumps and valves)
uutalled at CERCLA cleanup sites that.
contain or contact substances
containing 10 percent by weight or more
total organic*.
Although today's final standards
would not be ARAR for an types of
remedial and removal actions that are
potential sources of organic air ,
emissions, other existing RCRA or CAA
•regulations may qualify as ARAR for
many of the** activities. For example,
subpart O of 40 CFR part 284 establishes
standards of performance limiting
organic emissions from thermal
destruction processes (Le, hazardous
waste Incinerators).
IV. Applicability and Requirements of
Proposed Proem Vent and Equipment
LMkStaadatds
On February 5.1987 (52 FR 3748). EPA
proposed standards under RCRA section
3004(n) for the control of organic air
emissions from certain equipment and
process vents at hazardous waste TSDF.
The proposed standards would have
applied to equipment and process vents
"!a volatile hazardous air pollutant
fVHAP) service" (U, containing or
contacting liquids, gases, or other
derivatives of hazardous waste in
concentrations greater than 10 percent
total organics) located at TSDF required
to have a RCRA permit The decision as
to whether equipment or process vents
would be covered by the rule (Lew would
ever contain or contact wastes greater
than 10 percent total organics) could be
based either on testing the waste and
derivatives according to specified test
procedures or on engineering judgment
as to these materials, total organic
content
The proposed standards would have
required a 85-percent reduction in
organic emissions from vents hi VHAP
service oa product accumulator vessels
and on other process vent sources (e.g«
vents OB dosed accumulator tanks on
other processes). The preamble for the
proposed standard, at 52 FR 3753,
described "product accumulator
vessels" as types of equipment that
generate process emissions and include
distillate receivers, surge control
vessels, product separators, or hot-wells
that are vented to the atmosphere either
directly or through a vacuum-producing
system. Product accumulator vessels
included units used to distill and steam
or air strip volatile components from
hazardous waste: examples include
distillation columns, steam stripping
columns, air stripping units, and thin-
film evaporation units at TSDF. '
The proposed standards would have
regulated actual reclamation processes
for the first time. Only recycling units at
TSDF already subject to RCRA permit
requirements (e.g* because of storage
activity on the facility) would have been
subject to the proposed air standards.
Both new and existing units would have •
been required to have add-on control
devices designed to achieve a 95-percent
reduction (based on the application of
secondary condensers) and to operate
within that design. Once in operation.
the facilities would have demonstrated
compliance by monitoring the operation
of the control device.
The proposed standards also would
have required implementation of a
monthly leak detection and repair
(LDAR) program for valves, pumps,
compressors, pressure relief devices.
and closed-vent systems used to handle
hazardous wastes and their derivatives
at TSDF. Control systems, leak
definition methodology, leak definitions,
and repair schedules were based on
existing equipment leak standards
developed under sections 111 and 112 of
the CAA.
Since proposal. EPA has made several
important changes to the standards
based on the public comments received
after proposal and analyses resulting
from these comments, The applicability
and requirements of the final standards.
including the changes made since
proposal, are discussed hi section V.
The EPA's responses to the major.
comments are summarized in section VL
Additional information is presented in
the BIO for the final standards.
V. Applicability and Requirements of
Today's Final Standards
This section provides a detailed
summary of the final standards as they
apply to the affected TSDF community
and to process vents and equipment
subject to today's rule. Also summarized
is the relationship of the final standards
to existing exemptions under the RCRA
regulatory program.
A. Scopa of Final Standards
Today's final standards limit organic
air emissions as a class at TSDF that are
subject to regulation under subtitle C of
RCRA. This action is the first part of a
multiphasigd regulatory effort to control
air emissions at new and existing
hazardous waste TSDF. These rules
establish final standards limiting
organic emissions from (1) process vents
associated with distillation.
fractionatiion, thin-film evaporation.
solvent extraction, and sir or steam
stripping operations that manage
hazardous wastes with 10 ppmw or
greater total organics concentration on
an annual average basis, and (2) leaks
from equipment that contain or contact
hazardous waste streams with 10
percent by weight or greater total
organics.
The final standards do not expand the
~RCRA-permitted community for the
purposes of air emissions control As
promulgated, the final standards control
organic emissions only from process
vents and equipment leaks at hazardous
waste TSDF that are subject to
permitting requirements under RCRA
section 301)5 and are applicable only to •
specific hazardous waste.msnagement
units. The rules apply to hazardous
waste management units that are
subject to the permitting requirements of
part 270 and to hazardous waste
recycling emits that are located at
facilities otherwise subject to the
permitting requirements of part 270.
Exempt units, other than recycling units
(e.g.. 90-day accumulation tanks and
wastewatET treatment units as specified
in 5 270.1(<:)(2)}. are not subject to the
rules even when they are part of a
permitted facility. Permitting aspects are
further discussed in section IX.
The term "organics" is used in the
final standards instead of "volatile
organics" lo evoid confusion with
"volatile oifganic compounds" (VOC)
that are regulated as a class under the
CAA. To be subject to the standards, a
TSDF: (1) Musi have equipment that
contains or contacts hazardous wastes
that are 10 percent or more by weight
total organics, or (2) must have
distillation, fractionation, thin-film
evaporation, solvent extraction, or air or
steam stripping operations that treat or
process hazardous wastes with total
, organics concentrations of 10 ppmw or
greater on a time-weighted annual
average basis.
The fine), regulations require the
facility owners or operators to
determine whether their equipment is
subject to (he equipment leak rules,
subpart BB of parts 284 and 265. The
owner or" operator of a facility may rely
on engineering judgment for this
determination, or. if the waste's organic
content is questionable, the owner or
operator may choose any of the test
methods identified in the final rule for
-------
determining whether a piece of
equipment contains or contacts
hazardous wastes that are 10 percent or
more total organics by weight As
proposed, these methods includes ASTM
Methods D-2287-88. E169-87, S168-88,
and B 260-85 and Methods 9060 and
8240 of SW-848. The owner or operator
also may use any other test method for
determining total organic content that is
demonstrated to be equivalent to the
test methods identified in the rule using
the petition process described in 40 CFR
28X23. The test method selected should
be the one best suited for the
characteristics of the waste stream.
Regardless of the method chosen, the
final standard requires the facility
owner or operator to determine that the
organic content is never expected to •
exceed 10 percent The determination of
organic content of the waste must at all
times be appropriate to the wastes
currently being managed in the relevant
units. If any action-is taken that would
result in the determination no longer
being appropriate to the facility's or a
particular unit's operations (e.g» an
upstream process change that results in
. a change in a waste's organic content),
then a new determination is required.
To determine whether a particular
hazardous waste management unit of
the type specified in the rule (e.g. a
steam stripping or air stripping unit) is
subject to the provisions of subpart AA
of parts 284 and 265. the owner/operator
is required to determine the total
organic concentration of the waste
managed in the unit initially (by the
effective date of the standards or when
the waste is first managed in the waste
management unit) and thereafter on a
periodic basis (for continuously
generated wastes). A waste
determination for subpart AA
applicability would not be necessary
when an owner/operator manages the
waste in a distillation, fractionation.
thin-Rim evaporation, solvent
extraction, or air or steam stripping unit
that is controlled for organic emissions
and meets the substantive requirements
of subpart AA.
Determination that the time-weighted.
annual average total organic
concentration of the waste managed in
the unit is less than 10 ppmw must be
performed by direct measurement or by
knowledge of the waste as described
later in this section. Direct measurement
of the waste's total organic
concentration must be performed by
collecting individual grab samples of the
. waste and analyzing the samples using
one of the approved reference methods
identified in the rule.
The EPA is requiring that analytical
results for a minimum of four samples be
used to determine the total organic
concentration for each waste stream
managed in the unit In setting the
minimum number of samples at four.
EPA will obtain sufficient data to
characterize the total organic
concentration of a waste without
imposing an unnecessary burden on the
owner/operator to collect and analyze
the samples.
Waste determinations must be
performed under process conditions
expected to result in the maximum
waste organic concentration. For waste
generated on site, the samples must be
collected at a point before the waste is
exposed to the atmosphere such as in an
enclosed pipe or other closed system
that is used to transfer the waste after
generation to the first affected
distillation/separation operation. For
waste generated off site, the samples
must be collected at the inlet to the first
waste management unit that receives
the waste, provided the waste has been
transferred to the facility in a closed
system such as a tank truck, and the
waste is not diluted or mixed with other
» waste.
The location where the waste's total
organic content is determined is
important because sampling location
. can greatly affect the results of the
determination. This effect occurs,
because the concentration level can
decrease significantly after generation
as the waste is transferred to (and
managed in) various waste management
units.
If the waste is directly or indirectly
exposed to ambient air at any point a
portion of the organics in the waste will
be emitted to the atmosphere, and the
concentration of organies remaining in
the waste will decrease. For example.
for highly volatile organic compounds
such as butadiene, all of the compound
would evaporate within a few seconds
of exposure to air. To ensure that the
determination of total organic
concentration is an accurate
representation of the emission potential
of a waste upon generation, it is
essential that the waste determination
be performed at a point as near as
possible to where the waste is
generated, before any exposure to the
atmosphere can occur.
For the reasons stated above, the
. waste determination must be based on
the waste composition before the waste
i* exposed, either directly or indirectly.
to the ambient air. Direct exposure of
the waste to the ambient air means the
waste surface interfaces with the
ambient air. Indirect exposure of the
waste to the ambient air means the
waste surface interfaces with a gas
stream that subsequently is emitted to
the ambient air. If the waste
determination is performed using direct
measurement the standards would
require that waste samples be collected
from an enclosed pipe or other closed
system that is used to transfer the waste
after generation to the first hazardous
waste management unit If the waste
determination is performed using
knowledge of the waste, the standards
would require that the owner or
operator have documentation attesting
to the organic concentration of the
waste before any exposure to the
ambient air.
The location where the waste
determination would be made for any
one facility will depend on several
factors. One factor is whether the waste
is generated and managed at the same
site or generated at one site and
transferred to a commercial TSDF for
management Another important factor
is the mechanism used to transfer the
waste from the location where the waste
is generated to the location of the first
waste management unit (e.g.. pipeline.
sewer, tank truck). For example, if a
waste is first accumulated in a tank
using a direct enclosed pipeline to
transfer the waste from its generation
process, then the waste determination
could be made based on waste samples
collected at the inlet to the tank. In
contrast if the waste is first
accumulated in a tank using an open
sewer system to transfer the waste from
its generation process then the waste
determination would need to be made
based on waste samples collected at the
point where the waste enters the sewer
before the waste is-exposed'to the
ambient air. Where the waste is
generated off site, the owner or operator
may make the determination based on
samples collected at the inlet to the first
waste management unit at the TSDF
that receives the waste, provided the
waste has been transferred to the TSDF
in a closed system such as a tank truck
and the waste is not diluted or mixed
with other waste. If a waste
determination indicates that the total
organic concentration is equal to or
greater than the applicability criterion.
then the owner or operator would be
required to comply with the standards.
As an alternative to using direct
measurement an owner/operator is
allowed to use knowledge of the waste
as a means of determining that the total
organic concentration of the waste is
less than 10 ppmw. Examples of
information that might be considered by
. EPA to constitute sufficient knowledge
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 2S461
Include; (1) Documentation that organics
art not involved'in the process
generating the waste. (2) documentation
that the waste is generated by a process
that is identical to a process at the same
or another facility that has previously
been determined by direct measurement
to generate a waste stream having a
total organic content less than 10 ppmw,
or (3) previous spedation analysis
results from which the total
concentration of organics in the waste
caa be computed and it can be
documented that no process changes
have occurred since the analysis that
could affect the waste's total organic
concentration. The final standards
include the provision that EPA can'
require that the waste be analyzed using
Method 8240 if EPA believes that the
documentation is insufficient to
determine an exception by knowledge of
the waste (£§ 264.1034(f) and
205.1034(0).
To address the temporal variability
that can occur both within a particular
waste stream and within the various
waste streams managed in a hazardous •
waste management unit, the final rules
require a time-weighted, annual average
concentration to characterize the waste
managed ia the unit. The final rules
require that an owner/operator repeat
the waste determination whenever there
is a change in the waste being managed
or a change in the process that generates
or treats the waste that may affect the
regulatory status of the waste or, if the
waste and process remain constant, at
least annually. For example, continuous
processes are more likely to generate a
more homogeneous waste than batch
operations: batch operations involve
processes that may frequently involve
change in materials or process
conditions. Batch operations, therefore.
usually generate wastes with varying
characteristics, including such
characteristics as orgsnics content
Ground water concentrations would
also be expected to show significant
variation if more than one well provides
influent to a waste management unit
such as an air stripper and the wells that
feed the unit are varied over time or if
the proportions from the wells that make
up the influent are changed. This is
because there is typically considerable
spatial variability in contaminated
ground water concentrations. The
situation where feed wells are changed
and the change is not accounted for in
the initial waste determination would be
considered a process change or change
in the waste being managed that would
require a new determination.
With the time-weighted, annual
average applicability criterion, a
hazardous waste management unit
-would not be subject to this rule if it
occasionally treats wastes that exceed
10 ppmw if at other times the wastes
being treated in the unit are such that
the weighted annual average total
organic concentration of all wastes
treated is less thaa.10 ppmw. The time-
weighted.-annual average is calculated
using the annual quantity of each waste
stream managed ia the unit and the
mean organic concentration of each
waste stream.
Determining the applicability of the
.standards to affected processes, units,
and facilities is of paramount
importance to the TSDF owner or
operator in complying with the final'.
standards. A mistake even an
inadvertent one, will not excuse a
facility owner or operator from the
obligation to comply with either the
requirements of the standards or with
potential enforcement actions. Accurate
' determinations of what equipment and
vents must ba controlled are crucial to
ensuring that all equipment and vents
subject to this rule are in fact controlled.'
When the facility owner/operator and
the Regional Administrator disagree on
the determination of emissions or
emission reductioa achieved, then a
performance test conducted as specified
in the rules must be used to resolve the
disagreement In situations where the
owner/operator and Regional
Administrator disagree on whether a
unit manages a waste with 10 ppmw or
greater organics content or a piece of
equipment contains or contacts a waste
with 10 percent or more organics
content then procedures that conform to
the test methods referenced in the rules
may be used to resolve the
disagreement
Consistent with section 3010 of RCRA.
the final standards for process vent and
equipment leak control and monitoring
become effective 0 months from today.
Owners and operators must come into
compliance with these requirements by
the effective date; however, where
compliance involves the installation of a
control device. EPA is requiring that
installation be completed as soon as
possible but no later than 24 months
from the date the regulatory action
affecting the unit is published or
promulgated. To obtain the extended
time for compliance (18 months beyond
the effective date), a facility must show
that installation cannot reasonably be
expected to be completed earlier. In
these circumstances, an owner/operator
must develop an implementation
schedule that indicates when the
installation will be completed and
shows that additional time is necessary.
The implementation schedule must be
included in the operating record by the
effective date of the rules. Changes in
the implementation schedule are
allowed within the 24-month time frame
if the owner/operator documents that
the charge cannot reasonably be •
avoided,
B. Standards for Process Vents
Affected; Equipment
A "process vent" is a pipe, stack, or
other opening through which emissions
from a hazardous waste management
unit are released.to the atmosphere
either directly, through a vacuum-
producing system, or indirectly, through
another tank. The process vents that •
would have been covered by the
proposed standard included vents
associated with any hazardous waste
management process or waste
management unit
Review of the hazardous waste TSDF
industry has shown that process vents
are most typically associated with
processes related to distillation or other
separation operations. These
technologies were also the type being
evaluated under the LDR for spent
solvents,, Therefore EPA concentrated
its analysis of process vents on those
hazardous waste management units that
are involved in solvent or other organic
chemical! separation or reclamation by
distillation, fractionation, thin-film
. evaporation, solvent extraction, or air or
steam stripping operations. This should
include the largest segment of process
vents at TSDF and address those
sources iwith the greatest emission
potential. Vents on other types of waste
management units (e.g. vents on storage
tanks) ate being addressed in the Phase
0 rulemaking.
Two basic changes have been made
since proposal that clarify the
applicability of the final vent standard.
First to avoid confusion with tanks not
associated with the processing of waste
streams, the term "product accumulator
vessel" has been deleted from the final
standard and affected equipment is
more specifically defined. The
applicability of the final standard for
process vents also has been clarified
since proposal to exclude air emissions
from vents on other closed (covered]
and vented tanks not associated with
the specified distillation/separation
processes to avoid regulatory
duplication of the Phase II standards as
discussed above.
Thus, the final vent standards apply.
to: (1) Vents on distillation fractionation,
thin-film evaporation, solvent
extraction, and air or steam stripping
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Federal Register / VoL 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
processes and vents on condensers
serving these processes: and (2) vents on
tanks (e.g.. distillate receivers, bottoms
receivers, surge control tanks, separator
tasks, and hot wells associated with
distillation, fractionation. thin-film
evaporation, solvent extraction, and air
or steam stripping processes) if
emissions from these processes are
vented through the tank. For example.
uncondensed overhead emitted from a
distillate receiver (which fits the
definition of «tank) serving • hazardous
waste distillation process unit is subject
to these Phase 1 air controls. OB the
other hand, emissions from vests on
tanks or containers that do not derive
from a process unit specified above are
not covered by these rules. For example.
if the condensed (recovered) solvent is
pumped to an intermediate holding tank
following the distillate receiver
mentioned hi the above example, and
the intermediate storage tank has a
pressure-relief vent (e.g., a conservation
vent) serving the tank, this vent will not
be subject to the process vent standards.
Emissions from vents that an not
covered under today's rules will be
addressed by Phase H of the air
standards under section 3004(n).
Second, the terms "VHAP" and "hi
VHAP service" have been deleted from
the final rule hi response to public
comments. Commenters found the terms'
inappropriate for transfer from
equipment leak standards developed
under section 111 or 112 of die CAA to
RCRA standards for organic emissions
from hazardous waste. The EPA agrees
with these commenters: these terms can
be confusing and they are unnecessary
for these rules. Therefore, the cross-
reference to part 81 has been eliminated
and the wording of the final regulation
has been revised to reflect applicability
based on clearly specified hazardous
waste management processes or unit
operations that manage wastes with a
10 ppmw or greater total organic
content
Requirements of Final Standard for
Process Vents
In response to public comments,
several changes have been made to the
proposed standard for process vents.
While the proposed 95-percent emission
reduction standard would have applied
to individual process vents emitting
organics with concentrations of 10
percent or greater by weight the final
process vent 95-percent'emission
reduction standard applies to total
organic emissions from the combination
of all affected vents (Le.. vents subject
to the provisions of subpart AA) at the
facility. As discussed in section VI of
this preamble and in the BIO for the
final rules, the term "facility" refers to
the entire site that is under control of
the owner or operator engaged in
hazardous waste management Thus.
organic emissions from affected process
vents anywhere on the hazardous waste
management facility are subject to the
standards.
The 10-percent concentration criterion
for process vents has not bees included
in the final rules because the
promulgated standards contain a
facility-based emission rate limit of 1.4
kgA (3 Ib/h) and 2J» Mg/yr (3.i ton/yr)
that is more effective in controlling
emissions from affected sources and
excluding facilities with little emission
reduction potential. Based on emissions
and health risk analyses conducted in
response to comments, this emission
rate limit represents an emission level
from process vents that is protective of
human health and the environment and
below which additional meaningful
reductions is nationwide health risk and
environmental impacts attributable to
process vents'cannot be achieved.
Control of facilities with process vent
emissions less than 'the emission rate
limit would not result in further
reductions of either cancer risk or
incidence os a nationwide basis.
Facilities with organic emissions from
process vents that do not exceed these
emission rates will not have to install
controls or monitor emissions from
affected process vents. Selection of the
emission rate limit is addressed in
section VLB of this preamble and in
chapters 4J> and 7.0 of the BID.
Because the emission rate limits (3 lb/
h and XI ton/yr) provide health-based
limits, EPA considered dropping
completely the organic content criterion
(U., at least 10 percent total organics).
However. EPA decided not to
completely eliminate the organic content
criterion because it is not clear that the
same controls can be applied to very
low concentration streams as can be
applied to the higher concentration
streams that generally are associated
with emission rates greater than the
limits. For low-concentration streams.
EPA questions whether controls are
needed on a national or generic basis
but is unable to resolve this question at
this time. Thus. EPA decided to defer
controlling very low concentration
streams until it is better able to
characterize and assess these streams
and the appropriate controls.
Once EPA decided to consider
facilities that manage very low
concentration organic wastes as a
separate category, there remained the
problem of determining the appropriate
criterion. The EPA examined existing
data on air strippers, the treatment
device most commonly used with low-
concentration streams: it appeared that
the quantity of emissions and the risk
associated with air strippers treating
streams with concentrations below 10
ppmw may be relatively small, thus
minimizing the potential harm of
deferring control until a later time.
Examples of facilities managing low-
concentration wastes are sites where
ground water is undergoing remedial
action under CERCLA or corrective
action pursuant to RCRA. Given the
limited set of precise data available, and
the comments that the 10-percent
criterion was too high. EPA determined
that an appropriate criterion would be
10 parts per million (ppm) total organics
hi the waste by weight
The 10-ppmw criterion is not an
exemption from regulation: it is intended
only as a way for EPA to divide the air
regulations into phases. The EPA is
deferring action on very low
concentration streams (i.e.. ones with
less than 10 ppmw total organic content)
from the final rule today but will
evaluate and announce a decision later
on whether to regulate these waste
streams.
To comply with the final standards for
process vents, the TSDF owner or
operator is required to identify all
process vents associated with
distillation, fractionation. thin-film
evaporation, solvent extraction, and
stripping processes that are treating
' hazardous waste with a 10-ppmw or
greater total organics concentration on a
time-weighted annual average basis (i.e..
vents affected by the rules). Organic
emission rates for each affected vent
and for the entire facility from all
affected vents must be determined. The
facility process vest emission rate must
then be compared to the short- and long-
term process vent emission rate limits (3
Ib/h or 3.1 ton/yr) to determine whether
additional emission controls are
required. If the process vent emission
rate limit is exceeded, the owner or
operator must take appropriate action to
reduce total facility emissions from
affected process vents to below the
cutoff level or install additional
emission controls to reduce total facility
process vent organic emissions by 95
weight percent If an incinerator.
process heater, or boiler is used as a
control device, the volume-concentration
standard of 20 ppmv can be met instead
of the 95-weight-percent reduction
(§5 264.1033(c). 284.1060. 28S.1033(c), .
and 285.1060).
Because the final rules could apply to
dilute process vent streams and the rule
is formatted in terms of a weight-percent
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Federal Register / Vol. 55. No. 120 / Thursday, June 21, 1990 / Rules and Regulations 25463
reduction standard, it is necessary to
include the volume concentration
standard in the final control device
standards to account for the
technological limitations of enclosed
combustion devices (43 FR 4933.
October 21.1983). one of the control
technologies examined as part of the
rulemaldng. treating dilute streams.
Below a critical concentration level, the
maximum achievable efficiency for "
enclosed combustion devices decreases
as inlet concentration decreases: thus.
for streams with low organic vapor
concentrations, the 95-percent mass
reduction may not be technologically
achievable in al) cases. Available data '
show that 20 ppmv is the lowest outlet
concentration of total organic
compounds achievable with control
device inlet streams below
approximately 2.000 ppmv total
organic*. Therefore, a concentration
limit of 20 ppmv has'been added as an
alternative standard for incinerators,
procsse heaters, and boilers to allow for
the drop in achievable destruction
efficiency with decreasing inlet organics
concentration. For consistency, the 20-
ppmv concentration is expressed as the
sum of the actual individual compounds.
not carbon equivalent*, on a dry basis
corrected to 3 percent oxygen. For
facilities that do not meet the emission
rate limit, the final process vent
standards require that control devices
achieve a 95-percent reduction in total
organic emissions for the facility or. in
the case of enclosed combustion
devices, a reduction of each process
vent stream to a concentration of no
more than each process vent stream to a
concentration of no more than 20 ppmv
total organic compounds.
The final standards for process vents
do not require the use of any specific
equipment or add-on control device: the
standards can be met using several
types of controls. Depending on the
characteristics of the process vent
stream, either a condenser or a carbon
adsorber will likely be the control
technology of choice. However, other
control devices such as flares.
incinerators, process heaters, and
boilers, as well as any other device of
the owner or operator's choice, also can
be used where applicable to achieve
compliance.
Operating requirements for closed-
vent systems and control devices are
included in f § 284.1033 and 285.1033. A
closed-vent system means a system not
open to the atmosphere and composed
of piping, connections, and. if necessary.
flow-Inducing devices that transport gas
or vapor from a piece or pieces of
equipment to a control device. If vapor
recovery systems such as condensers
and adsorbers are used as control
devices, they must be designed and
operated to recover the organic vapors
vented to mem with an efficiency of 95
percent or more unless the total organic
emission limits for affected process
vents (!§ 284.1032 and 285.1032) can be
attained at efficiencies less than 95
percent Vapor recovery systems whose.
primary function is the recovery of
organics for commercial or industrial
use o? reuse (e.g^ a primary condenser
on a waste solvent distillation unit) are
not considered a control device and
should not be included in the 95-percent
emission reduction determination.
If enclosed combustion devices such
as incinerators, boilers, or process
heaters are used, they must be designed
and operated to achieve a total organic
compound emission reduction efficiency
of 95 percent or more or must provide a
minimum residence time of 0.5 s at a
minimum temperature of 780 *C° The
latter are general design criteria
established by EPA, and used in .
numerous rulemakings. that can be used
by facilities to lieu of conducting a site*
specific design for enclosed combustion
devices. The operating requirements for
closed-vent systems and control devices
include a provision allowing enclosed
combustion devices to reduce organic
emissions to a total organic compound
concentration of 20 ppmv, by compound.
rather than achieve the 95-weight
percent reduction.
If flares are used, they must be
designed and operated with no visible
emissions as determined by the
procedures of Reference Method 22.
except for periods not to exceed a total
of 5 min during any 2 consecutive hours.
The final standard specifies that Saras •
must be operated with a flame present
at all times and must be operated at all
times when emissions may be vented to
them. In addition, flares must provide a
net heating value of the gas being
combusted of 11.2 mega joules per
standard cubic meter (MJ/scm) or more.
be steam-assisted or air-assisted, or
provide a net heating value of 7.45 Mf/
scm or more if the flare is nonassisted.
Specific design and operating
requirements for steam-assisted, air-
assisted end nonassisted flares also are
included in the final standard.
Calculations and procedures for
determining the net heating value of the
gas being combusted the actual exit
velocity and the maximum allowed
velocity are included in the final
provisions for closed-vent systems and
control devices (see 55 2S4.1033(d) and
265.1033(d)).
Facilities must maintain
documentation in the operating record
supporting waste determinations.
identifying affected process vents,
affected waste management unit
throughputs and operating hours.
emission rates for each affected vent
and for the overall facility, and the basis
for determining the emission rates
(IS 284.1!J3S(b](2) and 265.1035(b)(2)}.
Regardless of the type of control device
used, the documentation must certify
that add-on control devices achieve the
emission rate limit by design and during
operation, or that add-on control devices
achieve n 95-percent reduction in
organics or achieve the 20-ppmv
organics concentration limit by design
and during operation where the
emission rate limit is not attained. The
design documentation must present the
basis for determining the design
emission reduction and establish the
basic values for operating parameters
, used tc monitor the control device s
operation, and maintenance. The design
control level (i.e* the emission reduction
needed t<» achieve the emission rate
cutoff or 155-percent emission reduction)
can be documented by vendor/
manufacturer certifications, by
engineering calculations, or through
source tents to show that the control
device removes the required percentage
of organics entering the device. All
required information and documentation
must be kept in the facility s operating
record. The facility's waste
determinations and process vent
emission rate determinations must at all
times reflect the facility's current waste
management unit designs and wastes
managed If the owner/ operator takes
any action that would result in the
determination no longer being
appropriate to the facility's operations
(e.g.. if a waste of different composition
is managiid, the operating hours of the
affected management units are
increased beyond what was originally
considered, or a new affected unit is
added thtit may impact its regulatory
status), then a new determination is
required (§9 234.103S(b)(2)(ii) and
285.103S(b)(2J(ii)). In addition, certain
information regarding the facility's
emission determination and control
device design must be included in the
facility's part B permit application.
The finiil rules require the continuous
monitoring of specific parameters on ail
control devices needed to meet the
standards to ensure that the devices
perform according to their design
(SS 264.1033(f) and 265.1033(f)). The final
rules clarify the general parameters
listed in the proposal by describing the
requirements in greater detail. Operating
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1980 / Rules and Regulations
parameters are specified for condensers,
carbon adsorbers, flares, incinerators.
and other enclosed combustion devices.
Although minimum operating conditions
are identified for organic vapor
destruction devices (e.g., incinerators
and flares) to ensure 95-percent
destruction, values or ranges of values
for recovery device (Le, condensers and
carbon adsorbers) operating parameters
cannot be specified on aa industry-wide
basis. Therefore.« recovery device must
be designed for the particular
application and monitored to ensure that
it ic being operated within design
specifications. Proper design shall be
determined through engineering
calculations vendor certification, and/or
emission testing.
The owner/operator is required to
record the control device monitoring
information, including the basis for the
operating parameters used to monitor
control device performance, in the
facility operating record. Periods when
monitoring indicates control device
operating parameters are outside
established tolerances on design
specifications must be recorded.
Facilities with final permits
incorporating these standards (Le..
facilities subject to the provisions of 40 .
CFR part 284 snbpart AA) must report
exceedances that are not corrected
within 24 hours to the Regional
Administrator on a semiannual basis. • •
The records and reports must include
the dates, duration, cause, and
corrective measures taken. (See '
51264.1038(8) and 284.1065(a)(4).J
The specific monitoring requirements
* for control device operating parameters
include; (1) Continuous monitoring of
coolant fluid temperature and exhaust
gas temperatures or the concentration
level of organic compounds in the exit
gas stream for condensers. (2)
continuous monitoring of exhaust gas
organic breakthrough for carbon
adsorbers: (3) continuous monitoring of
' combustion zone temperature for
incinerators, boilers and process
heaters: and (4) the presence of a pilot
flame using a thermocouple or any other
equivalent device to detect the presence
of a flame for flares.
The final standards would require that
emission control equipment is properly
designed, installed, operated, and
maintained. Also, as previously
described, the standards would require
continuous monitoring of specific
control device operating parameters. A
control device monitor reading outside
the operating range allowed by the
'standards (referred to in this preamble
as a "control device-exceedance")
indicates that the control device is not
operating normally or is malfunctioning
(i.e., not operating at the design setting
necessary to achieve at least 95 percent
organic emission control efficiency).
Action must be taken by the owner or
operator to return the control device to
operating at the design setting. When a
control device exceedance cannot be
corrected within 24 hours of detection.
the final standards would require the
owner or operator to record specific
information concerning the control
device exeeedance. Facilities with final
RCRA permits must report this
information to EPA on a semiannual
basis; interim status facilities, are not
required to report control device
exceedances. The exceedance report
would need to describe the nature and
period of each control device
exceedance and to explain why the
control device could not be returned to
normal operation within 24 hours. A
report would need to be submitted to
EPA only if control device exceedances
have occurred during the past 8-month
reporting period. These reports would
serve to aid EPA in determining the
owner's or operator's ability to properly
operate and maintain the control device.
The EPA recognizes that a control
device malfunction may occur due to
circumstances beyond the control of the
owner or operator (e.g, defective
equipment supplied by the
manufacturer). Therefore, a single
control device exceedance may not
necessarily be indicative of improper
control device operation or
maintenance.
C. Equipment Leak Standards
Affected Equipment
The final standards apply to each
valve, pump, compressor, pressure relief
device, open-ended valve or line, flange
or other connector, and associated air •
emission control device or system that
contains or contacts hazardous waste
streams with 10 percent or more total
organics by weight
In response to public comments, EPA
has changed the applicability of the final
LDAR standards for pumps and valves
to better relate to the volatility of the
wastes managed and thus to air
emission potential The requirements for
pumps and valves have been revised to
include the heavy liquid provisions
contained in EPA's new source
performance standard (NSPS) for
equipment leaks of VOC in the synthetic
' organic chemicals manufacturing
industry (SOCMI) (40 CFR part 60. part
VV). The heavy liquid provisions
(II 264.1058and 285.1058) exempt
pumps and valves processing lower
vapor pressure substances from the
routine leak detection monitoring
requirements of the standards. By their
nature, heavy liquids exhibit much
lower volatilities than do light liquids,
and because equipment leak rates and
emissions have been shown to vary with
stream volatility, emissions from heavy
liquids are less than those for lighter.
more volatile streams. For example. EPA
analyses indicate that emissions from
valves in heavy liquid service are more
than 30 times lower than the emissions
from valves in light liquid service.
Pumps.and valves are in light liquid
service if the vapor pressure of one or
more or the components being handled
by the piece of equipment is greater than
O3 kilopascal (kPa) at 20 *C if the total
concentration of the pure components
having a vapor pressure greater than 0.3
kPa at 20 *C is equal to or greater than.
20 percent by weight and if the fluid is.
liquid at operating conditions. Pumps •
and valves not in light liquid service are
defined to be in heavy liquid service.
The regulations governing equipment
leaks also have been incorporated and
reprinted in the final standards to
eliminate cross-referencing, to part 81
regulations and to consolidate the
requirements under RCRA.
Equipment Leak Control Requirements
The control requirements for valves
are based on LDAR requirements.
Valves in light liquid or gas/vapor
service (5 J 284.1057 and 285.1057) must
be monitored using Reference Method
25: an instrument reading at or above
10.000 ppm indicates the presence of a
leak. If a leak is detected, the valve must
be repaired as soon as practicable but
no later than 15 days after the leak is
detected. A first attempt to repair the
valve must be made no later than 5 days
after the leak is detected. First attempts
at repair include, but are not limited to,
tightening or replacing bonnet bolts
tightening packing gland nuts: or
injecting lubricant into the lubricated
packing.
Monthly monitoring is required:
however, any valve for which a leak is
not detected for 2 successive months
may be monitored the first month of
each succeeding quarter until a leak is
detected (53 284.10S7(c) and
265.1057(c) J. If a leak is detected the
valve must be monitored monthly until a
leak is not detected for 2 successive
months.
In addition, monthly monitoring is not
required if: (1) A leakless valve, such as
a sealed-bellows valve, is used to
achieve a no-detectable-emissions limit
(500 ppm above background, as
measured by Method 21. with an annual
performance test: §5 284.1057(0 and
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Federal Register / Vol. 55, No. 120 / Thursday, June 21. 1990 / Rules and Regulations 2546S
2flS.1057(fJ; (2) tin owner or operator
meets a performance level of 2 percent
of ill valves leaking (§§ 284.1061 and
285.1001); (3) the owner or operator
elects to comply with a skip-period leak
detection and repair program as
described for valves (§| 264.1062 and
285.1062): or (4) the) valve is designated
by the owner or operator as unsafe-to-
mocitor or diflkult-to-monitor
(li 284.1057 (a) and (hj and 285.1057 (g)
and (h)). A valve may be designated as
' unsafo-tcHBonltor if monitoring
personnel would be exposed to an
immediate danger as a consequence of
monitoring and if the owner or operator
adheres to a written plan that requires
monitoring of the valve as frequently as
practicable during safe-to-monitor times.
A valve may be designated as dlfflcult-
tc-mooitor if the valve cannot be
monitored without elevating monitoring
personnel more than 2 m above a
support surface, the valve is in an
existing hazardous waste management
unit and the owner or operator follows a
written plan that requires monitoring at'
least once a year.
The EPA Is continuing to study the
status of new technology available for
the control of air emissions from valves.
The EPA has issued a separate notice in
the Federal Register that discusses
available information on leakless valve
technology (54 FR -•"»«. July 19,1930).
Public comments were requested in that
notice oa several aspects of the
technology to assist EPA in determining
applications for which leakless valve
technology would be appropriate at
hazardous waste TSDF.
The final standards also require
monitoring for pumps at TSDF
containing or contacting wastes with
greater than 10 percent organics
(!i 284.1052 and 285.1052). Each pump in
light liquid service must be monitored
monthly with a portable vapor analyzer
following the EPA Reference Method 21
protocol In addition, each pump in light
liquid service must be checked weekly
by visual inspection for indications of
liquids dripping front the pump seaL A
pump is determined to be leaking if an
instrument reading of 10.000 ppm or
greater is measured or there are
indications of liquids dripping from the
pump seat When a leak is detected, it
must be repaired as soon as practicable.
but not later than 15 days after it is
detected unless the delay-of-repair
provisions specified in the rule apply.
The first attempt at repair must be made
within 5 calendar days of the leak being
detected.
Pumps in light liquid service are
exempt from the monitoring
requirements under §i 284.1052 (d) and
(e) and 265.1052 (d) and (e) if: (1) The
pump is equipped with a dual
mechanical seal system that includes a
barrier fluid between the two seals. (2) a
magnetically coupled or diaphragm
pump is used to achieve a no-detectable-
emissions limit (indicated by a portable
organic vapor analyzer reading of lese
than 500 ppm above background), or (3)
the pump i» equipped with a closed-vent
system capable of transporting any
leakage from the seal or seals to e 95-
percent efficient control device. If
pumps are equipped with a dual
mechanical seal system, emissions from
the barrier fluid reservoir must be
vented to a control device designed and
operated to achieve a 95-percent control
efficiency, die barrier fluid must be
purged and added to the hazardous
waste stream, or die pressure of the
barrier fluid must be maintained at a
level above the pressure in the pump or
exhauster stuffing box. A pressure or
level indicator to detect any failure of
the seal system or the barrier fluid
system ie required, with the indicator
checked daily or equipped with an
alarm to signal failure of the system. If
leakless equipment is used, such as
magnetically coupled or diaphragm
pumps, the standards require an annual
performance test by Method 21 to verify
the no-detectable-emissions status of
the equipment
Compressors must be equipped with a
seal system that includes a barrier fluid
system that prevents leakage of organic
emissions to the atmosphere. The seal
system must be operated with the
barrier fluid at a pressure that is greater
than the compressor stuffing box
pressure, be equipped with a barrier
fluid system that is connected by a
closed-vent system to a control device
that meets the design and operating
requirements established in 51 284.2060
and 285.1060. or be equipped with a
system that purges the barrier fluid into
e hazardous waste stream with zero
total organic emissions to the
atmosphere. In addition, the barrier fluid
system must be equipped with a sensor
that detects failure of the seal system.
barrier fluid system, or both. A
compressor is determined to be leaking
if the sensor indicates failure of the seal
system, the barrier fluid system, or both.
When a leak is detected, it must be
repaired as soon as practicable, but not
later then IS calendar days after it is
detected: a first attempt at repair must
be made within 5 calendar days.
Except during emergency pressure
releases, each pressure relief device in
gas/vapor service must be operated
with no detectable emissions (500 ppm
above background, as measured by
Reference Method 21) (SI 284.1054 and
285.1054). No later than 5 calendar days
after any pressure release, the device
must be relumed to a condition of no
detectable emissions and be monitored
to confirm that status. Any pressure
relief devitie that is equipped with a
closed-vent system capable of capturing
and transporting leakage to a control
device thai: meets the requirements of
,|| 284.1060 and 285.1060 is exempt from
"these requirements.
Each opim-ended valve or line must
be equipped with a cap. blind flange.
plug, OF second valve (55 284.1058 and
285.1056). irhe cap. blind flange, plug, or
second valve must seal the open end at
all times' except during operation
requiring hazardous waste stream flow
through th« open-ended valve or line.
Operationul requirements for second
valves and double block and bleed
systems aluo are specified in the final
regulation.
Pumps add valves in heavy-liquid
service, pritssure relief devices in light-
liquid or iuiavy-liquid service, and
flanges aad other connectors must be
monitored within 5 days by Reference
Method 21 if evidence of a potential leak
is found by visual audible, olfactory, or
any other detection method (5 § 284.1058
and 26S.10!ia). A leak is detected if an
instrument reading-of 10.000 ppm or
greater is measured. When a leak is
detected, il: shall be repaired as soon as
practicable! but not later than 15
calendar days after detection. The first
attempt at repair must be made within 5
calendar days of the leak being
detected.
The final standards also include
provisions for delay of repair (§5
284.1059 and 285.1059). Delay of repair
of leaking oquipment is allowed if the
repair is teshnically Infeasible without a
hazardous wasts management unit
shutdown (Le.. a work practice or
operational procedure that stops
operation of a hazardous waste
management unit or part of a hazardous
waste management unit). However,
repair of the leak must be performed
before the iend of the next shutdown of
that unit Delay of repair also is allowed
for equipment (i.e.. either pumps or
valves) that is isolated from the
hazardous waste management unit and
is prevented from containing or
contacting a hazardous waste with 10
percent or more organic content. For
valves, delny of repair is allowed if: (1)
The owner or operator determines that
emissions of purged material resulting
from immediate repair are greater than
the emissions likely to result from delay
of repair, and (2) when the valve is
repaired the purged materials are
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25468 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
collected and destroyed or recovered in
a control device complying with the
requirements of (he standards. Delay of
repair beyond a hazardous waste
management unit shutdown is allowed
only if valve assembly replacement is
necessary during the next shutdown of
the unit valve assembly supplies have
been depleted, and valve assembly
supplies had been sufficiently stocked
before supplies were depleted (i.e.. the
owner/operator has made a good-faith
effort to maintain adequate spare parts).
For pumps, delay of repair is allowed if:
(1) Repair requires the use of a dual
mechanical seal system that includes a
barrier Quid system, and (2) repair is
completed as soon as practicable, but
not later than 6 months after the leak is
detected.
.The final standards also include
design and operating requirements for
closed-vent systems that may be used to
comply with the equipment leak
standards (SS 284.1060 and 263.1060).
Closed-vent systems must be designed
for and operated with no detectable
emissions, as indicated by an instrument
reading of less than 500 ppm above
background by Reference Method 21. A
leak on a closed-vent system, indicated
by an instrument reading of £00 ppm or
by visual inspection, must be repaired
within IS calendar days after detection;
a first attempt at repair must be made
no later-than S calendar days after
detection. Monitoring must be
conducted initially, annually, and at
other times as requested by the Regional
Administrator, to confirm the no-
detectable-emissions status of the
system. Like other control devices.
closed-vent systems must be operated at
all times when any emissions may be
vented to them.
The provisions of 40 CFR 31.244.
subpart V; which provide a formal
mechanism for applying for use of an
alternative means of emission limitation.
were specifically not included in the
proposed TSDF process vent and
equipment leak rules and have not been
included in these final standards. The
alternative means of emission limitation
provisions are not considered self-
implementing: i.e.. these provisions
cannot be satisfied without the need for
detailed explanation or negotiation
between the facility owner/operator and
EPA. and thus are not appropriate as
requirements for interim status facilities
under part 263. Therefore, the
alternative means of emission limitation
provisions were not included in the final
subpart AA and BB rules. An owner or
operator, however, may use an
alternative means of emission limitation
to comply with the process vent or
equipment leak standards of part 264.
The owner/operator can use part B of
the permit application to provide
Information that demonstrates the
effectiveness of any alternative means
of emission limitation and can use the
negotiation process associated with
issuance of a final permit to establish
conditions for use of an alternative
means of emission limitation. The owner
or operator would be responsible for
collecting and verifying test data to
document that the emission reduction
achieved by the alternative is equal to
or greater than the emission reduction
achieved by the equipment design, or
operational requirements in the
standard.
Additional general recordkeeping
requirements include information on
pump, valve, compressor, and pressure
relief device leak repair attempts;
reasons for repair delays; and design
criteria for sampling connection systems
and closed-vent systems and control
devices. There are also recordkeeping
and monitoring requirements for pieces
of equipment covered by alternative
requirements.
Compliance with the equipment.Seak
standards will be assessed through
plant inspections and the review of
records that document implementation
of the requirements as required by the
final standards.
D. Summary of Changes from Proposal
Several changes have been made.to
the standards since proposal as the
result of EPA's evaluation of comments
and of additional information gathered
in response to comments. These changes
respond primarily to commenters*
concerns that additional controls are
unnecessary for TSDF process vents and
equipment with very low emissions and
that the applicability, implementation.
and compliance provisions of the
standards should be clarified. The EPA
has addressed these problems in the
final rules.
The proposed standards would have
required that organic emissions from all
process vents that emit organics in
concentrations of 10 percent or greater
on all TSDF waste management units be
reduced by 95 percent The final rules.
apply to process vents on specific
hazardous waste management units that
• treat wastes with total organics
concentrations of 10 ppmw or greater
and include (1) process vents on
distillation, fractionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operations and vents on
condensers serving these operations and
(2) process vents on tanks associated
with distillation, fractionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operations if emissions
from these process operations are
vented through the tanks.
While the proposed standard would
have required 95 percent emission
reduction from each affected vent the
final vent standard's weight-percent
reduction applies to total emissions from
the combination of.all affected vents at
each facility. The final rules also add
facility-based emission rate limits for all
affected process vents of 1.4 kg/h (3 lb/
h)and23Mg/yr(3.1ton/yr)(§§ ' .
284.1032(a](l) and 265.1032(a)(l)).
Facilities with organic emissions from
vents below the emission rate limits will
not have to reduce process vent organic
emissions. The owner or operator of the
facility must determine and document
that emissions from affected vents will
not exceed the emission rate limits. The
EPA estimates that baseline emissions
will be reduced by about 90 percent by
controlling process vent emissions from
about 55 percent of affected facilities.
i.e., those with emissions above the
emission rate limit
• Another major change affects the
applicability of the final standards for
pumps and valves to better relate to the
volatility of the wastes managed and
thus to air emission LDAR potential. The
proposed LDAR requirements for pumps
and valves have been revised to
distinguish between equipment in heavy
liquid service and equipment in gas/
light liquid service. The provisions
exempt pumps and valves processing
relatively low vapor pressure
substances (heavy liquids) from the
routine instrument monitoring
requirements of the standards. These
provisions are included to avoid
requiring unnecessary controls on
equipment that poses little emission
problem even when leaking.
Because of cammenters' concerns
with the administrative problems
associated with obtaining a major
permit modification, the final standards
do not require modifications of RCRA
permits issued before the effective date
of these rules (§5 2S4.1030(c) and
264.1050(0)). In such cases, requirements
for affected hazardous waste
management units and associated
requirements for process vents and
equipment must be added or
incorporated into the facility's permit at
review under § 270.50 or at reissue
under § 124.15. However, in the
forthcoming Phase II air rules. EPA will
be proposing to modify §§ 264.1030(c)
and 284.1050(c} as they apply to control
of air emissions under subparts AA and
BB. This action, if adopted, would mean
that the air rules promulgated under
RCRA section 3004(n) would be
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 25467
applicable to all facilities at of the
effective date of the Phase U rules. Mora
detail* regarding implementation are
presented in section IX of this preamble.
The proposed air emission standards
for process vents and equipment leeks
would have added part 269. Air
Emission Standards for Owners and
Operators of Hazardous Waste
Treatment. Storage, and Disposal
Facilities. For consistency with
standards for other TSDF sources under'
RCRA. the final standards have been
incorporated into part 264. for permitted
facilities, and part 285. for interim status
facilities. In addition, whereas at
propose! the equipment leak
requirements of 40 CFR part 61. subpart
V, were incorporated by reference, these
provisions have been written into
subpart BB with editorial revisions
appropriate for a standard promulgated
under RCRA authority rather than CAA
authority.
£ RaktionshipofRCRA Exemptions to
Fined Standards
Under 40 CFR 281.4{c). hazardous
wastes that are generated in process-
related equipment such as product or
raw material storage tanks or pipelines
are exempt from RCRA regulation. This
exemption applies until the weste is
physically removed from the unit in
which it was generated, unless the unit
is a suffice impoundment Or unless the
hazardous waste remains in the unit
more than 90 days after the unit ceases
to be operated for manufacturing, or for
storage or transportation of product or
raw materials. This exemption is not
affected by this rule. Therefore, units
such as product (not hazardous waste)
distillation columns generating
hazardous waste still bottoms
containing organic* are not subject to
the standard while the wastes are in the
product distillation column. However.
distillation columns that receive
hazardous wastes and that are used in
hazardous waste treatment (Le,
hazardous waste management units) are
subject to this standard if the waste's
organic content exceeds the 10-ppmw
applicability criterion. As discussed in
the preamble to the proposed standard.
only thoee recycling units that are part
of a facility already subject to RCRA
permit requirements are subject to the
air standards. The EPA's authority to
control air emissions from solvent
reclamation operation* not part of
closed-loop systems is discussed further
tn section VI of this preamble and in the
BID.
Totally enclosed treatment facilities
also are exempt from RCRA subtitle C
requirements under 40 CFR 264.1(g)(S).
40 CFR 285.1(cK9). and 270.1(c){2). A
"totally enclosed treatment facility" is a
hazardous waste treatment facility that
is "directly connected to an industrial
production process and which is
constructed end operated in a manner
that prevents the release of any
hazardous waste or any constituent
thereof Into the environment during
treatment" (40 CFR 280.10).
Treatment facilities located off the .
site of generation are not directly
connected to an industrial process.
Thus, commercial weste treatment
facilities with equipment affected by the
final standards, such as solvent
reclamation facilities, by definition
ordinarily would not be totally enclosed.
In addition, storage facilities, disposal
facilities, and ancillary equipment not
used for treating hazardous waste do
not fall within the definition of a totally
enclosed treatment facility.
The EPA believes that many on-site
treatment facilities also are not totally
enclosed. Distillation columns and other
treatment technologies typically are
designed to release emissions into the •
air. Therefore, by definition, these on-
site technologies generally are not
totally enclosed. (See 45 FR 33218, May
19. I960 (no constituents released to air
during treatment).)
Two important characteristics define
a totally enclosed treatment facility. The
key characteristic of a totally enclosed
treatment facility is that it does not
release any hazardous waste or
constituent of hazardous weste into the
environment during treatment Thus, i/a
facility leaks, spills, or discharges waste
or waste constituents, or emits waste or
waste constituents into the air during
treatment, it is no! a totally enclosed
treatment facility within the meaning of
these regulations. The second important
characteristic is that K must be directly
connected to en industrial production
process.
The EPA also excludes elementary
neutralization and wastewater
treatment tanks as defined by 40 CFR
260.10 from regulation under the
hazardous waste rules. The EPA
amended these definitions (see S3 FR
34080. September 2, 1988) to clarify that
the scope of the exemptions applies to
the tank systems, not just the tank. For •
example, if a wastewater treatment or
elementary neutralization unit is not
subject to RCRA subtitle C hazardous
waste management standards, neither is
ancillary equipment connected to the
exempted unit, The amendments also
clarify that, for a wastewater treatment
unit to.be covered by the exemption, it
must be pert of an oiuita wastewater
treatment facility. Thus, emissions from
process vents associated with
distillation, fractionation thin-film
evaporation, solvent extraction, or air or
steam stripping operations and ancillary
equipment (piping, pumps, etc.) that are
associated with a tank that Is part of the
wastewater treatment system subject to
regulation either under sections 402 or
307(b) of the Clean Water Act are not
subject to these standards. However, air
emission sources not subject to RCRA
may be subject to CAA guidance and/or
standard:!.
As noted in the preamble to the
proposal, under 40 CFR 26Z34.
generatoia that accumulate hazardous
waste in 'tanks and containers for 90
days or loss are not subject to RCRA
permitting requirements, provided they
comply with the provisions of 40 CFR
282.34, wliich include the substantive
requiremonts for tanks and containers •
storing hiizardous waste. 40 CFR part
265, subparts I and J. This remains
unchanged, and the final standards do
not apply to generator tanks that
accumulate hazardous waste for 90 days
or less. However, as part of the Phase II
TSDF air emission regulations. EPA
intends tci propose to modify the
exemptions conditions to require that 90=
day tanks, meet the control requirements ,
of the Phase I and Phase II standards.
Today'n fiaai rules regulate the
activity oif reclamation at certain types
of RCRA facilities for the first time. The
EPA is amending 40 CFR 281.8 under its
RCRA authority over reclamation to
allow covering reclamation of hazardous
wastes in waste management units
affected by today's final rules. It should
be recognized, however, that these final
rules apply only at facilities otherwise
heeding a RCRA permit In addition, the
closed-loop reclamation exemption in
f 261.4(a)i;a) is not changed by these
rules. Therefore, not all reclamation
units will necessarily be affected by
these rules.
VL Summary of Comments and
Responses
Numerous comments on the proposed
rule were received that relate to nearly
all aspectii of the RCRA standards
development process. The comment
summaries cover topics relating to
regulatory issues, applicability of the
standards, control technologies impact
analyses and implementation and
compliance issues. Detailed responses
to these and other comments are
included in the BID for the promulgated
standards, which is available in the
public docket for this rule.
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25468
' Federal Register / VoL 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
A. Regulatory Issues
Statutory Authority
Comment: Several commenters argued
that TSDF air emissions should be
regulated under the CAA rather than
RCRA because (1) CAA standards under
sections 111 and 112 are already in place
in the SOCMI and petroleum refining
industries (2) air emissions at some
TSDF have already been permitted
under State implementation plans (SIP),
new source review programs, or under
State regulations-for VOC or air toxics
control: (3) VOC and ozone control are
the province of the CAA. not RCRA: and
(4) a statutory mechanism already exists
under the CAA for evaluating the risk
posed by air emissions.
Response: Congress has required EPA
to promulgate air emission monitoring
and control requirements at hazardous
waste TSDF. under section 3004(n) of
RCRA. as may be necessary to protect
human health and the environment.
Congress was aware of the existence
and scope of the CAA when it enacted
section 3004(n) of RCRA. There is no
indication that Congress intended that
all air regulations be issued within the
confines of the CAA. On the contrary;
when adding section 3004(n), Congress
specifically recognized EPA's dual
authority to regulate these air pollutants
(S. Rep. 98-284. page 63).
The EPA has conducted an analysis of
current State and Federal controls and
concluded that further regulation under
section 3004(n) is necessary to protect •
human health and the environment The
EPA examined State regulations, as well
as existing Federal standards (and those
under development), to determine the
potential for overlapping rules and
permitting requirements. The EPA found
that 8 States have established air toxics
programs.'21 States have established
generic standards for VOC independent
of Federal regulations, and several
States have extended control techniques
guidelines (CTG) for VOC to TSDF.
However, the standards vary widely in
scope and application and in many
cases controls have not been required
.when emissions are below 40 ton/yr,
even in the 37 States with ozone
nonattainment areas. The EPA believes
that today's action will help alleviate
the nonuniformity among the States'
efforts and will help achieve emission
reductions necessary to protect human
health and the environment
A few commenters also argued that
the standards would duplicate existing
CAA standards that apply to the SOCMI
and petroleum refineries. The EPA
disagrees because the standards being
promulgated today apply to waste
management sources whereas the CAA
standards previously promulgated apply
to the production process.
The EPA also disagrees with
contentions that it is outside the
province of RCRA to address VOC and
ozone. As noted, section 3004(n)
standards, like all RCRA subtitle C
standards, are to protect "human health
and the environment" VOC and ozone
are threats to human health and the
environment and thus are well within
the regulatory scope of section 3004(n).
Organic emissions from TSDF
contribute to ambient ozone formation.
In fact. TSDF are estimated to emit
nearly 12 percent of all VOC from
stationary sources, and thus any
reductions in these emissions will
contribute to reducing ozone formation
and associated health and
environmental problems.
RCRA Authority Over Recycling
Comment: Several commenters argued.
that EPA does not have regulatory
authority under RCRA to control solvent
reclamation operations or units or
equipment managing materials destined
for reclamation such as spent solvent
because they are producing or managing
products and not wastes.
Response: The EPA disagrees with the
commenters regarding EPA's authority
to control solvent reclamation
operations. In response to a court
opinion fAmerican Mining Congress v.
EPA, 824 F.2d 1177, DC Circuit Court of
Appeals. July 31.1987) concerning the
scope of EPA's RCRA authority. EPA
proposed amendments to the RCRA
definition of "solid waste" that would
clarify when reclamation operations can
be considered to be managing solid and
hazardous wastes (53 FR 519, January 8.
1988). The EPA has accepted comments
on its interpretation arid proposed
amendments. The EPA has not yet taken
final action on this proposal Thus. EPA
is addressing the scope of its authority
over reclamation operations under
RCRA in the context of that rulemaking.
This rule is based on EPA's current
interpretation of its RCRA authority, as
described in the January 1988 proposal
The following summarizes EPA's
proposed position. In general, the
proposed amendments would exclude
from RCRA control only those spent
solvents reclaimed as part of a
continuous, ongoing manufacturing
process where the material to be
reclaimed is piped (or moved by a
comparably closed means of
conveyance) to a reclamation device.
any storage preceding reclamation is in
a tank, and the material is returned after
being reclaimed, to the original process
where it was generated. (Other
conditions on this exclusion relate to
duration and purpose of the reclamation
process. See proposed § 281.4(a)(8).)
However, processes (or other types of
recycling) involving an element of
"discard" are (or can be) within RCRA
subtitle C authority. When spent
materials are being reclaimed, this
element of discard can arise in two
principal ways.-First, when spent
materials are reclaimed by someone
other than the generator, normally in an
off-site operation, the generator of the
spent material is getting rid of the
material and so is discarding it. In
addition, the spent material itself, by
definition, is used up and unfit for
further direct use: the spent material
must first be restored to a usable
condition. This type of operation has
been characterized by some of the worst
environmental damage incidents
involving recycling (50 FR 858-661. - -
January 4,1985). Moreover, storage
preceding such reclamation has been
subject to the part 264 and 285 standards
since November 19,1980. (See generally
53 FR 522 and underlying record
materials.) The American Mining
Congress opinion itself indicates that
such materials are solid wastes (824
F.2datll87).
When a spent material is reclaimed
' on site in something other than a closed-
loop process. EPA also considers that
the spent material is discarded (i.e- .
spent solvents removed from the
process, transferred to an on-site
distillation unit and regenerated have
been removed from the production •
process). The EPA's reasoning is that
these materials are no longer available
for use in an ongoing process and have
been disposed of from that operation.
even if the reclamation operation is on
site. Finally, EPA also considers that
when hazardous secondary materials
are reclaimed but then burned as fuels,
the entire operation—culminating in
thermal combustion—constitutes
discarding via destructive combustion '
(53 FR 523). Consequently, under this
reading, any intermediate reclamation
step in these types of fuel production
operations remains within EPA's
subtitle C authority.
In summary, under EPA's current
interpretation of the court's opinion, air
emissions from distillation.
fractionation. thin-film evaporation.
solvent extraction, and stripping
processes involving reclamation of spent
solvent and other spent hazardous
secondary materials can be regulated
under RCRA subtitle C whenever the
reclamation system is not part of the
type of closed-loop reclamation system
described in proposed part 281.4(a)(8).
Any changes to this interpretation as
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 25469
part of the solid waste definition final
rule may affect the scope of this rule.
Selection of Source Category
Comment: Several commenters
disagreed with the selection of TSOF
and Waste Solvent Treatment Facility
(WSTF) process vents and equipment
leaks for regulation because they
believed that (1) out-of-date data or .
extrapolated data were used hi the
analysis and. as a result the estimate of
the number of affected facilities
nationwide and the number affected by
the proposed rule is far too low; (2) the
role of State regulations was not
considered: (3) EPA should control
larger, more hazardous air emission
sources at TSOF. such as storage tanks,
before controlling process vents and •
equipment leaks: and (4) air emissions
from waste solvent reclamation
operations do not pose a health risk
warranting control.
Response: The EPA generally
disagrees with the commenters that the
selection of TSDF process vents and
equipment leaks wu inappropriate.
However. EPA agrees that the standards
will affect mow than the 100 WSTF
estimated at proposal. To respond to
these and other comments. EPA
conducted additional technical
analyses. The EPA developed an
industry profile using results of the 1988
National Screening Survey of Hazardous
Waste Treatment Storage. Disposal
and Recycling Facilities (hereafter
called the "Screener Survey"). The
Screener Survey data represent all of
the TSOF active in 1965 with interim
status or final RCRA permits, which
totalled about 3,000 facilities. The
Screener Survey data are for operations
la 1965. the latest year for which such
comprehensive data are available. A
review of the Screener Survey data
shows a total of about 450 faculties that
need authorization to operate under
RCRA section 3005 and report solvent
recovery by operations such as batch
distillation, fractionation. thin-film
evaporation, or steam stripping at the
facility: Le.. operations that would have
process vents subject to the standards.
The EPA used these facility counts
together with the reported 1985 waste
solvent throughputs as the basis for the
final process vent standards impacts
analyses. In addition. EPA estimates
that about 1.000 on site and off site
permitted TSOF that do not practice
solvent recovery do manage hazardous
waste streams containing 10 percent or
more total organics and would be
subject to the equipment lenk
requirements. In total about 1.400
facilities are potentially subject to the
provisions of subpart BB.
State and Federal regulations also
were reviewed to help EPA better
estimate baseline emission control
levels. Although a few States have
controls in place, it appears that there
are no general control requirements for
TSDF process vents. Moreover, because
TSDF with solvent recycling generally
are small operations, any new waste
management units with process vents
would likely have potential VOC
emissions of less than 40 ton/yn thus,
prevention of significant deterioration
(PSD) permit requirements would not
apply. In addition. EPA sent section 3007
information requests to several large
and small TSDF: respondents to' the EPA
section 3007 questionnaires did not
indicate control requirements for
process vents. Several of the facilities
that were asked to provide information
reported requirements for obtaining air
contaminant source operating permits,
but they reported no permit
requirements for controlling process
vent emissions. Therefore, the revised
emission estimates (that are baaed on
site-specific emission data) should
reasonably reflect the current level of
control of process vent emissions.
With respect to those commenters
who argued that other air emission
sources should be controlled instead of
process vents and equipment leaks, it
should be pointed out that section
3004(n) of RCRA requires EPA to
promulgate regulations for the
monitoring and control of air emissions
from hazardous waste TSDF, including
bat not limited to open tanks, surface
impoundments, and landfills, as may be
necessary to protect human health and
the environment Organic emissions are
generated from process vents on
distillation and separation units such as
air strippers, steam strippers, thin-film
evaporators, fractionation columns.
batch distillation units, pot stills, and
condensers and distillate receiving
vessels that vent emissions from these
units. Distillation and separation
processes may be found in solvent
reclamation operations, wastewater
treatment systems, and in other
pretreatment processes. Organic
emissions also are released from
equipment leaks associated with these
processes as well as from nearly all
other hazardous waste management
units.
As discussed in section 1U.D of this
preamble, the EPA chose to develop the
process vent and equipment leak portion
of its TSDF rulemaking as the first phase
of the TSDF air emission rules partly to
prevent uncontrolled air emissions from
LDR treatment technologies since these
technologies were' likely to have
increased use. In addition. EPA already
had control technology information to
support these regulations, and thus
earlier development of these rules was
possible. This is principally because
effective controls now in place under the
CAA to control emissions from the same
types of omission points in chemical
production facilities and petroleum
refinene!i can be applied to reduce the
health risk posed by air emissions from
uncontrolled distillation, fractionation,
thin-film evaporation, solvent
extraction!, and stripping processes and
equipment leaks at TSDF. The EPA has
limited the applicability of today's final
standard! to those types of process
vents for which control techniques are
well developed, i.e., those associated
with processes designed to drive the
organics ;From the waste, such as
distillation, fractionation. thin-film
evaporation, solvent extraction, and
stripping operations.
Organic emissions also are generated
from numerous other sources at TSDF.
Preliminary estimates indicate that
nationwide organic emissions (after
control of process vents associated with
distillation/separation units and
equipment leaks) are about 1.8 million
Mg/yr. The EPA is in the process of
developing standards for these sources
under section 3004(n) of RCRA. and the
standardti.are scheduled for proposal in
1990. Source categories being examined
include tanks, surface impoundments,
container!, and miscellaneous units.
These other TSDF source categories
require different data and engineering
evaluations: thus, standards for these
other sources are on a separate
rulemakiaig schedule. The emissions and
risk analyses needed to support
extension of the process vent standards
to other closed (covered), vented tanks
are also being developed in conjunction
with this future rulemaking. These
include vcmt emissions that are
incidental to the process, such as
emissions caused by loading or by
agitation/ aeration of the waste in a
treatment tank.
The EPA has determined that organic
emissions from TSDF/WSTF process
vents and equipment leaks pose a
significant! risk to human health and the
environment and that section 3004(n)
provides authority to Control TSDF air
emissions from these sources. Therefore.
EPA has decided to take measures to
reduce the atmospheric r»lp»*e of
organic aiir pollutants from these sources
as quickly as possible. The fact that
distillation, fractionation. thin-film
evaporation, solvent extraction, and
stripping processes and equipment leaks
are regulated before other sources is not
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25470 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
germane. There is no reason to delay
these rules while others are under
development
Other commentera criticized the
selection of the source category for
regulation because their process vent
emissions either are already controlled
or are low enough so as not to pose a
threat to human health and the
environment However. EPA's analysis
of process vent emissions and impacts
indicates that for a large segment of the
industry, TSDF process vent emissions
can pose significant environmental and
health risks. These facilities are the
.target of the subpart AA process vent
standards. As discussed in section VLB
of this preamble, the final standards
include facility process vent emission
rate limits designed to avoid control of
facilities where meaningful reductions in
nationwide risk to human health and the
environment cannot be achieved.
Several commentera also criticized the
source category for regulation because
emissions from generators who conduct •
on-site reclamation and off-site
reclaimers with no prior storage (i.e.,
those recycling activities conducted at
facilities not requiring a RCRA permit)
would not be controlled.
The standards being promulgated
today (under section 3004{n() apply only
to waste management facilities that
need authorization to operate under
section 3005 of RCRA. Air emissions
.from subtitle C waste management
facilities that are excluded from RCRA
permit requirements will be subject to
regulation under either the CAA or
RCRA authority as appropriate. Waste
management facilities that fall under the
requirements of subtitle D (i.e.,
nonhazardous waste operations) will
also be subject to regulation under the
CAA. The EPA limited the scope-of the
standards at proposal and in this final
rule to facilities required to have a
permit under RCRA to minimize
disruption to the current permitting
system (i.e., net-expand the permit
universe) and not impose a permit
burden on facilities not otherwise
subject to RCRA permits. Although EPA
is controlling only some sources in this
rule, other sources of significant levels
of air emissions will also be controlled:
i.e.. it is a matter of timing rather than a
decision not (o control these other
sources. This phased regulatory
approach is discussed in section III.C of
this preamble.
RCRA Decision Criteria
Comment: Several commentera
alleged that the standards do not meet
the mandate of RCRA section 3004(n)
because (1) the standards are not
protective in all cases: (2) the standards
are inconsistent with RCRA section
3QQ4(m) that requires treatment
standards based on best demonstrated
available technology (BOAT): and (3)
neither the RCRA statute nor its
legislative history allows consideration
of costs.
.Response; The EPA believes that the
standards promulgated today
•appreciably reduce health risks .that are
presented by air emissions at TSDF and
provide protection to human health and
the environment as required by section
3004(n) of RCRA. for the vast majority of
the air emissions affected by these
standards. The EPA's analysis of
residual cancer risk after
implementation of the standards for
process vents indicates that maximum
individual risk, even at the upper-bound
emission rate, is well within the residual
risk for other standards promulgated
under RCRA. which historically has
been in the range of IX10"' to 1X10~*.
On the other hand, the analysis
indicates that residual cancer risk after
implementing the equipment leak
standards is higher than the residual
risk for other standards promulgated
under RCRA. However. EPA believes
that the equipment leak standards
achieve significant reductions in
emissions and risk and, that after
control, the vast majority of facilities are
well within the risk range of-other RCRA
standards.
As was already described, EPA will
be promulgating regulations to control
TSDF air emissions in phases. Thus, in
Phase m. EPA will be evaluating the
need for additional control (e-g~ control
of individual toxic constituents after
implementation of these standards) for
cases where the risk from air emissions
after implementation of the Phase I and
II standards is higher than desirable.
(This regulatory approach is discussed
in section OLC of this preamble.) During
the interim, permit writers should use
EPA's omnibus permitting authority to
require more stringent controls at
facilities where a high residual risk
remains after implementation of the
standards for volatile organics. The
permitting authority cited by section
3005 of RCRA and codified in
§ 270.32(b)(2) states that permits
"* * * shall contain such terms and
conditions as the Administrator or State
Director determines necessary to protect
human health and the environment"
This section allows permit writers to
require emission controls that are more
stringent than those specified by a
standard.
As has been described above, the
approach that EPA is using to control
TSDF air emissions is to proceed with
promulgation of regulations to control
organic emissions as a class (Phases I
and II) and to follow this with
regulations that would require more
stringent controls for cases where the
risk after implementing the organic
standards remains high. The EPA
believes that this approach will
ultimately be protective of human health
.and the environment for all TSDF air
emissions on a nationwide basis.
The question of whether these
standards implement the requirements
of RCRA section 3004(m) is irrelevant.
Regulations implementing section
3004(m). which is a pretreatment-based
program that defines when hazardous
wastes can be land-disposed, have been
(and will continue to be) separately
promulgated by EPA. For example, see
40 FR 288 (November 7.1966) and 52 FR
25787 (July 8,1987). fa contrast today's
regulations under section 3004(n) of .
RCRA do not specify technology-based
treatment levels for hazardous wastes
but regulate air emissions from
treatment units as necessary to protect.
.human health and the environment.
Therefore, in developing today's rule
EPA has focused on achieving
acceptable levels of health and
environmental protection rather than on
specifying pretreatment levels for
hazardous wastes. The two regulatory
efforts (i-e, 3004(m) and 3004(n) rules)
are integrated and coordinated to the
extent possible to reduce duplicate and
conflicting regulations. Furthermore.
today's rules are designed to ensure that
treatment required under 3Q04(m) is
protective of human health and the
environment
The role of costs as a decision
criterion under RCRA In subtitle C is not
explicitly addressed in the statute. The
EPA's position is that it can consider
cost information as a basis for choosing
among alternatives either (1) when they
all achieve protection of human health
and the environment or (2) for
alternatives that are estimated to
provide substantial reductions in human
health and environmental risks but do
not achieve the historically acceptable
levels of protection under RCRA. when
they are equally protective. However.
EPA does not believe that the cost
burden on industry is a basis for
reducing the stringency of standards
EPA considers necessary to protect
human health and the environment.
Total Organics Approach
Comment: Commenters argued that
applicability should be limited to known
or suspected carcinogens. In addition.
several commentera argued that
applicability of the standards should be
based on volatility and not on total
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Federal Resistor /• Vol. 55. No. 120 / Thursday, June 21, 1990 / Rules and Regulations 25471
petroleum refineries, it is reasonable to
expect similar performance and
efficiency of the technology for
controlling organic emissions at
hazardous waste management units. The
EPA has no reason to believe that the
equipment standards would not be
applicable to TSOF. Moreover, although
EPA has not conducted actual
equipment leak testing at TSDF,
observations of equipment during plant
visits have confirmed that the
assumptions and analyses used in other
equipment leak standards apply to
TSDF as well.
Changes have been made in the final
standards and analyses to incorporate
provisions included in the CAA
standards Ithat reflect the effect of
volatility OB emissions. As is discussed
in section V of this preamble, the LDAR
requirements for.pumps and valves have
been revised to include the light-liquid
provisions in EPA's NSPS for VOC
equipment leaks in the SOCML
Correspondingly, the emission and
health risk analyses have been revised
to reflect this change to the standards.
Additional information on the
appropriateness of the CAA data on the
SOCMI and petroleum refineries is
presented iin the next section.
B. Standards and Applicability
Standards for Accumulator Vessels
Comment: Commenters contended
that the rejguiatory approach of applying
a single standard to the wide varieties of
accumulator vessels irrespective of the
chemical constituents that are present
and the size of the vessel is not
appropriate because the proposed
standards result in the control of
already low emission rates at
disproportionately high costs. Standards
for tanks (whether accumulation or
storage tanks) should be conditioned by
the size of the vessel the vapor pressure
of the material being stored, and the
type of units that pose a risk to human
health and the environment. The EPA's
approach should be similar to or
consistent with the CAA NSPS for
petroleum liquid storage vessels (40 CFR
part 60. subpart Ka). These standards
exempt veusels that store liquids less
than 1.5 psia or that store less than
40.000 gal
Response: Commenters recommending
that the air emission standards be
conditioned by the size of the tank and
the vapor pressure of the material being
stored have misinterpreted the
applicability of the proposed standards.
To clarify 'the applicability of the
standards, the term "product
accumulator vessel" has been dropped
organic content because the relative
amount of organic content by weight
doe* not determine potential air
emission* and subsequent health effects.
Retponto: First it should be pointed
out that ozone presents a threat to
human health and the environment that
warrant* control under RCRA. The EPA
agrees that total organic content may .
not be a completely accurate.gauge of
potential environmental (e.g« ozone) or
health (t.g* cancer) impacts for a source
such a* procts* vent*, but it is a readily
measurable indicator. In addition, the
final rule's substantive control
requirements do apply only to vents and
equipment containing volatile
component*.
Tht final vent standard applies to
certain process vent* emitting organics
if the vent is associated with one of the
processes specified in the rule. A
process vent Is determined to be
affected by the standard if the vent is
part of a hazardous waste distillation.
fractionation. thin-film evaporation.
solvent extraction, or air or steam
stripping unit that manage* wastes with
10 ppmw or more total organic*; this
Includes vent* on tank* (e.g* distillate
receivers or hot wells) if emissions from
the process operation* are vented
through the tank. Total organic content
of the vent stream (Le* the emission* to
the atmosphere) !* not a consideration
In determining process vent
applicability. As public commenters
pbinted out the 10-percent total
organic* concentration cutoff for the
vent stream doe* not limit total
emissions or relate to emissions that
escape capture by existing control
devices and therefore was not Included
in the final rule*.
Furthermore, the process vent*
covered by this rule are typically
associated with distillation/separation
processes used to recycle spent solvents
and other organic chemicals. By
definition, distillation is a process that
consists of driving gas or vapor from
liquid* or solid* by heating and then
condensing the vapotfs) to liquid
products. Waste* treated by distillation
are expected to contain organics that
are driven off in the process. Thus, by
their nature, process vent emissions
contain volatile organic*.
Under the final standards, the term
"organic emissions" is used in lieu of
"volatile organic emissions" to avoid
confusion with "volatile organic
compounds." As at proposal the final
ruin applies to total organics. Because of
the hundreds of hazardous constituents
that could be contained in and
contacted by the equipment covered by
today's rules. EPA recognizes the
potential for the residual risk at some
facilities to remain higher than the
residual risk-for other standards
promulgated under RCRA. Regulations
based only on specific constituents will
therefore be developed, as necessary, in
Phase in of EPA's regulatory approach.
The constituents to be evaluated will
include those reported as being present
in hazardous wastes managed by
existing TSDF for which health effects
have been established through the
development of unit risk factors for
carcinogens and reference doses for
noncarcinogeiis.
A* is discussed in section VI.B of this
preamble, emission potential from
equipment leaks also was considered by
incorporating the light-liquid definition
in the section 111 CAA standards. Light
liquids exhibit much higher volatilities
than do heavy liquids, which are
relatively nonvolatile. Equipment leak
rates and emissions have.been shown to
vary with stream volatility; emissions
from heavy liquids are far less than
those for lighter, more volatile streams.
For example. EPA analyses indicate that
emissions from valves in heavy-liquid
service are more than 30 times lower
than the emissions from valves in light-
liquid service (see the BID. § 4.6). The
EPA examined the emissions and risk
associated with light- and heavy-liquid
waste streams and found that light-
liquid streams are the overwhelming
contributors to both emissions and risk..
Thus, the final standards take into
account the volatility of emissions and
the subsequent impact on health and the
environment
Application of CAA Equipment Leak
Standards
Comment: Several commenters did
not agree that the standards should be
based on the transfer of technology from
the section 112 standards for benzene
(40 CFR, subpart V] because TSDF
waste streams and processes differ from
the chemical plants and petroleum
refineries upon which the CAA
standards are based. . ,
Response; Data used in establishing
the benzene fugitive standards under
CAA section 112 are based on extensive
emission and process data collected at a
variety of petroleum refinery and
SOCMI operating units. Data were
obtained for equipment and chemical
component mixtures that include many
of the same organic compounds that are
treated, stored, and disposed of in
hazardous waste management units.
Because hazardous waste management
units such as distillation units have the
same sources of fugitive organic
emissions (such as pumps and valves)
and handle the same chemicals as do
chemical manufacturing plants and
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Federal Register / Vol. 58. No. 120 / Thursday. June 21, 1990 / Rules and Regulation
25472
from the promulgated rule, including the
equipment definition, and the process
vent definition has been revised to be
specific to the applicable emission
sources. "Process vent" is defined to .
mean "any open-ended pipe or stack
that is vented to the atmosphere either
directly, through a vacuum-producing
system, or through a tank (e.g* distillate
receiver, condenser, bottoms receiver.
surge control tank, separator tank, or
hot well) associated with distillation
fractionation. thin-film evaporation.
solvent extraction, or air or steam
stripping operations." Similarly, the
definition of "vented" has been revised
to specifically exclude the passage of
liquids, gases, or fumes "caused by tank
loading and unloading (working
losses)." Because tank working and
breathing lasses are not considered
process emissions, the comments
concerning vapor pressure and tank size
exemptions are not relevant. (It should
be noted, however, thai EPA intends to
regulate hazardous waste storage tanks,
along with various other TSDF air .
emission sources in the Phase 11, section
3004(n). TSDF air standards now being
developed and evaluated by the
Agency.)
In conducting the impact analysis of
the WSTF/TSDF process vent
standards, EPA considered and took
into account the relative size of WSTF
process units and the wide range of
chemicals processed in the WSTF
industry. For example, three sizes of-
WSTF model units were defined for
analysis of emissions, health risks, and
economic impacts in the final
rulemaking (see section VI.D). In
addition, the final standards for process
venls promulgated by EPA contain
emission rate limits and require controls
only at facilities whose total process
vent emissions are greater than 1.4 kg/h
(3 Ib/h) and Z& Mg/yr (3.1 ton/yr). More
detailed descriptions of the model units
and the process vent emission rate
limits are provided in chapters SJO and
7 A respectively, of the BIO.
Comment: Several commenters
objected to the proposed standard for
process vents that requires a fixed 95-
percent emission reduction. They
believe that the process v«nt standard is
inequitable because some operations
could reduce emissions by 95 percent
and still have higher emissions than
some small uncontrolled operations and
because facilities would have to install
control devices on all condenser and
still vents regardless of emissions or risk
posed to human health or the
environment A few commenters asked
EPA to consider exemptions for small
solvent operations thai have low
emissions and thus nose little health
risk. .-. .
Response: In resoonse to these
comments. EPA estimated the TSDF/
WSTF air quality and health impacts
using updated model unit, emission rate.
and facility throughput data. Although
total facility waste solvent throughputs
were available, the data base did not
contain any information on the number
or capacities of process units at each
site. Therefore, the risk analysis is
based on overall facility operations and
total facility process vent emissions as
opposed to individual process vent
emissions. The impacts analysis results
show that nationwide reductions in
emissions, maximum individual risk
(MIR), and cancer incidence level off
(i.e.. yield only insubstantial incremental
reductions) at a facility emission rate of
about ia Mg/yr 13.1 ton/yr). At a typical
rate of 2JOOO h/yr of operation, this
annual emission rate corresponds to 1.4
kg/h (3 Ib/h) of organic emissions.
Control of facilities with process vent
emissions less than these values does
not result in further reductions of
nationwide MIR or cancer incidence. At
this emission level, larger facilities (ie-
those with uncontrolled emissions
above the emission rate limit) that are
controlled to a 95-percent emission
reduction result in MIR values higher
than the remaining uncontrolled small
facilities (i-e- those with uncontrolled
emissions below the limit). The same
holds true for nationwide cancer
incidence. The reduction in cancer
incidence achieved by controlling
facilities below the limit is not
significant relative to the nationwide
reductions achieved by controlling the
larger facilities.
Consequently, the analysis results
indicate that provision of small facility
emission rate limits of 1.4 kg/h (3 Ib/h)
and i8 Mg/yr (3.1 ton/yr) for process
vent emissions provides essentially the
same level of protection for human
health and the environment (in terms of
risk, incidence, and emissions] as does
covering all facilities. In addition, the
MIR after control is within the range-of
residual risk for other standards
promulgated under RCRA. As a result,
Ike final rule requires control of only
those facilities emitting greater than 1.4
kg/h (3 Ib/h) andZS Mg/yr (3.1 'on/yrj
organic emissions from all process
vents. A more detailed discussion of the
process vent emission rate limits is
contained in chapter 7.0 of the BID.
Because the final standards contain
process vent emission rate limits, it is
anticipated that small solvent recovery
operations would not be substantially
affected by the final process vent
standards. The EPA estimates, based on
the high emission rates and 1985 waste
solvent throughput data, indicate that
about 45 percent of the WSTF identified
in the industry profile will have process
vent emissions of less than 2.8 Mg/yr
(3.1 ton/yr). Consequently, it is expected
that a large number of small facilities
would not be required to install
additional process vent controls.
Selection of 10-Percent Cutoff
Comment: Commenters believed that
the 10-percent level proposed is
comparable to 100.000 ppm and may be
too high, particularly when compared to
the 10.000-ppm level that defines an
equipment leak, and' that EPA should
evaluate the health and environmental
impacts associated with the proposed
limit The 10-percent limit will allow
excessive emissions from leaking
equipment"and is based on costs, not
technical limitations. Commenters. also
argued that the 10-percent limit does not
adequately protect the environment
because emissions could be substantial
if there are numerous leaking
components with relatively dilute
streams and that controls, such as
carbon adsorbers, are available to
capture emissions from dilute streams.
Response: First for clarification, the
10-percent organic content limit for
equipment leaks in no way relates to the
10.000-ppm leak definition. The leak
definition, which is a Method 21
instrument reading used to define when
a leak is detected. 13 discussed in a later
comment As proposed, the 10-percent
total organics cutoff level for
applicability of the standards covered
both equipment leak (fugitive) emissions
and process vent emissions. Control
technologies for fugitive emissions
comprise the use of control equipment,
inspection of equipment and repair
programs to limit or reduce emissions
from leaking equipment. These control
technologies have been studied and
evaluated for equipment containing
fluids with more than 10 percent
organics (EPA-iSO/3-80-32b, EPA-^iSO/
3-80-33b. EPA-450/3-62-010. and EPA-
450/3-88-002). The 10-percent criterion
was chosen in EPA's original benzene/
• SOCMI studies to focus the analyses on
air emissions from equipment containing
relatively concentrated organics and
presumably having the greatest potential
for air emissions. Available data from
the original benzene/SOCMl studies do
not suggest that fugitive emissions from
leaking equipment (e.g.. pumps and
valves) handling streams containing loss
than 10 percent organics are significjnt
or that the 10-percent cutoff allows
excessive emissions from dilute streams
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Federal Register / Vol. 55. No. 120 / Thursday, June 21. 1990 / Rules and Regulations 25473
However, to reavaluate this would
require Mveral years to conduct field
studies to collect and analyze additional
emissions and control effectiveness data
tot equipment leaks. Because available
data support the need for. and
effectiveness of. standards for
equipment handling streams containing
at least 10 percent organics. the EPA
doe* not believe that a delay in
ruletaaking to assess emissions and
controls for equipment handling streams
containing less than 10 percent organics
Is warranted.
The effectiveness of fugitive emission
control technologies has been
-. thoroughly evaluated for equipment.
containing fluids with at least 10 percent
organic*, and fugitive emission
standards have been proposed or
established under both sections 111 and
•112 of (he CAA. (See 48 FR1138. January
5,1961: 48 FR 1165. January 5.1981:48
FR 273. January 4.1983; 48 FR 37538.
August 18.1983; 48 FR 48328. October 18.
, 1963:49FR22S96.May30.1984:49FR
Z3408. June 0.1984: and 49 FR 23522.
June 8.1964.) As elaborated in these
rulemakings. a 10-percent cutoff deals
with (he air emissions from equipment
most likely to cause significant human
health and environmental harm.
With regard to process vent
emissions. EPA agrees with the
coounanter. Emission test data show
that the 10-percent cutoff potentially
may allow significant emissions from
process vents on a mass-per-unit-time
basis (e4* kg per hour or Mg per yr). As
public coaunenters pointed out the 10-
percent cutoff for process vents does not
limit total emissions, nor does it relate
to emissions that escape capture by
existing control devices. Therefore the
10-percent cutoff may not be
appropriate: as a result. EPA has
eliminated the 10-percent cutoff as it
applies to process vents. The EPA
believes that an emission rate limit more
effectively relates to emissions.
emission potential, and health risks than
does a 10-percent organic concentration
cutoff. Accordingly, a health-risk-based
facility process vent emission rate limit
has been added to the final rules in lieu
of the 10-percent cutoff.
Because the emission rate limits (3 lb/
h and 3.1 ton/yr) provide health-based
limits. EPA considered dropping
completely the organic content criterion
(I.e.. at least 10 percent total organics).
However. EPA decided not to eliminate
completely the organic content criterion
because it is not dear that the same
controls can be applied to very low
concentration streams as can be applied
to the higher concentration streams that
generally are associated with emission
rates greater than the limits. For low-
concentration streams. EPA questions
whether controls are needed on a
national or generic basis, but is unable
to resolve this question at this time.
Thus. EPA decided to defer controlling
very low concentration streams until it
is able to better characterize and assess
these streams and the appropriate
controls.
Once EPA decided to consider
facilities that manage very low
concentration organic wastes as a
separate category, there remained the
problem of determining the appropriate
criterion. The EPA examined existing
data on air strippers, the treatment
device most commonly used with low-
concentration streams; it appeared that
the quantity of emissions and the risk
associated with air strippers treating
_ streams with concentrations below 10
' ppmw may be relatively small, thus
minimizing the potential harm of '
deferring control until a later time.
Examples of facilities managing low-
concentration wastes are sites where
ground water js undergoing remedial
action under CERCLA or corrective
action pursuant to RCRA. Based on the
limited set of precise data available, and
the comments that the 10-percent
criterion was too high. EPA determined
that an appropriate criterion would be
10 ppm total organics in the waste by
weight
The 10-ppmw criterion is not an
exemption from regulation: it is intended
only as a way for EPA to divide the air
regulations into phases. The EPA is
deferring action on very low
concentration streams (i.e., ones with
less than 10 ppmw total organic content)
from the final rule today but will
evaluate and announce a decision later
on whether to regulate these waste
streams.
Exemptions
Comment: Several commenters
• disagreed with EPA's interpretation that
the definition of "totally enclosed
treatment units" (which are exempt from
regulation) may in certain circumstances
include on-site treatment units that use
engineered controls to prevent the
release of emissions. One commenter
stated that on-site treatment facilities
directly tied with process equipment
have the same potential for emissions as
do other sources not exempted by the
proposed regulation.
Response: This rule does not create or
modify any exemption for totally
enclosed treatment facilities; rather, the
existing definition of an exemption for
totally enclosed treatment facilities
remains in effect and existing
regulatory interpretations remain in
effect as well. Although the preamble to
the proposed rule repeated the existing
definition, at also contained a request for
comments on an interpretation of the
totally enclosed facility exemption
whereby the "use of effective controls
such as those required by the proposed
standards" would meet the criteria of 40
CFR 260.10, Upon consideration of the
comments, EPA has determined that this
interpretation would have conflicted
with the reijulatory definition and
previous interpretations of the
exemption and. therefore, has decided to
withdraw it
* As presented in the preamble to the
proposed rule, under 40 CFR 2G4.1(g)(5)
and 40 CFR 265.1(c)(9), totally enclosed
treatment facilities are exempt from
RCRA regulation. A "totally enclosed
treatment facility" is a facility treating
hazardous waste that is "directly
connected to an industrial production
process and which is constructed and
operated in, a manner which prevents
the release of any hazardous waste or
constituent thereof into the environment •
during treatment" (40 CFR 260.10).
Therefore, as stated in the proposal.
preamble, process equipment designed
to release stir emissions are not "totally
enclosed."
The EPA agrees with the commenter
that on-site treatment facilities
associated with process equipment
generally are designed to release air
emissions and. thus, are not "totally
enclosed." "The EPA specifically stated
this in the preamble to the proposed
rule. To be considered "totally
enclosed." units must meet the test of
preventing the release of any hazardous
constituent from the unit not only on a
routine basis but also during a process
upset Thus; the risks from these units
are expected to be less than from units
that are nol! totally enclosed.
Comment: Commenters stated that the
exemption for tanks storing or treating
hazardous wastes that are emptied
every 90 days and that meet the tank
standards of'40 CFR 262.34 is not
justified based on risk, as RCRA
requires. The exclusion of less-than-90-
day storage! tanks from air emission
control requirements will increase the
use of the 90-day storage exemption and
the resultant air emissions.
Response: In 40 CFR part 270,
hazardous waste generators who
accumulate waste on site in containers
or tanks for less than the time periods
provided in §262.34 are specifically
excluded from RCRA permitting
requirements. To qualify for the
exclusions In §262.34. generators who
accumulate hazardous waste on site for
up to 90 days must comply with 40 CFR
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Federal Register / Vol. 55. No. 120'/ Thursday. June 21. 1990 / Rules and Regulation
265. subpart! or J (depending on
whether the waste is accumulated in
containers or tanks) and with other
requirements specified in §262J4.
Small-quantity generators (i.e.,
generators who generate more than 100
kilograms but less than 1.000 kilograms
per calendar month) are allowed to
accumulate waste on site for up to 180
day's or. if they must ship wasteoff site
for a distance of 200 miles or more, and
if they meet certain other requirements,
set out in § 28234, for up to 270 days.
The promulgated regulation does not
create a new exemption for 90-day
accumulation, nor does it modify the
existing regulation. As the commenter
notes. EPA is considering what changes
(if any) should be made to §262.34 (the
"90-day rule") under a separate
rulemaking (51FR 25487. July 14.1986).
As part of that effort EPA currently is
evaluating whether air emissions from
these and other accumulator tanks.
mentioned above, at the generator site
should be subject to additional control
requirements. Preliminary analysis'
indicates that 90-day tanks and
containers may have significant organic
air emissions: consequently, as part of
the second phase of TSDF air emission
regulations. EPA is considering
proposing to modify the exemption fo
require that 90-day tanks meet the
control requirements of the.Phase I and
I! standards. (The muitiphased
standards development approach for
regulating organic air emissions is
discussed in section HLC of this
preamble.) Until a final decision is made
on regulating the emissions from these
units, they will not be subject to
additional controls. However. EPA does
not believe that more generators wilt
use the 90-day exemption if air emission
controls are not imposed on these units.
Those generators who are eligible for
inclusion under §262.34 are probably
already taking advantage of the •
provision now by storing their
hazardous wastes for less than 90 days.
LOAR Program
, Comment: Several commenters
criticized the incorporation of the
national emission standard for
hazardous air pollutants (NESHAP) for
benzene because of differences in scope
from the SOCMI NSPS in that (1) the
NSPS distinguishes between light and
heavy liquids and the proposed
standards based on the benzene
NESHAP do not: (2) the NSPS does not
require testing of all SOCMI units
because process fluid vapor pressure is
the overriding consideration in
predicting leak frequencies and leak
rates ((he proposed standards
incorporating the NESHAP do not
recognize vapor pressure and require
testing of all SOCMI units); and (3) the
NSPS exempts facilities from routine
fugitive emission monitoring, inspection,
and repair provisions if a. heavy-liquid
product from a heavy-liquid raw
material is produced and limits
monitoring of equipment in heavy-liquid
service only to where there is evidence
of a potential leak. -
Response: The EPA agrees with the
commenters that the provisions for light
and heavy liquids in the SOCMI NSPS
should be incorporated in the section
3004(n) standards, even though the
•subpart V NESHAP does not contain the
distinction. No distinction was made for
the benzene NESHAP because benzene
is a light liquid. By their nature, heavy
liquids exhibit much lower volatilities
than do light liquids and because
equipment leak emissions have been
shown to vary with stream volatility.
emissions for heavy liquids are less than
those for lighter and more volatile ones.
As previously noted. EPA analyses have
determined that the emission rate for a
valve in heavy-liquid service is more
than 30 times less than the emission rate
for a valve in light-liquid service. In
response to these comments. EPA
examined the emission and risk
associated with light- and heavy-liquid
waste streams and found that light-
liquid streams are the overwhelming
contributors to both emissions and risk.
Therefore, a routine LDAR monthly
inspection is not necessary for heavy
liquids.
Thus, the final regulations have been
changed to incorporate the light/heavy-
liquid service provisions 'for pumps and
valves (40 CFR parts 264 and 265.
subpart BB, §§264.1052,264.1057
265.1052. and 265.1057). Equipment is in
light-liquid service if the vapor pressure
of one or more of the components is
greater than 0.3 kPa at 20 °C, if the total
concentration of the pure components
having a vapor pressure greater than 0.3
kPa at 20 *C is equal to or greater than
20 percent by weight and if the fluid is a
liquid at operating conditions. The 0.3-
kPa vapor pressure criterion is based on
fugitive emission data gathered in
various EPA and industry studies (EPA-
4SO/3-82-010). Equipment processing
organic liquids with vapor pressures
above 0.3 kPa leaked at significantly
higher rates and frequencies than did
equipment processing streams with
vapor pressures below 0.3 kPa.
Therefore. EPA elected to exempt
equipment processing lower vapor
pressure substances (i.e., heavy liquids)
from the routine LOAR requirements of
the standards. In addition, monitoring of
equipment in heavy-liquid service is
required only where there is evidence
by visual audible olfactory, or any other
detection method of a potential leak.
Comment: Several commenters asked
EPA to consider exemptions from
fugitive emission monitoring for small
facilities based on volume (as was done
in the benzene NESHAP and the SOCM!
NSPS), emission threshold, product
applicability threshold or equipment
component count or equipment size. In
support the commenters pointed to
similar exemptions in the CAA rules
that were in the proposed standards.
Response: The commenters suggest
that EPA consider other exemptions for
fugitive emission monitoring that are
applied in the benzene NESHAP or
SOCMI NSPS (e.g.. small facilities with
the design capacity to produce less than
1,000 Mg/yr). The EPA recognizes that
estimated emissions and health risks
from small facilities-should be
considered in the final rules. With
regard to the SOCMI NSPS small-facility
exemption, the cutoff was based on a
cost-effectiveness analysis. Under
section 111 of the CAA. EPA may
exempt units where costs of the
standards are unreasonably high in
comparison to the emission reduction
achievable. Under RCRA. the statutory
criterion is protection of human health
and the environment. Therefore, any
cutoff for RCRA standards must be risk-
based. Cost effectiveness is only a
relevant factor for choosing among
alternatives either (1) when they all
achieve protection of human health and
the environment or (2) for alternatives
that are estimated to provide substantial
reductions in human health and
environmental risks but do not achieve
the historically acceptable levels of
protection under RCRA. when they are
equally protective.
In the benzene NESHAP (49 FR 23498.
June 8.1984), EPA concluded that
control of units producing less than 1,000
Mg/yr did not warrant control based on
the small health-risk potential. The
benzene standards, however, did not
have to deal with the many different
pollutants covered by the TSDF process
vent and equipment leak standards,
some of which are much more
carcinogenic than benzene. In addition
to unit size (or throughput), fugitive
emissions are also a function of the
chemical characteristics of the
hazardous wastes being handled.
• Typically. TSDF have a variety of
hazardous waste management processes
(e.g., container storage, tank storage.
treatment tanks, incinerators, injection
wells, and terminal loading operations)
located at the same facility, all of which
have associated pumps, valves.
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Federal Register / VoL 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 25475
closed-venl! systems for these discharges
on a site-specific basis.
The LDAR program transferred from
the CAA standards does not exempt
pressure relief devices in light liquid or
heavy liquid service and flanges, but
requires foirmal monitoring of these
sources if operators see. smell, or hear
discharges. The EPA considers that this
is She most practical way to manage
these sources. Although scheduled
routine maintenance may be a way of
avoiding the need for formal monitoring.
it may not be c successful method for all
sites In eliminating leaks due to the
numerous variables affecting leak
occurrence. For example, flanges may
become fugitive emission sources when
leakage occurs due to improperly chosen
gaskets, poorly assembled flanges, or
thermal stress resulting in the
deformation of the seal between the
flange facet. In these situations.
operators will be able to detect such
leaks by oiijht. smelt or sound. Support •
for this approach was presented and
evaluated in developing several CAA
rulemakinss (EPA-450/3-63-416b. EPA-
450/3-00-0330, and EPA-450/3-81-
OlSb).
Comments One commenter stated that
the LDAR program should require
preventive maintenance, such as the
periodic replacement of valve packings,
before waiting for the valve to fail. In
support, thn commenter argued that
EPA's own data show that directed
maintenani:e could reduce leaks from
valves to below 10,000 ppm. The
commenter also criticized the 10,000-
ppm leak definition as being too high
and states that EPA must consider the
levei is terns of the health effects.
Response The key criterion for
selecting a leak definition is the overall
mass emisiiion reduction demonstrated
to be achievable. The EPA has not
concluded that an effective lower leak
definition has been demonstrated. Most
data developed for current CAA
standards CEPA-450/3-02-010) on leak
repair effectiveness have applied 10,000
ppm as the leak definition and therefore
do not indicate the effectiveness of
repair for leak definitions between 1,000
and 10.000 ppm. Even though limited
data between these values were
collected for support of CAA standards,
they are not sufficient to support a leak
definition below 10.000 ppm. Data are
insufficienl: to determine at what
screening value maintenance efforts
begin to reiiult in increased emissions.
As the commenter noted, although
there is some evidence that directed
maintenance is more effective, available
data are insufficient to serve as a basis
•Hi ' '
sampling connections, eta. and
therefor*, fugitive emissions from
equipment leaks. Also, several different
types of hazardous wast* typically are
managed at • facility. Because of the
various factors affecting facility fugitive
emissions from equipment leaks (e.g,
equipment teak emissions an a function
of component counts rather than waste
throughput), it would be very difficult to
determine a small-facility exemption
bued OB risk bat expressed as volume
throughput. For these reasons. EPA did
not include exemptions for fugitive
emission monitoring such as those
applied to the benzene NESHAP or
SOCMINSP3 (Le, small process units
with the design capacity to produce less
thealdOOMg/yr).
Comment: Commenters stated that the
TSDF fugitive emission standards
should conform to the benzene
NESHAP. which allows exemptions for
vacuum systems, systems with no
emissions, and systems whose leakage
rat* is demonstrated to be below 2
percent.
Retpon**:Tb» EPA has included in
the final TSDF standards (§ f 284.1050
and 283.1050) the exemption for
equipment "in vacuum service" found in
the benzene NESHAP (40 CFR part 61,
jubpert V. (51342-1). Also included are
the identification requirement
contained la the regulation. "In vacuum
service" means that equipment is
operating at an Internal pressure that is
atleast 5 kPa below-ambient pressure.
The EPA haa concluded that it is
unnecessary to cover equipment "In
vacaaa service" because such
equipment has little if any potential for
emissions and* therefor*, does not pots
a threat to human health and the
environment. Accordingly, this
equipment has been excluded from the
equipment leak fugitive emission
requirements.
The proposed standards stated that
owners and operators of facilities
subject to the provisions of the rule must
comply with the requirements of 40 CFR
pert 61. subpart V (equipment leak
standards for hazardous air pollutants),
except as provided in the rule itself. The
provisions of the proposed rule did not
exclude IS 61243-1 and 01243-2
(•Jternative standards for valves in
VHAP service), and the alternative
standards have been incorporated as
i 1264.1001.284.1002.205.1061. and
265.1062 of the fine! rule. Therefore, an
owner or operator may elect to have all
valve* within e TSDF hazardous waste
management unit comply with an
alternative standard that allows a
percentage of valves leaking of equal to
or less than 2 percent (§1264.1061 and
265.1061). or may elect for all valves
within a hazardous waste management
unit to comply with one of the
alternative work practices specified in
paragraphs (b) (2) and (3) of f 1264.1062
and 265.1062.
Comment: One commenter suggested
that releases-from pressure relief
devices is gas service should be
directed te control equipment at least
equal its performance to those for other
process sources or an alternative means
provided to prevent ea uncontrolled
discharge. According to the commenter.
rupture discs or closed-vent systems
restrict small teaks but not major
releases; a closed-vent system
connected to a control device is needed
to capture releases. The commenter
concluded that EPA ha* provided no
data to support exempting flanges and
pressure relief devices in liquid service
from LDAR requirements and should not.
rely on operators to see, hear or smell
teaks from this equipment
Response: Pressure relief devices
allow .the release of vapors or liquids
until system pressure is reduced to the
normal operating level The standards
are geared toward control of routine
low-level equipment teaks that may
occur independently of emergency
discharges. Pressure relief discharges
are as entirely different source of
emissions than equipment leak* or
process vents and were not covered in
the original equipment leak standards
under the CAA. The new subpart BB
rules require that pressure relief devices
in gas service be tested annually by
Method 21 (and within 5 days of any
relief discharge) to ensure that the
device is maintained at no detectable
emissions by means of a rupture disc. In
addition, because a pressure discharge
constitutes a process upset that is many
case* can lead to hazardous wast*
management unit downtime and might
also pose a risk to workers, a facility
has the incentive to tn
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Federal Register / Vol 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
for requiring directed maintenance for
ail sources.
(Note: In "directed maintenance" efforts,
the tightening of the packing it monitored
simultaneously end is continued only to the
extent that it reduces emissions. In contrast.
"undirected" repair means repairs such as
tightening valve packings without
simultaneously monitoring the result to
determine whether the repair is increasing or
decreasing emissions.)
The EPA's rationale for selecting the
10.000-ppmv leak definition and for not
requiring directed maintenance under
the CAA LDAR program also has been
discussed in the proposal and
promulgation BHDs for benzene
emissions from coke by-product'
recovery plants (SPA-450/3-63-016 a
and H for SOCMI fugitive emissions
(EPA-450/3-80-033 a and b). for
petroleum refinery fugitive emissions
(EPA-450/3-41-015 a and b). and for.
benzene fugitive emissions (EPA-450/3-
80-032 a and b). (See also the "Response
to Public Comments on EPA's Listing of
Benzene Under section 112" (EPA-4SO/
5-82-003) "Fugitive Emission Sources of
Organic Compounds—Additional •
Information on Emissions. Emission
Reductions, and Costs" (EPA-450/3-82-
010). and EPA's "Response to Petition
for Reconsideration" (50 FR 34144.
August 23.1985).)
The commenter also criticizes EPA for
not reanalyzing the health effects of the
10,000-ppmv level before applying the
limit to TSDF under RCRA. Because
section 112 of the CAA and 3004(n) of
RCRA are comparable in their
recognition of health risk aa the
predominant decision factor, the EPA
believes that the leak definition has
been adequately analyzed under the
CAA and that further evaluation is not
needed prior to transferring it as part of
the LDAR program under RCRA. It must
also be pointed out that transfer of the
CAA equipment leak standards is only
the first phase of EPA's regulatory
actions related to control of TSDF air
emissions. In thisphase. EPA transferred
a known technology to reduce
emissions. If new data show that a
lower leak definition is appropriate.
EPA will then consider whether it is
appropriate to change the rules.
C, Control Technology
Feasibility of Condensers
Comment: Several commenters did
not agree that condensers provide a
feasible means of meeting the 95-percent
emission reduction requirement for
affected process vents in the proposed
standard. Problems cited by the
commenters limiting the application of
condensers included the presence of
water in the waste stream in the TSDF
portion of the facility and the wide
variety of waste solvents treated by
WSTF. One commenter claimed that a
higher emission reduction efficiency
could be achieved through an increased
condenser area or a different condenser
refrigerant with a lower boiling point
than was used in the analysis for the
proposal.
•Response: In response to this
comment, the feasibility of using
condensers to achieve a 9&percent
reduction of emissions from WSTF
process vent streams was reexamined
using a state-of-the-art chemical
engineering computerized process
simulator that includes a refrigeration
unit capable of producing a coolant at a
temperature as low as -29 *C (-20 *F)
and a primary water-cooled heat
exchanger to remove water vapor from
the vent stream.
A variety of chemical constituents
and operating conditions were
examined to determine the organic.
removal efficiency achievable through
condensation. The constituents selected
for the condenser analysis (toluene.
methyl ethyl ketonejMEK). 1.1.1
trichloroethane (TCE), and methylene
chloride) were judged to be
representative of the solvents recycled
by the WSTF industry, based on a *
review of a National Association of
Solvent Recyclers (NASR) survey.
numerous site-specific plant trip reports.
and responses to EPA section 3007
information requests. Three of these four
solvents had been used in the proposal
analysis: methylene chloride, at the
lower end of the solvent boiling point
range (!.&. more difficult to condense),
was added to provide a broader range of
volatilities for the condenser analysis. A
total of 40 WSTF model unit cases
consisting of combinations of organic
emission rates, concentrations, and
exhaust gas flows representing the wide
range of operating conditions found at
WSTF were included in the condenser
analysis.
The results of the condenser analysis
indicate that condensers cannot
universally achieve a 95-percent
emission reduction when applied to
WSTF process vents. With regard to
increasing organic removal efficiency by
increasing condenser area or changing
the condenser refrigerant, the analysis
shows that there are technical limits on
condenser efficiency that go beyond the
condenser design and operating
parameters. Specifically, the physical
properties of the solvents being
condensed and the solvent
concentration in the gas stream affect
condenser efficiency. In some situations.
the partial pressure of the organic
constituent in the vapor phase was too
low to support a liquid phase
thermodynamically regardless of the
refrigerant used or condensation area:
as a result no appreciable condensation
could occur. Therefore, the analysis
shows that condensers are not
universally applicable to the control of
WSTF process vents. However, the
facility process vent emission reduction
requirements are not based solely on the
use of condensers; carbon adsorption
and incinerators/flares are capable of
attaining a 95-percent control efficiency
for all WSTF organics, including cases
where condensation is not feasible. In
summary, although condensers may not
by themselves achieve a 95-percent
emission reduction at all process vents.
condensers do provide a practical and
economic means of reducing process
vent emissions, and these devices will
likely be the initial choice of control
technology for cases where
condensation is feasible.
Feasibility of Carbon Adsorbers
Comment: Several commenters
objected to the-identification of carbon
adsorption as a control technique
because of technical and safety
concerns related to the application of
carbon adsorbers to low organic
concentration and multicomponent
solvent streams. However, one
commenter did cite authorities that
support a 98-percent removal for this
type of control device.
Response! First it should be noted that
carbon adsorption is one of several
control technologies that could be used
to attain the standards. Other
technologies include condensers, flares.
incinerators, and any other device that
the owner or operator can show will
meet the standards.
Regarding carbon adsorption
applications. EPA acknowledges that
safety is an important consideration, but
concludes that any safety problems can
be avoided through proper design and
sorbent selection. Multicomponent
systems potentially can lead to
excessive heat buildup (hot spots).
particularly in large carbon beds with
low flow rates, which in turn can lead to
fire and explosion hazards.
Multicomponent vapor streams can also
lead to reduced removal efficiencies for
particular components. However, these
technical and efficiency problems can
be overcome through proper design.
operation, and maintenance.
In general, coal-based carbons have
fewer heat'generation problems than do
wood-based carbons, and small
diameter beds promote good heat
transfer. The bed must be designed with
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Federal Register / VoL 55. No. 120 / Thursday, June 21. 1990 / Rules and Regulations 25477
consideration for the least heat
adsorbent (or fastest) component in the
mix. as well as the component
concentrations and overall flow rate.
Other considerations include component
interaction, gas stream relative
humidity, and close monitoring of the
bed effluent for breakthrough.
In response to these comments, the
EPA examined carbon adsorption
design, operation, and performance data
from a number of plants in a wide
variety of industries; in addition, the
EPA has reexamined. with the help of
carbon manufacturers and custom
carbon adsorption equipment designers.
the elements that affect carbon
adsorption efficiency. This analysis has
reinforced EPA's original conclusion
that a well-designed, -operated, and -
maintained adsorption system can
achieve a 93-percent control efficiency
for all organic* under a wide variety of
stream conditions over both short-term
and long-term averaging periods. The
major factors affecting performance of
an adsorption unit are temperature.
humidity, organic* concentration.
volumetric flow rate "channelling"
(nonunifonn flow through the carbon
bed}, regeneration practices, and
changes in the relative concentrations of
the organic* admitted to the adsorption
system. The WSTF/TSDF process vent
stream characteristics an typically well
within design limits in terms of gas
temperature, pressure, and velocity for
carbon adsorbers. For example, the bed
adsorption rate decreases sharply when
gas temperatures are above 38 *C (100
"FJ; a review of plant field data showed
no high-temperature streams in WSTF/
TSDF process vents. If high-temperature
gas streams era encountered, the gas
stream can be cooled prior to entering
the carbon bed. Also, gas velocity
entering the carbon bed should be low
to allow time for adsorption to take
place. The WSTF/TSDF stream flows
are typically quite low and, as a result,
bed depth should not be excessive.
Therefore. EPA concluded that, for
WSTF/TSDF process vent streams.
carbon adsorption can reasonably be
expected to achieve a 95-percent control
efficiency provided the adsorber is
supplied with an adequate quantity of
high-quality activated carbon, the gas
strea'm receives appropriate
conditioning (e.g~ cooling or filtering)
before entering the carbon bed. and the
carbon beds are regenerated or replaced
before breakthrough. The data gathered
in the EPA carbon adsorption
performance study do not support a
higher control efficiency (I.e.. 98 percent
as opposed to 95 percent) for carbon
adsorption unite applied to WSTF/TSDF
process vents on an industrywide basis.
particularly in light of the design
considerations related to controlling
multicomponent vent streams when the
organic mix is subject to frequent
change.
When carbon adsorption is used to
remove organics from a gas stream, the
carbon must periodically be replaced or
regenerated when the capacity of the
carbon to adsorb- organics is reached.
When either regeneration or removal of
carbon takes place, there is an
opportunity for organics to be released
to the atmosphere unless the carbon
removal or regeneration is carried out •
under controlled conditions. There
would be no environmental benefit in
removing organics from an exhaust gas
stream using adsorption onto activated
carbon if the organics are subsequently
released to the atmosphere during
desorpUon or during carbon disposal
The EPA therefore expects that owners
or operators of TSDF using carbon
adsorption systems to control organic
emissions take steps to ensure that
proper emission control of regenerated
or disposed carbon occurs. For on-sits
regenerable carbon adsorption systems.
the owner or operator must account for
the emission control of the desorption
and/or disposal process in the control
efficiency determination. In the case of
off-site regeneration or disposal the
owner or operator should supply a
certification, to be placed in the
operating file of the TSDF. that all
carbon removed from a carbon
adsorption system used to comply with
subparta AA and BB is either (1)
regenerated or reactivated by a process
that prevents the release of organics to
the atmosphere. (Note: The EPA
interprets "prevents" as used in this
paragraph to include .the application of
effective control devices such as those
required by these rules) or (2)
incinerated in a device that meets the
performance standards of subpart 0.
Feasibility of Using Controls in Series
Comment: One commenter stated that
EPA should evaluate carbon adsorption
in series with a condenser because
condensers work best with concentrated
streams and carbon adsorbers with low
concentration streams. The two systems
together could yield an overall
efficiency of 99 percent, even if each
unit were only 90-percent effective.
Response: As discussed in section
VILE, the MIR from process vents after
control (i.e.. 4X10"1) is within the range
of what has been considered acceptable
under RCRA. Consequently, no further
control for process vents was
considered necessary at this time.
Nonetheless, in response to these
comments,, EPA evaluated the feasibility
of using a carbon adsorber in series with
a eondensw to control WSTF/TSDF
process vent emissions. The objective of
the analysis was to determine if the
combination of control devices would
yield an overall control efficiency
greater than the 95 percent that is
achiavablo using a single device. For
example, if a 99-percent overall control
efficiency Is desired and it is assumed
that the carbon adsorber is capable of
achieving a 95-percent control efficiency
in all casei (a reasonable assumption
for a properly designed, operated, and
maintained system), then a minimum
efficiency of 80 percent would be
required for the condenser followed in
series by the 95-percent efficient carbon
bed. Howitver. in the EPA condenser
analysis conducted for the WSTF model
unit cases,,.an 80-percent control was not
achieved i'or IB of the 40 cases
examined (See section 7.7 of the BID.)
In 7 of the 40 cases, the analysis showed
that no appreciable condensation would
occur because of low solvent
concentration and/or the high volatility
of some solvents. Because the model
unit cases are considered representative
of current WSTF operations. EPA does
not believe that die use of carbon
adsorption and condensation in series to
achieve a 99-percent control is a
technically feasible control option on an
industrywide basis. Such control
strategies win be considered further for
Phase ffl standards for individual
facilities, if necessary, should additional
analyses reveal unexpectedly high risks
in specific: situations.
Feasibility of Flares
Comment: Several commenters
objected to the use of flares at recycling
facilities because of technical and safety
concerns. A few commenters cite the
requirement of a constant emission
source lot efficient flare operation, and
other commenters contend that flares
are not suitable on intermittent sources
or the low-level emissions typical of
recycling operations. With regard to
safety, flares present the danger of
explosion, especially if they
malfunction: according to one
commentor. many State laws prohibit
the use of flares at recycling facilities.
Response: Available information on
WSTF operations indicates that
condensers, carbon adsorbers, and
incinerators are the most widely used
control technologies: therefore, they are
expected to be the technologies of
choice to reduce organic emissions at
WSTF. The final technical analyses
show that a 95-percent control efficiency
can be achieved with secondary
-------
25478 Federal Register / VoL 55. No. 320 / Thursday. June 21. J990 / Rules and Regulations
condensers for many WSTF process
vents or with carbon adsorbers in cases
where secondary condensers are not
feasible. Flares are not required
controls, but are an available option for
facilities so equipped provided they
meet the criteria established in the final
rules. Where State laws prohibit the use
of flares at recycling facilities, other
technologies are available.
With regard to the safety of flares, •
EPA has determined that the use of
flares to combust organic emissions
from TSDF process vents would not
create safety problems if engineering
precautions such as those used in the
SOCMI are taken in the design and
operation of the system. The following
are typical engineering precautions.
First the flare should not be located in
such proximity to a process unit being
vented that ignition of vapors is « threat
to safety. In the analysis conducted for
this standard at proposal, it was
assumed that the flare would be located
as far as 122 meters from the process
unit Second, controls such as a fluid •
seal or flame arrester are available that
would prevent flashback. These safety
precautions were considered in EPA's
analysis for the proposed rule. Finally,
the use of a purge gas, such as nitrogen.
plant fuel gas. or natural gas and/or the
careful control of total volumetric flow
to the flan would prevent flashback in
the flare stack caused by low off-gas
flow.
Feasibility of LDAR Program
Comment: One eommenter opposed
the fugitive standards as proposed
because they failed to require the proper
technology to control releases from
pumps and valves. The commenter
claimed that the standards should
require a 100-percent control, based on
what available technology (e.g., sealed
bellows valves, sealless pumps, or dual
mechanical seals for pumps) can
achieve. According to the commenter,
superior emission controls cannot be
rejected under RCRA-solely on the basis
of cost effectiveness.
Response: Control technologies for
fugitive emissions from equipment leaks,
as required by the proposed standards,
include the use of control equipment
inspection of process equipment and
repair programs to limit or reduce
emissions from leaking equipment that
handle streams with total organic
concentrations of greater than 10
percent These control technologies have
been studied and evaluated extensively
by EPA for equipment containing fluids
with 10 percent or more prganics and
are similar to those required by national
emission standards for chemical.
petrochemical and refining facilities
under the CAA.
A monthly LDAR program was
proposed for WSTF/TSDF pumps and
valves. Based on results of the EPA's
LDAR model, once a monthly monitoring
plan is la place, emission reductions of
73 percent and 59 percent can be
expected for valves in gas and light
liquid service, respectively, and a 61-
percent reduction hi emissions can be
achieved for pumps in light-liquid
service. For compressors, the use of
mechanical seals .with barrier fluid
systems and control of degassing vents
(95 percent) an required, although
compressors an not expected to be
commonly used at WSTF/TSDF. The
usa of control equipment (rupture disc
systems or closed-vent systems to flares
or incinerators) is the technical basis for
control of pressure relief devices. Closed
purge sampling is the required control
for sampling connection systems and is
the most stringent feasible control. For
open-ended valves or Sines the use of
caps, plugs, or any other equipment that
will close the open end is required: these
are the most stringent controls possible.
Flanges and pressure nlief devices in
liquid service an excluded from the
routine LDAR requirements but must be
monitored if leaks an indicated. For
operations such as those expected at
WSTF/TSDF, total reductions in fugitive
•emissions from equipment leaks of
almost 75 percent an estimated for the
entin program.
The EPA agrees with the commenter
that the level of control required by the
LDAR program does not result in the
highest level of control that could be
achieved for fugitive emissions from
pumps and valves in certain
applications. In some cases, there an
.more stringent technologically feasible
controls. For example, leakless
equipment for valves, such as
diaphragm and sealed bellows valves.
when usable, eliminates the seals that
allow fugitive emissions: thus, control
efficiencies in such cases are virtually
100 percent as long as the valve does not
fail In appropriate circumstances,
pumps can be controlled by dual
mechanical seals that would capture
nearly all fugitive emissions. An overall
control efficiency of 95 percent could be
achieved with dual mechanical seals
based on venting of the degassing
reservoir to a control device.
With regard to leakless valves, the
applicability of these types of valves is
limited for TSDF, as noted by EPA in the
proposal preamble. The design problems
associated with diaphragm valves are
the temperature and pressun limitations
of the elastomer used for the diaphragm.
It has been found that both temperature
extremes and process liquids tend to
damage or destroy the diaphragm in the
valve. Also, operating pressure
constraints will limit the application of
diaphragm valves to low-pressure
operations such as pumping and product
storage facilities.
Then an two main disadvantages to
sealed bellows valves. First they are,
for the most part only available
commercially in configurations that an
used for on/off valves rather than for
flow control As a result they cannot be
used in all situations. Second, the main
concern associated with this type of
valve is the uncertainty of the life of the
bellows seal. The metal bellows an
subject to corrosion and fatigue under
seven operating conditions.
Over 150 types of industries an .
included in the TSDF community, and
EPA does not believe that leakless
valves can be used in an
environmentally sound manner on the .
wide variety of operating conditions and
chemical constituents found nationwide
hi TSDF waste streams, many of which
are highly corrosive. Corrosivity is
influenced by temperature and such
factors as the concentration of corrosive
constituents and the presence of
inhibiting or accelerating agents.
Corrosion rates can be difficult to
predict accurately; underestimating
corrosion can lead to premature and
catastrophic failures; Even small
amounts (trace quantities) of corrosives
in the stream can cause corrosion
problems for sealed bellows valves;
these tend to aggressively attack the
metal bellows at crevices and cracks
(including welds) to promote rapid
corrosion. Sealed bellows valves
particularly an subject to corrosion
because the bellows is an extremely thin
metallic membrane.
At proposal, it was estimated that 20
percent of all plants process
halogenated compounds, which tend to
be highly corrosive. The subsequently
obtained 1988 Screener Survey data
show that of the TSDF indicating
solvent recovery operations, at least 33
percent of the total handle halogenated
organic*. Furthermore, of the 12 major
chemicals determined from site-specific
, data to be commonly occurring in waste
solvent streams, all of the chemicals
determined to be carcinogenic an
halogenated (i.e.. methylene chloride,
chloroform, and carbon tetrachloride).
Similarly, of the 52 constituents in TSDF
waste streams contributing to the
emission-weighted unit risk factor.
about 50 percent are halogenated and
. account for the vast majority of the
estimated nationwide emissions of
-------
Federal Register / Vol. 55. No. 120 / Thursday, June 21. 19SO / Rules and Regulations 25479
carcinogen*. Thus. TSDF *ra known to
routinely handle and treat chemicals
that may destroy sealed bellows and
diaphragm valves.
The durability of metal bellows la
highly questionable if the valve is
operated frequently; diaphragm and
bellows valves are not recommended in
the technical literature for general
service. The EPA does not believe that
the application of sealed bellows and
diaphragm valves is technologically
feasible for all TSDF valve conditions or
that their application would lead to a
significant reduction in emissions and
health risks. Valve sins, configurations,
operating temperatures and pressures.
and service requirements are some of
the areas in which diaphragm, pinch.
and sealed bellows valves have
limitations diet restrict service. With
regard to the emission reductions
achieved by seeled bellows, diaphragm.
and pinch valve technologies, these
valves are not totally leakless. The
technologies do eliminate the
conventional seals that allow leaks from
around the valve stem: however, these
valves do fail in service from a variety ,
of causes and. when failure occurs.
these valves can have significant
leakage. This is because these valves
generally are not backed up with
conventional stem seels or packing. The
EPA currently is reevaluating the control
efficiencies assigned to these
technologies. Because these leakless
types of equipment are limited in their
applicability and in their potential for
reducing health risks, EPA did not
consider their use es an applicable
control alternative at this time for
nationwide TSDF standards. The EPA
has requested, in a separate Federal
Register notice (54 FR 30220. July 19.
1968), additional information on the
applicability and use of leakless valves
at TSDF.
For pumps, the most effective controls
that are technologically feasible (e.g*
dual seals) in some cases also were not
selected as the basis for equipment leak
standards. The impact analysts
Indicates that including LOAR results in
less emission and risk reduction then
does including equipment requirements
for pumps. However, the difference in
the emission and health risk reductions
attributable to implementing a monthly
LDAR program rather than the more
stringent equipment standards for
pumps appears to be small in
comparison to the results of the overall
standards (about 5 percent). The overall
standards. Including a LDAR program
for pumps and valves, would achieve an
expected emission reduction for TSDF
equipment leaks of about 19.000 Mg/yr
(21.000 ton/yr). The estimated MIR from
equipment leak emissions would be
reduced to lxlO"s from SX10'S based
on the TSDF equipment leak emission-
weighted unit risk factor; cancer
incidence would be reduced to 0.32
case/yr from 1.1 cases/yr. In
comparison, including dual seals for
pumps could achieve an additional
fugitive emission reduction of about
1,200 Mg/yr (1320 ton/yr) and an
additional incidence reduction of about
OOO case/yr. The MIR. with leakless
controls for pumps, at 1X10"' would
be unchanged from that achieved by the
LDAR program.
Given the small magnitude and the .
imprecise nature of the estimated
emission and risk reductions'associated
with including dual seals for pumps in
the overall standard. EPA considers the
two control alternatives (i.e., LDAR and
dual seals) as providing essentially the
same level of protection. The data and
models on which the risk estimates are
based ere not precise enough to quantify
risk meaningfully to a more exact level
The data and models include
uncertainties from the emission
estimates, the air dispersion modeling,
and the risk assessment that involves
unit risk factor, facility location. "
population, and meteorologic
uncertainties (see section VILE).
The EPA considered these factors
when deciding whether to require TSDF"
to install dual seals on pumps to control
air emissions rather than to rely on
monthly LDAR. Considering the limited
applicability of additional equipment
controls end the low potential for
additional reductions in health risks of
applying equipment controls for valves
at TSDF and the estimated emissions
and risk reductions if leakless
equipment for pumps were required.
EPA is not requiring leakless equipment
at this time.
In Phase HL EPA will further examine
the feasibility and impacts of applying
additional control technology beyond
the level required by today's standards.
For example, dual mechanical seals may
be an appropriate emission control
method when applied selectively to
wastes with high concentrations of .toxic
chemicals. In such applications, the
reduction in toxic emissions (and
consequently the reduction in residual
risk) may be significant for select
situations. A summary of the health
impacts is presented in section VILE of
this preamble.
D. Impact Analyses Methodologies
Environmental Impacts Analysis
Comment: Numerous commenters
criticized the environmental impact.
estimates far the proposed standards
because (1] no actual data from
operating futilities were used: (2)
emission estimates were not supported
by any technical data base: and (3) the
waste constituents used in the analyses
were not representative of waste solvent
recycling operations and TSDF
operations in general. Commenters also
stated that the model plant solvent
reclamation rates (throughputs], vent
. flow rates, and emission rates used at
proposal were not representative of the
industry.
Response: In response to these
"comments. EPA reviewed all available
site-specific data on WSTF and TSDF.
data submitted by commenters. and
information generated through RCRA
section 3007 questionnaires mailed to a
limited number of small and large
facilities. Based on all this information.
EPA has revised both the TSDF model
units and emission factors that serve as
the bases for the impacts analyses.
With regard to the model unit
revisions, the industry profile developed
by EPA includes a frequency
distribution of the waste volumes
processed during 1985. Of the 450
facilities in the Screener Survey
reporting solvent recovery by operations
such as batch distillation, fraciionation,
or steam stripping that involved some
form of hazardous waste. 365 reported .
the total quantity of waste recycled in
1985. The median facility throughput
was slightly more than 189.000 L/yr
(50.000 gal/yr); the mean throughput was
about 43X10* L/yr (1.2X10* gal/yr).
Based on the industry profile, three sizes
of model units (small, medium, and
large] were defined to facilitate the post-
proposal analyses for control costs.
emission reductions, health risks, and
economic impacts.
The organic emission rates also were
• revised for the modal units based on
emission source testing conducted for
EPA. The tost data show that organic
emission rates for primary condensers
varied from a few hundredths of a
kilogram (pound) to nearly 4.5 kg/h (10
Ib/h), with six of the nine measurements
less than 0.45 kg/h (1 Ib/h). The two
secondary condensers tested showed
emission rates of 0.9 and 2.3 kg/h (2 and
5 Ib/h), respectively.
The flow rate of 28 standard cubic feet
per minute (scfrn) used at proposal was
found not to be generally valid for
application to waste solvent recyclers.
The flow rates specified for the revised
model unit!). 3.9.0.8. and 0.3 L/s.
equivalent to 8.3,1.2. and 0.8 scfm for
the large, medium, and small model
units, respectively, are based on a
•review of site-specific data from field
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25430
Federal Register / VoL 55, No. 120 / Thursday. June gU.MBO / Rules and Regulations
tests documented in site visit reports.
The largo and medium TSDF process
vent unit flow rates also agree with
those documented in the SOCMI
Distillation NSPS BID (see Docket No.
F-SG-AESP, item S0008) as
characterizing distillation units with low
overhead gas flows. The revised impact
analyses are based on actual data from
the industry and provide a reasonable
characterization of the industry's
operations and environmental impacts.
The constituents selected for the.
analysis of control technologies an
considered to be representative of the
industry, based on a review of relevant
information and literature, including (1)
a survey of member companies
submitted by NASR. (2) 23 site-specific
plant visit reports, (3) responses to the
EPA section 3007 Questionnaires from 6
small and 11 large faculties (two
respondents provided information for 4
facilities each). (4) the Industrial Studies
Data Base (ISDB) and (5) a data base
created by the Illinois EPA. The NASR
survey provided information on the
types of solvents most frequently
recycled at member facilities: the site-
specific information and EPA survey
responses included waste composition
data. The ISDB is a compilation of data
from ongoing, in-depth surveys by EPA'a
Office of Solid Waste (OSWJ on
designated industries that are major
waste generators. The Illinois EPA data
base contains information from about
35.000 permit applications. Generators
oust submit one application for each
hazardous and special nonhazardous
waste stream managed in the State of
Illinois. Each of these data bases
contains waste stream characterization
data for numerous generic spent solvent
waste streams (EPA Hazardous Wastes
F001-F005) and D001 wastes (ignitable).
which information from the Screener
Survey indicates also are recycled.
The three constituents used for the
model facilities in the proposal analysis
were toluene (with a boiling point (bp)
of 110 °Cl MEK (bp of 79 °C). and TCE
(bp of 74 *C). Methylene chloride (bp of
40 *C) was added to the list of
constituents evaluated in the final
analysis to provide an even greater
range of solvent volatilities for the
analysis. Therefore, the technical
feasibility and costs of applying the
recommended control techniques were
evaluated for constituents representing
the range of characteristics and
volatilities of commonly recycled
solvents at TSDF.
Comment: Commenters also stated
that it is inappropriate to apply the
, fugitive emission factors to TSDF that
were developed to estimate leaks from a
typical hydrocarbon plant because they
do not relate to the design, operating
conditions, maintenance practices, or
controls associated with processing of
waste solvents and other toxic wastes.
According to the commenters, the
emission factors and model units also
need adjustment to account for volatility
because not accounting for differences
hi vapor pressure overestimates risk as
well as emissions and underestimates
costs for controls.
, Response; The EPA disagrees; the
data used in establishing the fugitive
emission standards for TSDF are based
on emission and process data collected
at a variety of petroleum refinery and
SOCMI operating units. The EPA
Industrial Environmental Research
Laboratory fffiRL) coordinated a study
to develop information on fugitive
emissions in the SOCML A total of 24
chemical'process units were tested;
these data covered thousands of
screened sources (pumps, valves.
flanges, etc.) and included units ,
handling such chemicals as acetone,
phenol MEK. ethylene dichloride. TCE,
. trichloroethylene, and
perchloroethylene.
Refinery studies on fugitives also
include tests on units handling both
toluene and xylene. These same
chemicals are included in those listed by
the NASR as solvents commonly
recycled by member facilities and an
found in other sources of waste solvent
constituent information that are
described in the BID. The chemicals
commonly recycled at TSDF an those
produced in SOCMI operating units and
handled in petroleum refineries, and the
equipment involved in these industries
is typically the same (pumps, valves,
etc.]. Therefore, it is reasonable to
conclude that the emissions associated
with these chemicals and equipment an
similar and to expect similar emission
control performance and efficiencies at
hazardous waste management units.
The EPA agrees that the equipment
leak standards should take component
volatility into consideration. Previous
EPA and industry studies have shown
that the volatility of stream components.
as a process variable, does correlate
with fugitive emission and leak rates.
An analysis of the vapor pressures and
emission rates has shown that
substances with vapor pressures of O3
kPa or higher had significantly higher
emission and leak rates than did those
with lower vapor pressures (EPA—150/3-
82-010). This result led to the separation
of equipment component emissions by
service: gas/vapor, light liquid, and
heavy liquid. These classifications have
been used in most CAA fugitive
emission standards to effectively direct
the major effort toward equipment most
likely to leak. Therefore the rules have
been revised to account for volatility.
For example, pumps and valves in
heavy-liquid service must be monitored
only if evidence of a potential leak is
found by visual, audible, olfactory, or
any other detection method. The
determination of light- and heavy-liquid
service is based on the vapor pressure
of the components in the stream (less
than 0.3 kPa at 20 *C defines a heavy
liquid).
" All of the constituents used in the
model unit analysis, representing the
ranges of characteristics of commonly
recycled solvents, are light liquids to
which the benzene and SOCMI fugitive
emission factors are applicable.
Therefore, the revised risk and cost
analyses for WSTF equipment leak
fugitive emissions an based on the
fugitive emission factors used hi the
proposal analysis. The analyses of risk
and cost impacts on TSDF with affected •
fugitive emission sources also wen
revised after proposal to account for the
differences in light and heavy liquids.
Health Risk Impacts Analysis
Comment: Several commenters
objected to the limited support provided
for selection and derivation of the unit
risk factors used in the analysis of
cancer risks and contend that the risk
analysis and unit risk factors are not
representative of the wide variety of
wastes handled. A few of the
commenters stated that the upper-bound
risk factor was too high, and others
stated it was too low.
Response: the selection of the range
of unit risk factors (i.e- 2x10"* and
2xlO~*Oig/m3r* used at proposal to
estimate the cancer risk resulting from
TSDF emissions was based on an
analysis of the organic chemicals
associated with TSDF operations. This
analysis found that carbon tetrachlcride
is the organic chemical with the most
individual impact vis-a-vis emissions
and risk. Thus, it was used as the upper
bound on the range of unit risk factors
used to calculate health impacts (i.e.,
cancer risk) at proposal. However, this
range of unit risk factors was not used in
the final analysis.
Based on public comments, EPA
revised its health risk impacts analysis.
To estimate the cancer potency of TSDF
air emissions in the revised analysis, an
emission-weighted composite unit
cancer risk estimate approach was used
by EPA to address the problem of
dealing with the large number of toxic
chemicals that are present at many
TSDF. Use of the emission-weighted
-------
Federal Register / VoL 55, No. 12O / Thursday. June 21. 1980 / Rules and Regulations 25481
composite factor rather man individual
component aait cancer risk factors
*implifl» th* risk assessment so that
calculations da *ot need to b*
perfooBed for each chemical emitted.
«, Tb*coa»j>o4He unit cancer risk factor is
combined with estimate* of ambient
coocatomtioB* of total organic* and
population exposure t* estimate risk da*
ton»a«owid*TSDF emission*. SB
calculating the emission-weighted;
average wail risk factor, th* emission
multiplied by the DDK cancer risk factor
for that compound: then the (*mi«sion-
wvighfctd avenge i» computed by
Morning these product* and dividing
th* mm by th* total nationwide TSDF
•miitka value, which include* both
carcinogenic and noncMriiwgenlc
organic aotisaiGQ*. Using thi* tjrp* of -•
average, would give the same results a*
calculating th* risk foff c^ch *r^>m^%^
Involved. However. only thea*
carcinogen* fog wnkk- unit risk factor*
an attallahl* went included in th*
analytic of canctt risk under thi*
approach. • _
ThradaJi at* of In* EPA** TSDF Watt*
Qmraciematlon P*t* H»i* (WODB)
(dbca*»*e>ia appendix D of th* BO))
and • computerized model dcnfaped far
»mly*i* of tJ»reg»lato«y options far
TSEU? erabaion sowcss, EPA. estneetcd'
, total nation wide TSDF ofjfsjjjc
e*d*ciaB* by specific teat* caaxtitaeat.
Thirty-*!** ch««rcala w«pr itknttfiiri ut
•TSOP ocipoie ak poUtttaat
k«ks a4 all tjp«i of TSDF
taanagoMmt ptoctaaca. Unit etaccr rak
beta** let tbci* eoatiitaests went tfa«a
•vvrtftd basad OB beth iodividBai
coa»tituaat and total nattoawJd* TSDP
aquipmaat kak cry nif. tmiaaioe* to
co«ipo«iU nan TSDF eaac*i ami risk
factoc.
HtusAGoa coBatiBsc&ts with* higiiaT'
onR risk &cten than carbos
t«trmchlorid« (Including aoytonitaile and
«4yl«»« oxide) wttcinciaoadinth*
calculation of the ambatoo-weignted
mat aoc«rsi«k factor for TSDF
equipOMfltkaks. This emissioa-
weishtrd unit risk factor vahwwas
detanainid to b*45xi(r • Tpg/nt^-'
and wa» uaed to dttcnninc th* bcxith-
rtlaled iapacta aaaocialcd with TSOF
eo^jptacnt leak (fugitive} eminiona
ratbac tbaa th* rang* of the unit cancer
risk factors used at proposal that
reptesenttd a limited number of
chemical compound* •netted' at WSTE.
A BOM datailad discaMioo of th*
hazardous wast* TSDF unit risk factor
dettnainaUoB i» contained ia append^
Bofth»BHX
Charmeterization of WSTF waste
s&eama in th* ft*g^ anaJysis indic&f es
that the constituents used at propoeai ia
the risk analysis ore appropriate asd
representative of th* waste solvent .
recyelmg industry. However, insufficient
nationwide data oa WSTF {a subset of
the TSDF indnatr?} wast* stress
chemical constituent quantities asd
concentration* went available to
develop a& effiissiOB*weignted>
arithmetic mean cancer unit risk factor
for WSTF process vents. While
information o» *, sataU number of
process vest stream* was> available for
th* revised analysis, tha date wen too
limited to support thai conch crfnn that
tiic &ux eUMx Qa^fcf^i^ffy o£ ^^ H *^ i^jtfn gjr
found wen cepnsesiative of the entire
{aduatry.
Tha WSTF wast* streass and their
associated pncesc vent emission* wer*
found to contain a variety of chemical
coiutinieatb Those csastitueni* with .
established risk fasJozs were, tit aB
ccse* foe- th* planS-«p«cific data, ffes>
halocenated organks; those hafcgesiatad
oxga&ic coasSttBent caaceetration*
tended to b* quits tarn, genesailjr less
than 1 percent of organic* emitEei
Therefore. EPA fod^dv based on th*
limited data UTaila bin, feat ase of •
midrangs unit risk facSor •vioold b*
sppcopfiafB ia estraotting nationwide
health tepaeU aMacistsd with WSTF
process rent*. Th* uns8 eanear risk
factor assmaed at proposal. 2XHT*
m^~ *e wa* th* geometric. laidnmg*
betwecK the .highest and lowest tout risk
factor far th* canattteent* foand hi th*
WSTP process; treat stream*. Th*
campoeibB, mmt cancer risk factor
caicalated fog A* equipment laak
emissiaae agsee* fewsrably with th*
procesft vest atsBoer osed si ptDposiL
Beeatu* it is aot uaceaconabls to
assum* « aimiiar mix of cnnstitnants ia
process vent* a* in equipment teaks.
and becata* available data da aot
suggest otherwise; for the purpose of
estimating impacts* th* sam* unit 'yiM^r
risk factor was esed far both process
vents and equipinent leaks. 4JX1QT*
Caauntnt Several commenters also
stated that the failure to addres* th*
weight of evidence for carekKigenidly is
inconsistent with EPA's risk assnsnynt
goideUnea and th* principle* for
assassins cancer risk,
flespoasar Early bs th* ntlemakmg for
TSDF. EPA rooked at the costribation to-
total estimated risk (annual incidence)
by weight of evidence. At that tun*. "C*
carcinogen* accoanted for about 5
percent of th* total risk, and "A"
carcinogens about 10 percent. Thus, for
all practical purposes, calculating
separata risk estimates for chemicals in
each weight of evidence category adds
little to Che risk assessment. Moreover.
EPA's Guidelines for Carcinogen Risk
Assessnsen? (53 FR 33992} and
Gnidefews for die Health Risk
Assessniefie of Chemical Matures- (51
FR 34824} do not describe a means to
quantitatively Incorporate weight of
evidence arto risk assessments. Thus.
there is no* inconsistency between the
risk asstasment guidelines and the
presentation of health risk hi this
' ml croaking;
Comment: Other commenters, believed
that the risk assessment for the
proposed standards was flawed because
EPA did not consider noncancer health
effects and because targe uncertainties
are introduced when the additive or
synergistfc effects of carcinogens and .
the interindividual variability in
response are not factored in.
Response: The EPA does recognize
that health effects other than cancer
may be iissociated with both short-term,
and! lon{;-tefza humaa exposure to the
organic ish^ioicals, emitted to. the air at
WSTF/TCDF.Tha EPA believes.
however, that a risk assessment based
on cauotr serves as, the clearest basis
for evalintiag, the health effects
associated wife, exposore to sis
emissiotisfiej&TSDF. A cjuaatitalive
assessment of the potential nationwide
noncancer health impacts (e.g..
developinental. neurological.
immunologicai and respiratory effects)
was not conducted due to deficiencies at
this time: ia th* health data base for,
these types, of effects.
Although unable: to numerically
quantify ocncaaccr health risksv EPA
did condueS « scseenutg analysis of the
potential adverse noncancer health
effect*, associated with short-tens and
long-ten* exposure to individual waste
constituents emitted front TSDF. This
analysis was based OR a comparison of
relevant health data to the highest short-
term or Ions-term modeled ambient
concentrations for chemicals at each of
two selstfed TSDF. (A detailed
presentation of the screening analysis is
contained in the BID. appendix B.)
Result! of this analysis suggest that
adverse noncancer health effects are
unlikely fo be associated with acute or
chronic inhalation exposure to TSDF
organfe omissions. It should be noted
that th* Itealtb data base for many
chemical's was limited particularly for
short-tern exposures. The conclusions
reached In this preliminary analysis
should frr considered m the context of
the tmrilntions of the health datar the
uncertainties associated with th*
characterization of wastes at the
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25482 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 199Q / Rules and Regulations
facilities; and the assumptions used in
estimating emissions, ambient «
concentrations, and the potential for
human exposure. Additional evaluation
of noncancer health effects may be
undertaken as part of the third phase of
the TSDF regulatory program. To that
effect, in the proposal preamble for the
Phase D TSDF air rules, EPA is
specifically requesting comments from
the public on methodologies and use of
health data for assessing the noncancer
health effects of TSDF organic
emissions. In addition, because there is
a potential for cancer and noncancer
health effects from TSDF chemicals from
indirect pathways such as Ingestion of.
foods contaminated by air toxics that
have deposited in the soil EPA will
evaluate the need to include an indirect
pathway element in the TSDF health
risk analysis in the future.
The EPA is aware of the uncertainties
inherent in predicting the magnitude and
nature of toxicant interactions between
individual chemicals in chemical
mixtures. In the absence of toxicity data
on the specific mixtures of concern, and
with insufficient quantitative
information oh the potential interaction
among the components (i.e.. additivity,
synergism, or antagonism), the EPA has
assumed additivity to estimate the
earcinogenicity of the mixtures of
concern. This is consistent with ••,
guidance provided in the 1988 "EPA
Guidelines for the Health Risk
Assessment of Chemical Mixtures" (51
FR 34014).
The EPA also recognizes that there
are uncertainties associated with the
variability of individual human
responses following exposures to
toxicants. As stated in the 1988 "EPA
Guidelines for Carcinogen Risk
Assessment" (51 FR 33992) human
populations are variable with respect to
genetic constitution, diet, occupational
and home environment, activity
patterns, and other cultural factors.
Because of insufficient data, however.
the EPA is unable to determine the
potential impact of these factors on the
•estimates of risk associated with
exposure to carcinogens emitted from
TSDF.
Cost Impacts Analysis
Comment: Various commenters
questioned the cost estimates used in
the analysis for carbon adsorbers and
condensers as well as the nationwide
recovery credits for WSTF and TSDF.
Commenters contend that the costs for
carbon adsorbers estimated at proposal
are low because a device is needed for
each vent if manifolding is not practiced
aa a result of (1) the potential for cross-
contamination of new or recycled
materials and (2) additional Incurred
costs when the carbon is regenerated or
disposed of.
Response: In response to these
comments EPA evaluated controls for 40
model unit cases representing ranges
and combinations of solvent physical
properties, total flow rates, and organic
concentrations in the vent stream. Both
carbon canisters and fixed-bed
regenerable carbon systems were coated
for process vent streams where
condensers would not achieve a 95-
percent reduction because of stream
conditions. The analysis showed that
for a stream with an emission rate
greater than 0.45 kg/h (l Ib/h), a carbon
bed can achieve the same emission
reduction at lower cost than can a
carbon canister. Thus, there-is a level of
emissions at which the facility owner or
operator for economic reasons will
switch from the use of replaceable
carbon canisters to the use of a fixed-
bed regenerable carbon adsorption
system. The capital costs (1986 $) of the
fixed-bed regenerable carbon systems
ranged from $97,300 up to $202.000, and
annual operating costs ranged from
$40400 to $43,500 (from $33,100 to
843,100 when a recovery credit is
included). The capital cost (1986 S) of a
carbon canister was $1,050. and annual
operating costs ranged from $7,890 to
$24.800 (carbon canisters an not
regenerated on site and a recovery
credit is not included). The fixed-bed,
regenerable carbon system operating
costs include regeneration/disposal of
spent carbon: carbon canister operating
costs include carbon replacement and
disposal Thus, these costs were used in
conducting the final impact analyses.
With regard to the requirement of a
control device for each vent, EPA
acknowledges that there are instances
where vent manifolding is not allowed
because of potential product
contamination. However the product
has already been recovered from the
process prior to exhaust gases passing
to the vents, which are sources of
organic emissions to the atmosphere;
therefore, manifolding of the vent
streams should not lead to a product
contamination problem.
In the absence of the site-specific
information needed to determine control
device requirements, for the purposes of
estimating cost impacts, it was assumed
in the revised analysis that one control
device would be needed per WSTF.
Although this assumption may
underestimate the control cost for a
facility that chooses to install carbon
adsorbers on more than one vent, it is
potentially a very small underestimate
because the total annual cost of a
carbon canister, for example, is
comprised almost totally of annual
operating costs, which are directly
proportional to the emissions removed,
Thus the potential underestimate in total
annual cost resulting from assuming one
carbon adsorber per facility is not
significant Furthermore, the addition of
the process vent emission limit to the
rules based on the total facility emission
rate lessens ihe likelihood that a facility
will need to control multiple process
vents to attain the allowable emission
rate of 1.4 kg/h (3 ib/h) and 2.8 Mg/yr
(3.1 ton/yr).
Several commenters also questioned
the nationwide cost credit for secondary
condensers estimated at proposal.
stating that secondary condensers
actually would result in substantial
costs and that the cost estimates do not
account for the more sophisticated .
systems needed in high-humidity areas
to'allow for equipment deicing or water
removal In responsB-to concerns.
regarding the estimated condenser
yields and the requirement for more
sophisticated systems hi high-humidity
areas, EPA utilized a state-of-the-art
computerized process simulator known
as the Advanced System for Process
Engineering (ASPEN) for Devaluating
analyses of condenser design and cost
The ASPEN condenser configuration
included an optional primary water-
cooled heat exchanger to reduce the size
of the refrigeration unit and to remove
water vapor in order to avoid freezing
problems because the condenser
temperature is low enough to cause ice
buildup on heat transfer surfaces.
Therefore, the revised cost estimates
account for water removal.
The model unit cases represent
industrywide ranges and combinations
of vent stream characteristics. For the
large model unit cases (3.9 L/s total flow
rate), total annual cost with recovery
credit ranged from a credit of $4,980 up
to a net of no cost For the medium
mode! unit cases (O.S L/s total flow
rate), the total annual cost with recovery
credit ranged from $830 up to $2.000. For
the small model unit cases (0.3 L/s total
flow rate), the total annual cost with
recovery credit ranged from $1,770 up to
$2,000. Therefore, in many cases, the use
of secondary condensers does result in
positive costs; these costs, however do
not result in adverse economic impacts.
The model unit control cost estimates
and the WSTF industry profile were
used to generate nationwide control cost
estimates of implementing the process
vent regulations. The cost estimates are
for 73 large facilities and 167 medium
facilities. The 208 small facilities (less
than 189,000 L (50,000 gal) throughput/y?
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Federal Ragisfer / VoL 5R No, 12O / Thursday. Jane 21. 199O / Rules and Regulations 25433
a* defined In the port-proposal analysis J
would mt have to install additional
contra)*, because theft emissions are- Jess
than tb* facility process vent cutoff.
Became then was insufficient site-
specific inf ormatioB available to
dfltermin* which facilities could apply
condectatioR rather than, carbon
adsorption. upper- and tower-heend
estimates wets generated. The
appcrbound coat estimate is based on
tb* assumption that fixed-bed. .
regencsabla caiboa adsorption, system*
would b* reqoiied to control process
vents at all facilities with emissions
above the emission rat* cutoff. Similarly
the lower-bound cost estimate is based
on the assumption that condensers.
could be used to control process vents at
all fadlitias with emissions above the
emission rate cutoff. The range in
estimates of nationwide total annual
coal £» from a credit of ScaoOO m> ta> *
cost of 3129 nriJlfon. assuming the
installation of on* control device per "
facility.
Finally. EPA agree* thai c recovery
credit is not applicable to TSDFCn
gtnerai bceausa most of tha hazardoo*
waste* handled al TSOFare destined
for dbpcaaL In contrast, at * WSTR th*
leaks are. potentially/ recydabla:
solvent*. Thas.no recovery credit was
applied farTSDF other than \VSTP faa
the aaaryaCT far the final equipment leak
standards.
£ Implementation end Compliance
Comment: Ownmerrters argued that
the teat methods proposed for use hi
determining whether waste streams
contain more than 10 percent total
etfaaks are inappropriate primarily '
beeane* they do not tneasare volatile
organic*. On* comnenter objected to
the us* of weight percent when defining
-in VHAP service- based on Kqrrid
sample analyse*.
AcspensarThe'EPA recognized thai
each, of the variou* test methods
proposed for determining th* organic
content of waste streams had limitation*
and that none was universally
applicable. The determination; of subpart
BB applicability should not require
precise measurement of the 1O percent
total organic* by weight h> most cases.
The EPA anticipates that most waste
streams will haw an organic content
much lower or much higher than 10
percent. Furthermore, because the
regulation requires control if the organic
content of the waste stream ever equals
or exceeds the 10-percent vain*. EPA
believes that few owners or operators
will claim that a waste stream is not
subject to the requirements of the
standard based on a sample analysis'
with results nearlO percent. Therefore
a precis* measnremest of waste stream
total organic content Is not li&efy to be
needed to determine applicability of the
equipment teak standards.
If th* facility does decide to iesf the
waste, the- choice of th* appropriate
method must be based on a knowledge
of the process and waste. Tte EPA has
prepared a guidance document that
includes mfonnatfon to aid TSDF
owners/operators and enforcement and
permitting personnel in implementing
the regulations. Additional detail is
provided in the guidance document to
aid is choosing the most appropriate test
method (Refer to "Hazardous Waste
TSBF-iTechnical Guidance Document
far RCRA Air Emission Standards for
Process Vents and Equipment teaks."
In response to the cocunenters'
concerns- that votaSlity of th® waste-
stream should be eons&rred the UJAR
provision* of the regalatkw wer*
changed to establish twopotentsai
level* of required moniformfo Thos*
process** with the greater emission
potential an? designated to> b* in KgJrt-
liquid service and are- required to
implement a Bier* restrictive IDAR
program. Thoe« processes- with a lesser
emission potential are designated to be-
te heavy-iicjffiidi ssmcs> and are reqoired
to implement a less restrictive IDAS,
program. The determination of being in
ught-iiqufd servie* far based1 OR the
concentration* of organic components n
* waste whose pure- vapor pressure
exceeds O3 tPa. This addresses the
commenters' concerns that volatility of
the waste* stream should b* considered.
For the process vent portion of the
regulation, if as organic is present at the
vent, it £s presumed to be volatile.
Therefore, vofotifiiy is considered by
virtue of where th* determination of
applicability is made.
With reference to the osr of weight
percent when defining "In VHAP
service'* (a term that has been dropped
from the promulgated- regulations}. EPA
believes that weight percentage is the
unit of choice when the determination of
organic content is made OR a solid.
liquid or sludge waste. It is also
commonly associated with those types
of wastes; For gaseous streams that
exceed 10 percent organic* by weight,
the commenter's point is well taken.
Volume fractions are more eommonly
reported for gaseous streams. However,
it is not easier to calculate the volume
percent rather than weight percent.
Additional information on fhe
calibration standard used, the carrier
gas in* the standard, and bctH the
organic and other inorganic gases in the*
sample are required in both cases. FOE
simplicity* the units of the standard are
uniformly weight percent regardless of
waste type.
Implementation Schedule
Ccwzjaent Several commenters
objected to the time periods contained
in the proposed standards for
imptenenlatien schedules and
requested thai EPA not dictate a step-
by-step schedule.
'RaspansK The EPA agrees with the
commeiifers that EPA should not dictate
step-by-step implementation schedules
for instilling the control devices and
closed-vent systems required to compfy
with thine regulations because each
affected facility needs some flexibility
to budget funds, perform engineering
evaluations, and complete construction.
Therefore. EPA has dropped the interim.
dates iri the schedule and retained only
the final period of 2. years, feam the
promulgation for completing engineering
design, iind evaluation-studies and for
installing equipment. The final rules
require, that all affected facilities comply
with this standards, on the effective date:
however. the roles allow up to 24
months from the promulgation date (i.e-
18 momths alias tba effective date) for
faciKta* to comply if they are required
to install a control device and they can
document that installation of the
emission controls cannot reasonably be
expecicai ta b* completed earlier.
Exiatintt wasi* management units, that
became newly legolated unit* subject to
the proRsions of subpart AA or BB
beeauws of a new statutory or regulatory
amcndiaextt under RCRA (e.g« a new
listing cir identification of a hazardous
waste) will have up to 1& months after
the effective date of th* statutory or
regulatory amendments that render the
facility'subject to the provisions of
subperls AA or BE to complete
instaOatioB of the control device New
hazardous waste management units
starting.1 operation after the effective
date of aubparts AA and BB must meet
the standards upon startups This subject
is discussed further in section IX
Implementation, of this preamble. The
Gnal stiindards require that both
permitted and interim status facilities
maintain the schedules and the
accompanying documentation in their
operating'records. The implementation
schedule must be in the operating record
on the effective date of today's rule-.
which is 6 months after promulgation.
No provisions have been made in the
standaids for extensions beyond 24
months after promulgation.
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25484
Federal Register / Vol 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
Permitting Requirements
Comment: Several commenten
suggested that RCRA part B information
requirements be limited to the units
already included in the part B
application. Units that must comply with
this regulation because the facility is
subject to RCRA permit requirements for
other reasons should not be required to
be added to the part B permit
application. Other commenten objected
to statements in the preamble regarding
the role of the omnibus permitting
authority under RCRA section 3005(c)(3).
The commenten questioned the absence
of criteria for establishing when such
authority would be applied to require
more stringent controls and argued that
authorizing permit writers to impose
more stringent controls based on
unenforceable guidance is not a
substitute for regulations.
Response: The EPA is aware that
extending specific part B information
requirements to those hazardous waste
management units that are not subject
to RCRA permitting but are located at
facilities that are otherwise subject to
RCRA permit requirements could result
in the need for those facilities to modify
RCRA permits or their part B
applications. However. EPA believes
that extending the part B information
requirements to hazardous waste
management units not subject to RCRA
permitting is necessary to ensure
compliance with the subpart AA and
subpart BB standards.
The EPA also agrees that requiring a
modification of RCRA permits (and part
B applications) as part of this rule could
result in delays in processing and
issuing final RCRA permits. Therefore.
the final rules do not require facilities to
modify permits issued before the
effective date of these rules. Consistent
with 40 CFR 270.4. a facility with a final
permit issued prior to the effective date
is generally not required to comply with
new part 264 standards until its permit
is reissued or reviewed by the Regional
Administrator. Hazardous waste
management units and associated
process vents and equipment affected
by these standards must be added or
incorporated into the facility permit
when the permit comes up for review
under S 270.50 or reissue under § 124.15.
As previously noted. EPA intends to
propose to modify this policy* in the
forthcoming Phase II rules such that
permitted facilities must comply with
the interim-status air rules.
Facilities that have obtained RCRA
interim status, as specified in 40 CFR
270.70 (i.e.. compliance with the
' requirements of section 3010(a) of RCRA
pertaining to notification of hazardous
waste activity and the requirements of
40 CFR 270.10 governing submission of
part A applications), will be subject to
the part 265 standards on the effective
date. Interim status facilities that have
submitted their part B application prior
to the effective date of the regulation
will be required to modify their part B
applications to incorporate today's
requirements.
The omnibus permitting authority of
S 270.32 allows permit writers to require.
on a case-by-case basis, emission
controls that are more stringent than .
those specified by a standard. The EPA
has a mandate to use this authority for
situations in which regulations have not
been developed or in which special
requirements are needed to protect
human health and the environment For .
example, this authority could be used in
situations where, in the permit writers
judgment there is an unacceptably high
risk after application of controls
required by an emission standard. This
aspect of the permitting process is
discussed further in section DC of this
preamble. The EPA is currently
preparing guidance to be used by permit
writers to help identify facilities that
would potentially have high residual
risk due to air emissions. The guidance
will include procedures to be used to
identify potentially high-risk facilities
and will include guidance for making a .
formal site-specific risk assessment
Recordkeeping and Reporting
Comment: Commenten asked EPA to
include a provision in the final
standards to provide for the elimination
of recordkeeping requirements that may
be duplicative of State or Federal
requirements for equipment leaks.
Commenten also asked whether TSDF
are subject to any notification
requirements if their waste stream is
less than 10 percent organic*.
Response: The EPA agrees that
duplicative recordkeeping and reporting
should generally be eliminated to the
extent possible. Because of the
difficulties in foreseeing all situations in
which this could occur, a provision to
this effect has not been added to the
final standards. However, when records
and reports required by States are
substantially similar, a copy of the
information submitted to the State will
generally be acceptable to EPA. When
similar records and reports are required
by other EPA programs (such as the
visual observations required for pumps
and valves associated with storage
tanks and incinerators). EPA suggests
that ownen or operators of TSDF
coordinate monitoring and
recordkeeping efforts to reduce labor
and costs. One set of records should be
maintained with emphasis on the more
detailed monitoring records required by
these standards. The EPA considers that
the monitoring required for equipment
leaks under these standards differs
significantly from the monitoring
required for ground water protection
purposes under other RCRA rules.
Howeven the monitoring and
recordkeeping programs can be
combined for efficiency.
There are no notification requirements
in the equipment leak rules for waste
streams that have been determined
never to exceed 10 percent total
organics by weight
VIL Summary of Impacts of Final
Standards
A. Overview of the Source Category
Hazardous waste TSDF are facilities
that store, treat or dispose of hazardous
wastes. A TSDF may generate and
manage hazardous waste on the same
site, or it may receive and manage
hazardous waste generated by others.
The EPA has conducted a number of
surveys to collect information about the
TSDF industry. The most recent of these
surveys, the 1986 National Screening
Survey of Hazardous Waste Treatment.
Storage, Disposal and Recycling
Faculties, lists more than 2.300 TSDF
nationwide. Available survey data
further indicate that the majority (96
percent) of waste managed at TSDF is
generated and managed on the same site
and identifies more than 150 different
industries, primarily manufacturing, that
generate hazardous waste.
Approximately 500 TSDF are
commercial facilities that manage
hazardous waste generated by others.
The types of wastes managed at TSDF
and the waste management processes
used are highly variable from one
facility to another. The physical
characteristics of wastes managed at
TSDF include dilute wastewaters
(representing more than 90 percent by
weight of the total waste managed).
organic and inorganic sludges, and
organic and inorganic solids. Waste
management processes differ according
to waste type and include storage and
treatment in tanks, surface
. impoundments, and wastepiles:
handling or storage in containers such
as drums, tank trucks, tank cars, and
dumpsters: and disposal of waste in
landfills, surface impoundments.
injection wells, and by land treatment.
In addition, hazardous waste may be
managed in "miscellaneous units" that
do not meet the RCRA definition of any
of the processes listed above.
Hazardous waste may also be handled
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rulea and Regulations 254gf
In research, development, and
demonstration units as described in 40
CFR 27065.
The promulgated standards limit
organic emissions from (1) hazardous
waste management unit process vents
associated with distillation.
fractionation. thin-film evaporation.
solvent extraction, and air and stream
stripping operations that manage waste
with 10 ppmw or greater total organic*
concentration, and (2) leaks from
equipment at new and existing
hazardous waste management units that
contain or contact hazardous waste
streams with 10 percent or more total
organic*. The final equipment leak
standards apply to each pump valve,
compressor, pressure relief device.
sampling connection, open-ended valve
or line, flange, or other connector
associated with the affected hazardous
waste management unit About 1.400
facilities are estimated to be potentially
subject to the equipment leak standards '
(I.e., TSDP managing hazardous waste
containing at least 10 percent organic*).
Of these. 450 are estimated to have
process vent* subject to the vent
standards in subpart AA.
A Us* of Model* la the Regulatory
Development Process
In estimating baseline (i.e..'
unregulated) emissions, emission
impacts of the regulatory options, and •
control costs for the options for
equipment leaks, EPA made use of a
combination of analytical and physical
models of waste management processes.
This approach waa selected because
insufficient facility-specific data are
available to conduct a site-specific
characterization of the entire TSDF
industry. For example, the
physicalmodels of waste management
procas*e*'(or units) were, used as
simplified representations of the
equipment component mix expected to
be associated with each particular
hazardous waste management process.
The model unit provides an estimate of
the number of pumps, valves, .open-
ended lines, pressure relief valve*, and
sampling connections that are used in
the waste management process.
Although these models ere not exact for
each type of process, they provide a
reasonable approximation of what can
be expected on average: precise
equipment counts for each unit at each
facility are not available.
In the absence of sufficient site-
specific data. EPA developed a model to
calculate nationwide health.
environmental, and cost impacts
associated with hazardous waste TSDF.
Details of the national impacts model
can be found in the BID, appendix D.
This national impacts model was used
to estimate the nationwide impacts
necessary for comparison of the various
TSDF equipment leak emission control
options. The national impacts model is a
complex computer program that uses a
wide variety-of information and data
concerning the TSDF industry to
calculate nationwide impacts through
summation of approximate individual
facility results. Information processed
by the model includes results of TSDF
industry surveys aa well as
characterizations and simulations of
TSDF processes and wastes, emission
factors of each type of management unit.
the efficiencies and costs of emission
control technologies.-and exposure and
health impacts of TSDF pollutants. This
information is contained in several
independent data files developed by
EPA for use as inputs to the model.
These data files an briefly described
below.
Industry profile data identify the
name, location, primary standard
industrial classification (SIC) code,
wast* management processes, waste
type*, and waste volumes for each
TSDF. The industry data were obtained
from three principal sources: A1986
National Screening Survey of Hazardous
Waste Treatment, Storage. Disposal.
and Recycling Facilities: the Hazardous
Wait* Data Management System's
RCRA part'A permit applications; and
the 1931 National Survey of Hazardous
Waste Generator* and Treatment.
Storage, and Disposal Facilities '
Regulated Under RCRA. The industry '
data are used in the model to define the
location and the SIC code for each
facility and to identify the waste
management unit* at each facility as
well e* the types and quantities of
waste managed in each unit
The hazardous waste characterization
consists of waste data representative of
typical wastes handled by facilities in
each SIC code. The waste data are
linked to specific facilities by the SIC
cod* and the RCRA waste codes
identified for that facility in the industry
profile. The wast* characterization data
include chemical properties information
that consists of constituent-specific data
on the physical, chemical, and biological
properties of a group of surrogate waste
constituents that were developed to
represent the more than 4.000 TSDF
waste constituents identified in the
waste data base. The surrogate
categories wen defined to represent
actual organic compounds based on a
combination of their vapor pressures.
Henry's law constants, and
biodegradubiiity. The use of surrogate
properties was instituted to compensate
for a lack of constituent-specific
physical and chemical property data
and to reduce the number of chemicals
to be aiisessed by the model.
The omission factors data consist of
emissicm factors, expressed as
emissions per unit of waste throughput.
for each combination of surrogate waste
constituent and model waste
management process. Each model waste'
management process was. in effect a
"national average model unit" that
represented a weighted average of the
operating parameters of existing waste
management units. The EPA's LDAR
model was used to develop emission
control efficiencies and emission
reductions for the TSDF equipment leak
emission factors used in the analysis.
This LCIAR model is based on the
Agency's extensive experience with
equipment leaks in the petrochemical'
and synthetic organic chemical
manufacturing industries.
Incidence data consist of estimates of
annual cancer incidence for the
population within 50 km of each TSDF.
This information was developed using
EPA's Human Exposure Model. 1980
census data, and local meteorological
data summaries. Because some of the
data usisd in the national impacts model
an basitd on national average values
rather than actual facility-specific data.
maximum risk numbers generated by the
model lire not considered to be
representative of facility-specific risks.
.Maximum-individual risk has meaning
only at the facility level. Therefore, EPA
chose to use another methodology for
estimating MIR for equipment leaks.
This is discussed further in section
VIIJE.
Data related to emission control
technologies and costs include
information that describes control
efficiencies, capital investment and
annual operating costs for each emission
control option that is applicable to a
particular waste management process.
These data were obtained through
engineering analyses of control device
operations and the development of
engineering cost estimates.
To make use of all of these data, the
national; impacts model contains
procedures that (1) identify TSDF
facilities their waste management
processes, waste compositions, and
annual waste throughputs: (2) assign
chemical properties to waste
constituents and assign control devices
to process units: and (3) calculate
uncontrolled emissions, emissions
reductions, control costs, and health
impacts. Results produced by the model
include, on a nationwide basis,
uncontrolled emissions, controlled
-------
emission*, capital investment costs.
annual operating costs, annualized costs
for controls, and annual cancer
incidence. As previously stated, these
nationwide values are obtained by
summing the results of individual
facility analyses across all facilities.
The primary objective and intended
use of the national impacts model are to
provide reasonable estimates of TSDF
impacts on a nationwide basis. Because
of the complexity of the hazardous
waste management industry and the
current lack of detailed information for
individual TSDF. the model was
developed to utilize national average
data where site-specific data are not
available. As a result, the estimated
emissions and cancer incidence from the
model do not represent the impacts for a
specific individual facility. However.
with national average data values used
where site-specific data were missing,
EPA believes that the estimates are
reasonable on a nationwide basis and» .
are adequate for dedsionmakhig.
C. Emission Impacts
Since proposal in February 1987. EPA
has reviewed all available site-specific
information and data on WSTF and
TSDF. much of which has only become
•vaiUble since proposal. For example,
EPA is conducting a multiyear project to
collect information on the Nation's
generation of hazardous waste and the
capacity available to treat, .store.
dispose of. and recycle that waste. The
initial phase of the project was the 1988
National Screening Survey of Hazardous
Waste Treatment Storage. Disposal and
Recycling Facilities, which identified
and collected summary information from
all hazardous waste treatment storage.
disposal, and recycling facilities in the
United States. The results of this
"Screener Survey" together with data
from other existing data bases (such as
the Hazardous Waste Data Management
System's RCRA part A applications: the
National Survey of Hazardous Waste
Generators and Treatment Storage, and
Disposal Facilities Regulated Under
RCRA in 1981: the Industry Studies
Database: a data base of 40 CFR 261.32
hazardous wastes from specific sources:
the WET Model Hazardous Waste Data
Base: and a data base created by the
Illinois EPA) were used to support the
development and analysis of these air
emission regulations for hazardous
waste TSDF. Additional sources of data
on TSDF and waste solvent recycling
operations included EPA field reports on
hazardous waste facilities and
responses to RCRA section 3007
information requests sent to ajimited
number of both large And small
facilities. Based on all of this
information. EPA has revised and
expanded the impact analyses, including
estimates of emissions, risks, costs, and
the economic impact on small
businesses and on the industry as a
whole.
Using the revised impact, analyses.
nationwide (unregulated) baseline
equipment leak organic emissions from
TSDF waste streams of 10 percent or
greater total organio are estimated at
2&200 Mg/yr.Thls estimate includes
equipment leak emissions from waste
solvent treatment facilities and from
other TSDF with hazardous waste
management processes handling wastes
with organic concentrations of 10
percent or greater, a total of about 1.400
facilities. The bases for these estimates
are contained in the BID. appendix D.
Nationwide (unregulated) organic
emissions .from process vents at about
450 TSDF with solvent recovery
operations range from 300 Mg/yr (based
on lower-bound emission rates) to 0.100
Mg/yr (based an upper-bound emission
rates). This wide emission range occurs
because of variations hi primary
condenser recovery efficiencies and the
use of secondary condensers at some
sites. The lower-bound rate represents
high recovery efficiencies at all
facilities, and the upper-bound rate
represents low recovery efficiencies at
all facilities. Actual nationwide
emissions should fall between these
values:
With the implementation of the
standards, nationwide TSDF equipment
leak emissions will be reduced to about
7.200 Mg/yn nationwide organic
emissions from process vents will be
reduced to « range from 270 Mg/yr _
(lower-bound emission rates) to 900 Mg/
yr (upper-bound emission rates).
D. Ozone Impacts
Reductions la organic emissions from
. TSDF sources will have a positive
impact on human health and the
environment by reducing atmospheric
ozone formation as a result of
reductions in emissions of ozone
precursors, primarily organic
compounds. Ozone is a major problem
in most larger cities, and EPA has
estimated that more than 100 million
people live in areas that are in violation
of the ambient ozone standards. Ozone
is a pulmonary irritant that can impair
the normal functions of human lungs,
may increase susceptibility to bacterial
infections, and can result in other
detrimental health effects. In addition,
ozone can reduce the yields of citrus.
cotton, potatoes, soybeans, wheat
spinach, and other crops, and can cause
damage to conifer forests and a
reduction In the fruit and seed diets of
wildlife. Because TSDF organic
emission* account for about 12 percent
of total nationwide organic emissions
from stationary sources, today's rules
will contribute to a reduction in ozone-
induced health and environmental
effects and will assist in attainment and
maintenance of the ambient air quality
standards for ozone. Table 1
g1immariTP« the emissions and health
risk impact estimates.
Ozone precursors and
chlorofiuoroearbons. whose emissions
will be reduced by this mtemaking, are
both considered greenhouse gases (ie-
gases whose accumulation in the
atmosphere has been related to global'
warming). Although the regulation's
direct impact on global warming has not
been quantified, the direction being
taken is a positive one. Implementation
of these roles will reduce troposphere
ozone, which contributes to global
wanning.
£ Health' Risk Impacts
Human health risks posed by .
exposure to TSDF air emission* are
typically quantified in two forms:
Annual cancer incidence and MIR.
Annual cancer incidence is the
estimated number of cancer cases per
year due to exposure to TSDF emissions
nationwide. The MIR. on the other hand.
represents the potential risk to the one
hypothetical individual who lives
closest to a reasonable worst-case TSDF
for a lifetime of TOyears. The MIR is
derived from modeling a reasonable
worst-case scenario and is not based on
actual measurement of risk. It is not
representative of the entire industry.
and. in fact may be experienced by. few.
if any. individuals. As explained in
appendix B of the BID, there are great
uncertainties in both these types of
health risk estimates. These two health
risk forms were used as an index to
quantify health impacts related to TSDF
emissions and emission controls. As
discussed in section VLJX an
equipment-leak-specific. emission-
weighted unit risk factor of 4.S x 10"*
(jig/m*)"' was used to estimate the
nationwide annual cancer incidence and
the MIR of contracting cancer
associated with TSDF equipment leak
organic emissions. See appendix B of the
BID for a detailed analysis of the health •
risk impacts.
At proposal order-of-magnitude
health impacts were estimated for
cancer risks from exposure to organic
air emissions from WSTF and TSDF.
The Human Exposure Model (HEM) was
used to calculate the magnitude of risks
posed by WSTF at both typical and
maximum emission rates. Based on an
-------
Federal Register / Vol. 55, No. 120 / Thursday. June 21, 1990 / Rules and Regulations 25487
estimated urban/rural distribution, EPA
selected six WSTF to represent the
nationwide WSTF Industry in
performing the risk assessment Using
the results of the analysis of these
"typical- facilities, health impacts were
extrapolated to ail WSTF and TSDF in
feneral to provide nationwide estimates.
" In the revised health impacts analysis
for the final rules, annual cancer
incidence and MIR were again used to
quantify health impacts for the control
alternatives for process vents and
equipment leaks. However, in this
followup analysis, the HEM was run
using site-specific data on facility waste
throughputs, emission rates.
meteorology, and population density for
each WSTF and TSDF nationwide
Identified in the various data bases.
The facility-specific information was
obtained from three principal source's.
Waste quantity and solvent recycling
data were taken from the 1986 National
Screener Survey; waste management
processing schemes and waste types
managed in each facility were based on
the Hazardous Waste Data Management
System's (HWDMS) RCRA part A
applications; the National Survey of
Hazardous Waste Generators and
Treatment. Storage, arid Disposal
Facilities Regulated Under RCRA .in
1981 (Westat Survey): and the 1986
National Screener Survey.
In revising the methodology applied in
assessing cancer risks. EPA conducted
facility-specific HEM computer runs for
nearly all of the 448 WSTF that
reported, in the 1986 National Screener
Survey, recycling and/or reuse of
solvents and other organic compounds
(i.e* TSDF expected to have the
specified process vents) and for each of
the more than 1.400 TSDF ia the industry
profile of 2400 TSDF that were
determined to manage wastes with at
least 10 percent organic content These
HEM results were used to estimate
nationwide cancer incidence for both
TSDF equipment leaks and process
vents.
The nationwide annual incidence
resulting from uncontrolled TSDF
equipment leaks is estimated at 1.1
cases ol: cancer per year. Based on the
estimated lower-bound emission rates.
the nationwide cancer incidence from
uncontrolled process vents is 0.015 case/
yr. Based on the upper-bound emission
rate, this incidence from process vents is
0.38 case/yr. With the application of the
final process vent standards, based on
lower-bound emission rates, the annual
cancer incidence will be reduced to
0.001 from 0.015 case/yr. Based on
upper-bound emission rates, annual
incidence will be reduced to 0.027 case/
yr from 0.38 case/yr. With the
implementation of the LDAR programs
for equipment leak emissions, the
annual cancer incidence associated with
fugitive emissions will be reduced to
about 0.32 case/yr.
TAMJE 1. SUMMARY OF NATIONWIDE ENVIRONMENTAL AND HEALTH RISK IMPACTS OF TSOF ^R EMISSION REGULATIONS
tSDf taae» r, iKjuiy
•rootnvartt*
In^rhogp^ ,.„,., „„„»,.„„„, ' -
tlff~t**~*
F"mrrtflh*t , ,
Menem** OTiMm. Mo/
V
Uncoo-
VQMd
300
•.too
26306
COcitrcMwct
SfO
900
7.200
Annual jnctttnec*. C*M*/
V
Uneon-
trotM
0.015
0.38
1.1
Control
0.001
0027
0.32
Maximum individual rafe *
Uncon-
traMd
3x10-»
Sx10-«
5x10-'
Control
2X10-*
4X10"*
1X10"'
• Annual lnctdinc»«ndM
-------
25488 Federal Register / VoL SS. No. 120 / Thursday, June 21. 1990 / Rules and Regulations
available on a limited baaU since
proposal. The preliminary results of a
multiyear project to collect information
on the Nation's generation of hazardous
waste and the capacity available to
treat store, dispose of. and recycle that
waste were used as the basis of the
analysis. In the survey, all active
treatment storage, disposal, and
recycling facilities (TSDR) were sent a
detailed package of questionnaires
appropriate to the processes they
operate. The completed questionnaires
were reviewed for technical accuracy:
after independent verification, the
information collected was entered into a
complex data base. The TSDR survey -
questionnaire responses contain the
most detailed up-to-date nationwide
Information regarding the hazardous
waste management technologies each
facility has on site. For each facility.
detailed information is available in the
data base, including facility area.
numbers of hazardous waste
management units by process type (i.e,
number of surface impoundments.
incinerators, recycling units), annual
throughput by process unit and types of
waste (i.e.. RCRA waste codes)
managed by each unit at the facility. •
The availability of this information in
computerized format made it possible to
use the TSDR survey data base to
identify facilities that represent the
population of wont-case facilities with
regard to equipment leak emission* and
the potential for high MIR values. A
detailed discussion of the health impacts
methodologies is presented in appendix
B of the BID.
The MIR estimate was made first by
screening detailed TSDR Survey data for
more than 1.400 TSDF to identify the
fatality that has the highest potential
equipment leak emissions and the
highest potential for these emissions to
result in high ambient air concentrations
(Lew high emissions on a small facility
area). Next it was assumed that this
facility handles hazardous wastes that
have carcinogens with an emission-
weighted potency equal to that of the
nationwide average and that an
individual was residing at the shortest
distance from the TSDF management
units to the nearest apparent residence.
The highest annual-average ambient
concentration, resulting from this high
emission-rate facility, predicted to occur
• at the residence nearest the facility was
then determined by dispersion modeling.
The Industrial Source Complex Long-
Term (ISCLT) dispersion model was
used In the equipment leak MIR analysis
to model, the wont-case facility as a true
area source with the actual facility area
of about 1 acre as input The highest
annual average out of the results of 5
years of meteorological data modeled
for each of die eight cities used to
characterize nationwide meteorology
was selected for use in the MIR
calculation. Thus, this MIR estimate is
considered a reasonable worst-case
estimate for the industry and should not
be interpreted to represent a known risk
posed by any actual facility in the
industry.
The MIR resulting from TSDF baseline
(or uncontrolled) equipment leak
emissions is estimated at SXHT*. Le- 5
chances in 1400. Based on the estimated
lower-bound emission rates-for process
vents, the MIR for uncontrolled process
vents is about 3 chances in 100,000
(3X10"1; based on the upper-bound
emission rate, the MIR is 8x10-'.
Because of the uncertainties inherent in
nationwide emission and risk estimates
that must characterize the many
different constituents present in a
variety of TSDF operations. EPA
considered the upper-bound estimates in
its dedsionmaking.
• With tha application of the final
process vent standards, based on lower-
bound emission rates, the MIR will be
reduced to 2Xl«r»from 3X10~». Based
on the upper-bound emission rates, the
MIR will be reduced to 4X10-* from
8X10~4. With the implementation of
control requirements for equipment leak
emissions that include monthly LDAR
. requirements for pumps and valves,
caps for open-ended lines, closed-purge
sampling, and rupture discs for pressure
relief devices, die MIR associated with
fugitive emissions will be reduced to
about ixllT^from SX10~». Appendix B
of the BID. EPA 450/3-89-009, presents a
detailed explanation of the derivation of
these risk estimates.
The M3R estimate for equipment leaks
is sensitive to several factors. Emissions
are th« most obvious factor controlling
risk. The facility associated with the
reported MIR for equipment leaks is one
of the highest emitting TSDF In terms of
equipment leaks, in the upper S9.5
percent for potential equipment leak
emissions. If the analysis were to us*
the 85-pereentile emissions (i.e, 85
percent of the TSDF nationwide have
lower equipment leak emissions than
this value), men MIR would drop from
lxl0~»to SX10"* with all other factors
held constant
Another factor affecting the MIR
estimates is area of the emitting source.
For these types of sources, risk is
inversely proportional to the area of the
emitting source. For example, given '
equal emissions, a facility located over
10 acres generally poses leas risk than a
facility on 1 acre. For the facility
presenting the highest risk in this rule.
the MIR would drop from 1X10"' to
2X 10~4 if 10 acres were used in the
estimate rather than 1 acre. It should
also be pointed out that for the more
than 1.400 TSDF surveyed in the EPA
1987 TSDR Survey, the median facility
area was greater than 50 acres.
Distance to the nearest resident is
another key variable in the risk
estimate. The actual distance to the
nearest residence (i.e.. 250 ft) for the
worst-case facility was used in
calculating the reported MIR value;
however.-the median distance in a
random sample of distances to the-
nearest residence reported in a survey
of the hazardous waste generators was
1,000 ft If mis median distance were
used in the estimate, even with the high
emissions and the small area, the
maximum risk value would drop from
1X10~* to 2X10"*. Meteorology is also a
factor: the worst-case dispersion was
used In the reported estimate. If an
average case were used, then risk would
drop to 8X10-* with all other factors
~ hftld tsonitant,
As the above examples show,
facilities with anything other than the
combined worst-case factors would
'pose significantly less risk than the MIR
reported for equipment leaks. The MIR
estimates presented are, for the most
part based on worst-case or
conservative assumptions; the one
exception is the weighted-average
cancer potency value, or unit risk factor
(URF). used. Tha EPA believes it is
unreasonable to make all worst-case
assumptions for a single facility.
However, because of the overall
conservative nature of the analysis, for
the industry as_a whole, the vast
majority of TSDF would pose
significantly lower risk from equipment
leak emissions than the reported
reasonable, worst-case value.
F. Cost Impacts
The EPA developed a detailed
estimate of the total capital investment.
annual operating costs, and total annual
costs of each emission control
technology applied to each affected
waste management unit Total capital
investment represents the total original
cost of the installed control device.
Total annual cost represents the total
payment each year to repay the capital
investment for the control device as well
as to pay for the control device (or work
practice) operating and maintenance
expenses. The costs of attaining the 95-
percent control or emission reduction for
process vents are based on the use of
condensers to control process vent
streams for which condensation is
-------
Federal Register / VoL 55, No. 120 / Thursday, June 21. 1990 / Rules and Regulations 25489
technically feasible and on the UM of
carbon adsorption systems to control
the remaining process vent streams
subject to the regulations. Because site-
specific information was insufficient to
determine which facilities could apply
condensers rather than carbon
adsorbers industry-wide, upper* and
lower-bound cost estimates were
generated for process vent controls. The
upper-bound cost estimates are based
on the assumption that fixed-bed.
regtnerabk carbon adsorption systems
would be required to control process
vents at all facilities with emissions
above the emission rate limit. Similarly,
the lower-bound cost estimate is based
oa the assumption that condensers
could be used to control process vents at
all facilities with emissions above the
emission rate limit .
The nationwide capital investment
and total »nn"»l cost of implementing
the requirements of today's rule for
process. vent controls are estimated at
S24JS mfflfon and S123 million/year,
respectively, for the upper-bound case.
For the lower-bound case,' capital
investment is $1.5 million and total
annual costs represent a small savings
of STOXXW/yr. These costs are based on
an industry profile that includes 73 large
recycling facilities and 107 medium-
sized recycling facilities. The more than
200 small recycling facilities are not.
Included In the cost estimates because
they are projected not to have to install
additional controls to meet the facility
emission rate limit
The capital investment and total
annual coats of controlling TSDF
equipment leak emissions with the
LDAR program together with tome
equipment specifications ere estimated
at 5128.8 million and S3Z3 mulion/yr.
respectively. Table 2 summarizes capital
and annual costs associated with the
final rules.
Further information on the economic
impacts of the final standards for
organic control from TSDF process vents
and equipment leaks is presented in
section Vin of this preamble. Details of
the analysis are presented in the BID.
chapter OQ.
TABLE 2.—SUMMARY OF NATIONWIDE
COST IMPACTS OF TSDF AIR EMISSION
REGULATIONS—Continued
2.— SUMMARY of NATIONWIDE
COST IMPACTS OF TSOF Am EMISSION
REOUtATIONS
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VUL State Authorisation
A. Applicability of Ruin in Authorized
States
.Under section 3006 of RCHA, EPA
may authorize qualified Slate* to ;
administer aod enforce the RCRA •
program within the State. (See 40 CFR
part 271 for the standards and
requirements for authorization.)
Following authorization, EPA retains
enforcement authority under sections
3008.7003. and 3013 of RCRA. although
authorized States have primary
enforcement responsibility under
section 7002.
Prior to the HSWA of 1984,« State
with final authorization administered its
hazardous waste program entirely in
lieu of EPA administering the Federal
program in that State. The Federal
requirements no longer applied is the
euthorized State, and EPA could BO*
issue permits for any facilities ia the
State that the State was authorized to
permit When new. more stringent
Federal requirements were promulgated
or enacted, the State was obliged to
enact equivalent authority within
specified timefrsmes. New Federal
requirements did not take effect in an
authorized State until the State adopted
the requirements as State law.
In contrast, under section 3006(g)(l) of
RCRA. 42 U.S.C. 6828(g). new
requirements and prohibitions imposed
by HSWA take effect in authorized
States at the same time that they take
effect in nonauthorized States. The EPA
is directed to carry out those
requirements end prohibitions in
authorized Stales, including the issuance
of permits, until the State is granted
authorization to do so. While States
must still adopt HSWA-related
provisions as Slate law to retain final
authorization, the HSWA requirements
apply in authorized States in the interim.
£ Effect oa State Authorizations
Today's rule is promulgated pursuant
to section 3004(n) of RCRA. a provision
added by HSWA. Therefore. EPA is
adding die requirements to Table 1 in 40
CFR 271.1(j). which identifies the
Federal program requirements mat are
promulgated pursuant to HSWA and
take effect in all States, regardless of
authorization status. States may apply
for eithei' interim or final authorization
for the HSWA provisions identified in
Table 1. aa discussed in this section of
the preamble.
The EJ'A will implement today's rule
in authorized States until (1) they
modify their programs to adopt these
rules and receive final authorization for
the modification or (2) they receive
interim authorization as described
below. Because this rule is promulgated
pursuant to HSWA, a State submitting a
program modification may apply to
receive either interim or final
authorisation under section 3006(g)(2) or
section 3006(b), respectively, on the
basis of i-equirements that are
substantially equivalent or equivalent to
EPA's. The procedures and schedule for
State program modifications for either
interim or final authorization are
described in 40 CFR 271.21. It should be
noted that ail HSWA interim
authorizations will expire automatically
on January 1.1993 (see 40 CFR
271.24(c}|.
' Section 271.21(e)(2) requires that
authorized States must modify their
program:! to reflect Federal'program
changes and must subsequently submit
the modifications to EPA for approval.
The deadline for State program
modifications for this rule is July 1.1991
(or July 1.1992, if a State statutory
change in needed). These deadlines can
be extended in certain cases [40 CFR
271^1(e)|[3)]. Once EPA approves the
modification, the State requirements
become iiubtitle C RCRA requirements.
A SUM that submits its official
application for final authorization less
than 12 months after the effective date
of these standards is not required to
include standards equivalent to these
standards in its application. However,
the Slate must modify its program by the
deadlines set forth in 40 CFR 27l.21(e).
States that submit official applications
for final authorization 12 months after
the effective date of these standards
must include standards equivalent to
these standards in their, applications.
Section 271.3 sets forth the requirements
a State must meet when submitting its
final authorization application.
-------
25490 Federal Register / Vol. 55. No. 120 / Thursday. ?unt 21. 1990 / Rules and Regulation^
States that are authorized for RCRA
may already have requirements under
State law similar to those in today's
rales. These State regulations have not
been assessed against the Federal
regulations being promulgated today to
determine whether they meet the tests
for authorization. Thus, a State, is not
authorized to implement these
requirements in lieu of EPA until the
State program modification is approved.
Of course. States with existing
standards may continue to administer
and enforce their standards as a matter
of State law. In implementing the
Federal program. EPA will work with
States under cooperative agreements to
minimize duplication of efforts. In many
cases. EPA will be able to defer to the
States in their efforts to implement their
programs rather than take-separate
•actions under Federal authority.
IX Implementation
As proposed the air emission
standards for process vents and
equipment leaks were included as
subpart C of part 269, Air Emission
Standards for Owners and Operators of
Hazardous Waste Treatment. Storage.
and Disposal Facilities. Part 269 was to
be added to the CFR with the
promulgation of these standards. For
consistency with standards for other
TSDF sources under RCRA. the final
standards have been incorporated into
parts 264 and 285. Subpart AA applies to
process vents and subpart BB to
equipment leaks. In addition, whereas at
proposal the equipment leak
requirements of 40 CFR part 61. subpart
V. were incorporated by reference, these
provisions have been included in
subpart BB with revisions appropriate
for a standard promulgated under RCRA
authority rather than CAA authority.
Under the current RCRA permitting
system, a facility that has received a
final permit must comply with all of the
following requirements as specified in 40
CFR 270.4: (I) The specific conditions
written into the permit (including
conditions that demonstrate compliance
with part 284 regulations); (2) self-
implementing statutory requirements:
and (3) regulations promulgated under
40 CFR part 268 restricting the
placement of hazardous waste in or on
the land. When new regulations are
promulgated after the issuance of a
permit EPA may reopen the permit to
incorporate the new requirements as
stated in J 270.41. Otherwise, the new
regulatory requirements are
incorporated into a facility's permit at
the time of permit reissuance. or at the
5-year review for land disposal
facilities.
Facilities that have not been issued &
final permit and that have fully
complied with the requirements for
interim status must comply with the
regulations specified in CFR part 285.
New regulations that are added to part
285 become applicable to interim status
facilities on their effective dates.
Although EPA has the authority to
reopen permits to incorporate the
requirements of new standards, EPA is.
concerned about the resource burdens of
this approach. To reopen permits for
each new regulation at the time it is
promulgated would impose a large
administrative burden on both EPA and
the regulated community because a
major permit modification would
generally require the same
administrative procedures as are
required for initial permits (e.g.,
development of a draft permit, public
notice, and opportunity for public
hearing). As a consequence, the
requirements of new standards are
usually incorporated into a permit when
it ie renewed. For standards
implemented through the RCRA permit
system, the effect of this policy is to
"shield'' facilities that have been issued
a final permit from any requirements
promulgated after the issuance of the
permit until the time that the permit
must be renewed and the new
requirements are written into the permit.
Thus, this policy is often referred to as
the "permit-as-a-shieid" policy.
Although this policy is generally
applied. EPA may evaluate the need to
accelerate the implementation of
standards developed under RCRA and.
if warranted, make exceptions to the
permit-as-a-shield policy. In today's
rules, the permit-as-a-shield provision
applies to control of air emissions from
process vents and equipment leaks
regulated under section 3004(n).
However, as previously noted, in the
Phase 11 TSDF air rules. EPA intends to
propose modifications to permit-as-a-
shield provisions as they apply to
control of air emissions under these new
subparts. With this proposed action, air
rales promulgated under RCRA section
S004(n) would be applicable to all •
facilities, regardless of permit status.
Both interim status and permitted
facilities must comply with the
substantive control requirements of the
final standards. However, facilities that
have already been issued a final permit
prior to the effective date of today's
final rules are not required to comply
with the rules until such time as the
permit is reviewed or is reissued.
Interim status facilities that have
submitted their part B permit application
are required to modify their part B
applications to incorporate the
requirements of today's rules.
The EPA considers that the part 265
standards promulgated here can be
satisfied without the need for detailed
explanation or negotiation between the
facility owner/operator and EPA and
therefore, interim status facilities can
comply without awaiting permit action.
The self-implementing nature of these
rules is achieved by including specific
criteria for facility owners or operators
to identify waste management units that
are subject to the regulation and by
clearly specifying the emission control
and administrative requirements of the
rules.
The criteria for applicability are that
certain hazardous waste management
units at new and existing TSDF that
need authorization to operate under
RCRA section 3005 are covered by the-
rules. The applicability includes all
hazardous waste management units and
recycling units, at facilities that require
RCRA permits. For the equipment leak
standards to apply, the equipment must
contain or contact hazardous wastes
with a 10-percent-or:more total organics
concentration. For the process vent
standards to apply, the vents must be
. associated with specific hazardous
waste management units, i.e.,
distillation, fractionation, thin-film
evaporation, solvent extraction, or air or
steam stripping operations, that manage
wastes with 10 ppmw or greater total
organics concentration.
Control requirements in the final
regulation include specific design
.requirements for equipment and specific
performance criteria (i.e., a weight-
percent reduction and a volume
concentration limit) for emission control
devices. Provisions of the final
standards also list specific types of
equipment required. Owners and
operators who use one of the listed
types of equipment within the specified
design and operational parameters
would therefore be in compliance with
the regulation as long as the required
design, inspection, monitoring, and
maintenance provisions were met
Specifications for emission controls that
achieve at least a 95-weight-percent
reduction in volatile organic emissions
are somewhat less specific, but
engineering design practices are
sufficiently established that the
combination of a good control device
design and subsequent monitoring of
operating parameters, as required by the
final regulation, would offer reasonable
assurance that the specified emission
reduction is being achieved. Regardless
of the type of control selected, owners
and operators must maintain their own
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Federal Register / VoL 55. No! 120 / Thursday. June 21. 1990 / Rules and Regulations 25491
records of control device design.
installation, and monitoring and must •
submit reports identifying exceeders of
monitored control device parameters.
Periodic review of the required reports-
and records by EPA may be used to
ensure compliance.
Because today's rules are promulgated
under HSWA. all affected {acuities must
comply with these requirements on the
effective date of the rule, regardless of
the authorization status of the Slate in
which they are located. In addition.
because EPAVill implement these mica
in every State on the effective date, all
reports should be sent to the EPA •
Regions! Offices unuTthe State receives
authorization to implement these rules.
Therefore, owners and operators of
TSDF with existing waste management
units subject to the provisions of
subparts AA and BD must achieve
compliance with the process vent and
equipment leak control and monitoring
requirements on the effective date of
these rules (Le, 8 months following
promulgation) except where compliance
would require the installation of a
dosed-vent system and control device.
Information developed under other EPA
regulations has shown that in some
cases, the design, construction, and
installation of a doscd-vent system and
control device can take as long as 24
months to complete. As a result, EPA is
allowing up to 24 months from the
promulgation date of the regulation for
existing facilities to complete
installation if they ere required to install
a dosed-vent system and control device
and if they can document that
Installation of the emission controls
cannot reasonably be expected to be
completed earlier. In these
circumstances, owners'/operators are
required to develop an implementation
schedule that Indicates dates by which
the design, construction, and operation
of the necessary emission controls will
be completed. This implementation
schedule must document that
installation of dosed-vent systems and
control devices required by the final
standards would be achieved within a
period of ro more than 2 years from
today and must be included as part of
the facility's operating record on the
effective date of these final'rules (L&. 8
months after promulgation}. Changes in
the implementation schedule are
allowed within the 24-month timeframe
If the owner or operator documents that
the change cannot reasonably be
avoided.
This extension would also apply to
those existing facilities that are brought
under regulation because of new
statutory or regulatory amendments
under RCRA that render the facility
subject to the provisions of subpart AA
or BB (e.g, units handling wastes newly
listed or identified as hazardous by
EPA). That is. the owner or operator
may be allowed up to 18 months from
the effective date of the statutory or
regulatory amendment to complete
installation of a control device.
However, for facilities adding new
waste management units. EPA believes
that the lead time involved in such
actions provides adequate time for
owners and operators to design, procure,
and install the required controls.
Therefore, all new units must comply
with the rules immediately (i.e.. must
have control equipment installed and
operating upon startup of the unit}.
Under the approach discussed above,
the standards promulgated today for
process vents and equipment leaks
would be implemented on the following
schedule for existing TSDF: .
—180 days following promulgation, the
new subparts AA and BO standards
became effective; all facilities become
subject to the new standards.
—On the effective date of the standards,
compliance with the standards is
required. Each facility that does not
have the control devices required by"
the standards in place and operating
must have one of the following in the
facility's operating record: (1} An
implementation schedule indicating
when the controls will be installed, or
(2] a process vent emission'rate
determination that documents that the
emission rate limit is not exceeded
(therefore, controls are not required}.
—No later than 18 months following the
effective date (2 years following
promulgation), any control devices
required by the standards for process
vents and equipment leaks must be
installed at all facilities.
—All permits issued after the effective
date must incorporate the standards.
An existing solid waste management
unit may become a hazardous waste
management unit requiring a RCRA
permit when a waste becomes newly
listed or identified as hazardous.
Owners and operators of facilities not
previously requiring a RCRA permit who
have existing units handling newly
• listed or identified hazardous waste can
submit a part A application and obtain
interim status. The air emission
standards promulgated today would be
implemented at these newly regulated
facilities on the following schedule:
—180 days following the date the
managed waste is listed or identified
as hazardous, the standards become
effective: facilities become subject to
the subpart AA and/or BB standards.
—On the affective date of the standards,
each facility that does not have the
control devices required by the
process and/or equipment leak
standards in place must have one of
the following in the facility's operating
record: i[S) As implementation
schedule radicating when the controls
will be installed, or (2) a process vent
emission rate determination that
documents that the emission rate limit
is not exceeded (therefore, controls
are not required). ,
—No later than IS months following the
effective date (2 years fallowing
promulgation), the controls required
by the standards must be installed at
all facilities.
Newly constructed TSDF are required
to submit part A and part B permit
applications and to receive a final
permit prior to construction as required
by § 270.10. Following the effective date
of the standards promulgated today, a
part B application for a new facility
must demonstrate compliance with the
standards as contained in part 264. if
applicable Therefore, all controls
required tiy the standards would have to
be in place and operating upon startup.
Similarly, new waste management
units add
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25492 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1930 / Rules and Regulations
rules; the 24-month extension is not
applicable in this case. For the process
vent emission rate limit, the situation is
somewhat different TSDF process vents
associated with the distillation/
separation operations specified in the
rule that manage wastes with organics
concentrations of 10 ppmw or greater
are affected by the regulation regardless
of whether the facility emissions are
above or below the emission rate limit
Therefore, any change in the facility
operations that results in a TSDF going
above or below the emission rate limit
does not cause a change in the
applicability of the facility to subpart
AA. The rales require that affected
TSDF reduce total process vent organic
emissions from all affected vents by 95
percent or reduce the facility's total
process vent emissions to or below 1.4
kg/h and 2.8 Mg/yr. One of these
conditions must be met at all times; the
facility's emission rate determination.
which documents the facility's status
regarding compliance with the process
vent standards, must also at ail times
reflect current design and operation and
wastes managed in the affected units.
The permitting authority cited by
section 3005 of RCRA and codified in
§ 270.32(b)(2) states that permits issued
under this section "* * * shall contain
such terms and conditions as the
Administrator or State Director
determines necessary to protect human
health and the environment" This
section, in effect, allows permit writers
to require, on a case-by-case basis.
emission controls that are more
stringent than those specified by a
standard. This omnibus authority could
be used in situations whereon the permit
writer's judgment there is an
unacceptably high residual risk after
application of controls required by an
emission standard. As has been stated.
the approach that EPA is using in
today's regulatory action is to proceed
with promulgation of regulations to
control organic emissions and to follow
this with regulations that would Require
more stringent controls for individual
hazardous constituents or would
otherwise reduce risk where necessary.
Until then, permit writers should use
their omnibus permitting authority to
require more stringent controls at
facilities where a high residual risk
remains after implementation of the
standards for volatile organics.
X. Administrative Requirements'
A. Regulatory Impact Analysis
Executive Order No. 12291 (E.O.
12291) requires each Federal agency to
determine whether a regulation is a
"major10 rule as defined by the order
and "to the extent permitted by law." to
prepare and consider a Regulatory
Impact Analysis (RIA) in connection
with every major rule. Major rules are
defined as those likely to result in:
1. An annual cost to the economy of
$100 million or more; or
2. A major increase in costs or prices
for consumers or individual industries:
or _
a, Significant adverse effects on
competition, employment investment .
productivity, innovation, or
international trade.
The final rule establishes the specific
emission levels and emission control
programs that facilities must meet in
reducing air emissions from hazardous
waste management units. A complete
assessment of the costs.impacts. and
benefits of these rules has been
conducted by EPA. This analysis
indicates that the requirements of the
rules for TSDF equipment leaks and
process vents result in none of the
economic effects set forth in section 1 of
the E.O.12291 as grounds for finding a '
regulation to be major. The industry-
wide anmialized costs of the standards
are estimated to be $48 million, which is
less than the $100 million established as
the first criterion for a major regulation
in E.O.12291. Price increases associated
with the final standards are not
considered a "major increase in costs br
prices" specified as the second criterion
in E.0.12291. The final standard's effect
on the industry would not result in any
significant adverse effects on
competition, investment productivity.
employment innovation, or the ability of
U.S. firms to compete with foreign firms
(the third criterion in E.0.12291).
The final rule was submitted to the
Office of Management and Budget
(OMB) for review as required by E.O.
12291.
fl. Regulatory Flexibility Act
Under the Regulatory Flexibility Act.
whenever an Agency publishes any
proposed or final rule in the Federal
Register, it must prepare a Regulatory
Flexibility Analysis (RFA) that
describes the impact of the rule on small
entities (i.e., small businesses.
organizations, and governmental
jurisdictions). This analysis is not
necessary, however, if the Agency's
Administrator certifies that the rule will
not have a significant economic impact
on a substantial number of small
entities. The EPA has established
• guidelines for determining whether an
RFA is required to accompany a
rulemaking package. The guidelines
state that if at least 20 percent of the
universe of "small entities" is affected
by the rule, then an RFA is required. In
addition, the EPA criteria are used to
evaluate if a regulation will have a .
"significant impact" on small entities. If
any one of the following four criteria is
met the regulation should be assumed
to have a "significant impact:"
1. Annual compliance costs increase
the relevant production costs for small
entities by more than 5 percent
2. The ratio of compliance costs to
sales will be 10 percent higher for small
entities than for large entities.
3. Capital costs of compliance will
represent a significant portion of the
capital available to small entities, taking
into account internal cash flow plus
external financing capabilities.
. 4. The costs of the regulation will
likely result in closures of small entities.
At proposal. EPA's Administrator
certified that the rule would not have a
significant impact on small businesses
because the only entities subject to the
rule are those required to have a permit
for treatment storage, and'disposal of
. hazardous waste. Few, if any. of these
facilities are small entities. Based on
comments received at proposal. EPA
reviewed this conclusion in light of the
revisions made to the proposed
standards and closely examined the
potential impacts on the industry
segment comprised primarily of small
commercial recyclers. As a result of the
revisions made to exempt small
facilities from having to install control
devices. EPA again concluded that the
economic impact on small businesses
will be minimal and did not prepare a
formal RFA in support of the rule.
Accordingly, I hereby certify that this
regulation will not have a significant
impact on & substantial number of small
entities. Therefore, this regulation does
not require an RFA.
C Paperwork Reduction Act
The information collection
requirements contained in this rule have
been approved by OMB under the
provisions of the Paperwork Reduction
Act 44 U.S.C 3501 et seq. and have
been assigned OMB control number
2080-0195.
Public reporting burden resulting from
this rulemaking is estimated to be about
9 hours per response (on average).
including time for reviewing
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
Recordkeeping requirements are
estimated to'require ISO hours a year for
each facility.
Send comments regarding the burden
estimate or any other aspect of this
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Federal Register / Vol. 55, No. 120 / Thursday, June 21, 1990 / Rules and Regulations 25493
collection of information, including
suggestions for reducing this burden, to
Chief. Information Policy Branch. PM-
223. U.S. Environmental Protection
Agency. 401M Street SW.. Washington.
DC 20460: and to the Office of
Information and Regulatory Affairs
(Paperwork Reduction Project (2060-
0195)}, Office of Management and
Budget. Washington. DC 20503. marked
"Attention: Desk Officer for EPA."
D. Supporting Documentation
The dockets for this rulemaking
(Docket No. F-aS-AESP-FFFFF. which
covers the development of the rules up
to proposal, and Docket No. F-90-
AESF-FFFFF, which covers
development of the final rules from
proposal to promulgation) are available
for public inspection at the EPA RCRA
Docket Office (OS-300) in room 242TM
of the US, Environmental Protection
Agency. 401M Street SW- Washington,
IXJ 20460. The docket room is open from
9 sum. to 4 p.m., Monday through Friday,
except for Federal holidays. The public
must make an appointment to review
docket materials and should call (202)
475-9327 for appointments. Docket A-.
79-27, containing support information
used In developing the National
Emission Standard for Hazardous Air
Pollutants: Benzene Fugitive Emissions.
is available for public inspection and
copying between 8 ajn. and 4 p.m.,
Monday through Friday, at EPA's
Central Docket Section, room 2903B.
Waterside Mall. 401M Street SW..
Washington. DC 204CO. The public may
copy a maximum of 50 pages of material
from any one regulatory docket at no
cost. Additional copies cost S0.20/pnge.
The docket contains a copy of all
references cited in the BID for the
proposed and final rules, as well as
other relevant reports and
correspondence.
E. Us* of Subjects
40CFRPaft2BO
Air stripping operation. Closed-vent
system. Condenser. Control device.
Distillation operation. Equipment.
Fractionation operation. Process vent.
Solvent extraction operation. Steam
stripping operation. Thin-film
evaporation operation. Vapor
incinerator. Vented. Incorporation by
reference. *
40 CFR Part 261
Hazardous waste. Recyclable
materials. Recycling. Hazardous waate
management units.
40 CFR Parts 264 and 283
Hazardous waste. Treatment, storage,
and disposal facilities. Air emission
standards for process vents. Air.
emission standards for equipment leaks.
Incorporation by reference. Process
vents, Cloaed-vent systems. Control
devices' Pumps, Valves, Pressure relief
devices. Sampling connection systems.
Open-ended lines. Alternative
standards. Test methods, Recordkeeping
requirements. Reporting requirements.
4O CFR Part 270
Administrative practices- and
•procedures. Hazardous waste permit
program. Process vents. Equipment
leaks. Reporting and recordkeeping
requirements.
40 CFR Part 271
Hazardous waste. State hazardous
waste programs. Process vent and
equipment leak air emission standards
forTSDF.
Dated Jun« 13,1900.
William K.Xeilly,
Adminiitrator.
For- the reasons set out in the
preamble, chapter L title 40. of the Code
of Federal Regulations, parts 260,261,
264.265.270. and 271, are amended as
follows.
PART 260—HAZARDOUS WASTE
MANAGEMENT SYSTEM: GENERAL
1. The authority citation for part 260
continues to read as follows:
Authority: 42 U.S.C. 6905.6912(a). 6921
through 6827. 6630. 6934.6835.6937, 6933. and
6839.
2, Section 260.11 is amended by
adding the following references la
paragraph (a):
j ZOO* 11 HGi4CWICtt9»
(a)* • •
* • • • •
"ASTM Standard Method for Analysis
of Reformed Gas by Gas
Chramatography." ASTM Standard D
1946-82. available from American
Society foe Testing and Materials, 1916
Race Street, Philadelphia. PA 19103.
"ASTM Standard Test Method for
Heat of Combustion of Hydrocarbon
Fuels by Bomb Calorimeter (High-
Precision Method)." ASTM Standard D
2382-83. available from American
Society for Testing and Materials. 1916
Race Street. Philadelphia. PA 19103.
"ASTM Standard Practices for
General Techniques of Ultraviolet-
Visible Quantitative Analysis." ASTM
Standard E169-87. available from
American Society for Testing and
Materials, 1916 Race Street.
Philadelphia, PA 19103.
"ASTM Standard Practices for
General Techniques of Infrared
Quantitative Analysis." ASTM Standard
E163-88, available from American
Society for Testing and Materials. 1918
Race Street, Philadelphia, PA 19103.
"A8TM Standard Practice for Packed
Column Gas Chromatography," ASTM
Standard E 260-85. available from
American Society for Testing and
Materials. 1918 Race Street.
Philadelphia, PA 19103.
"ASTM Standard Test Method for
Aromatics in Light Naphthas and
Aviation Gasolines by Gas
Chromaiography," ASTM Standard D
2267-iJS, available from American
Society for Testing and Materials. 1916
Race Sjtreet, Philadelphia. PA 19103.
"A8TM Standard Test Method for
Vapor Pressure-Temperature
. Relationship and Initial Decomposition
Temperature of Liquids by Isoteriscope."
ASTM Standard D 2879-88. available
from j\merican Society for Testing and
Materials. 1916 Race Street,
Philadelphia, PA 19103.
"AITI Course 415: Control of Gaseous
Emissions," EPA Publication EPA-450/
2-81-005. December 1981. available from
National Technical Information Service.
5285 I»ort Royal Road. Springfield. VA .
22161,
PART 2S1—IDENTIFICATION AND
LIST! NG OF HAZARDOUS WASTE
3. The authority citation for part 261
continues to read as follows:
Autliority: 42 U.S.C 6905. 6912.6921. 6922.
and 6837.
Subpiirt A—General
4. In | 261.6, paragraph (c)(l) is
revised and paragraphs (c)(2)(iii) and (d)
are added to read as follows:
§26l.li Requirements for recyclable
materials*
(c)(l) Owners or operators of facilities
that store recyclable materials before
they sire recycled are regulated under ail
applicable provisions of subparts A
through L. AA. and BB of parts 234 and
283. and under parts 124. 268. 268. and
270 of this chapter and the notification
requirements under section 3010 of
RCRlL. except as provided in paragraph
(a) of this section. (The recycling
process itself is exempt from regulation
except as provided in 5 261.6(d).)
(2) ' ' '
(iii) Section 261.6(d) of this chapter.
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Federal Register / VoL 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
25494,
(d) Owners or operators of facilities
subject to RCRA permitting
requirements with hazardous waste
management units that recycle
hazardous wastes are subject to the
requirements of subparts AA and BB of
part 264 or 265 of this chapter.
PART 264—STANDARDS FOR
OWNERS AND OPERATORS OF
HAZARDOUS WASTE TREATMENT,
STORAGE. AND DISPOSAL
FACILITIES
5. The authority citation for part 264
continues to read as follows:
Authority: 42 US.C. 6905.6912(a). 6924. and
8925.
Subpart B—General Facility Standards)
6. Section 284.13 U amended by
revising paragraph (b]{6) to read as
.follows:
'analysis.
{264.13 Oenenl'
(b) * * ••
(6) Where applicable, the methods
that will be used to meet the additional
waste analysis requirements for specific
waste management methods as
specified in 55 264.17.284.314.264.341.
284.1034(d]. 284.1063(d). and 288.7 of this
chapter.
• * • • •'
7. Section 264.1S is amended by
revising the last sentence of paragraph
(b)(4) to read as follows:
1204.15 Generatinsr*
ptfquirameiits.
(b) • • •
(4)' * * At a minimum, the
inspection schedule must include the
terms and frequencies called for in
Si 284.174, 264.194. 284.221 264.253.
284.254. 264.303. 284.347, 284.802.
264.1033.264.1052.284.1053. and
264.1058. where applicable.
Subpart E— Manifest System.
Recordkeeping, and Reporting
8. Section 264.73 is amended by
revising paragraphs (b)(3) and (b)(6) to
read as follows:
$264.73 Operation record.
(3) Records and results of waste
analyses performed as specified In
S! 264.13. 284.17. 204.314. 284.341.
264.1034. 264.1083. 268-4(a). and 288.7 of
this chapter.
(8) Monitoring, testing or analytical
data, and corrective action where
required by subpart F and S§ 264:228.
284.253.264JS4.264.276.284.278, 26^280.
264.303,284.309.284.347.284.602.
264.1034(c)-264.1034(f). 264.103S.
264.1063(d}-264.1063(i}. and 264.1064.
9. Section 284J7 is amended by
revising paragraph (c) to read as
follows:
S.284J7 Additional reports.
(c) As otherwise required by subparts
F. K through N. AA. and BB.
10.40 CFR part 284 is amended by
adding subpart AA to read as follows:
Subput AA—Air Frniniirffi Standards for
PraceesVaatB
264.1030 Applicability.
264.1031 Definitions.
264.1032 Standard*: Process vents.
264,1033 Standard* Closed-vent systems
and control devices.
264.1034 Test methods and procedures.
26C.103S Recordkeeping requirements.
264.1036. Reporting requirements.
264.1037-264.1049 [Reserved!
Subpart AA—Air Emission Standards -
for Process Vents
} 264.1030 AppJteabURy.
(a) The regulations in this subpart
apply to owners and operators of
facilities that treat store, or dispose of
hazardous wastes (except as provided
in|2841J.
(b) Except for 5 3 264.1034(d) and
284.103S(e). this subpart applies to
process vents associated with
distillation, fraetionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operations that manage
hazardous wastes with organic
concentrations of at least 10-ppmw. if
these operations are conducted in:
(1) Units that are subject to the
permitting requirements of part 270. or
(2) Hazardous waste recycling units
that are located on hazardous waste
management facilities otherwise subject
to the permitting requirements of part
270.
(c) If the owner or operator of process
vents subject to the requirements of
§S 264.1032 through 264.1036 has
received a permit under section 3005 of
RCRA prior to December 21.1990 the
requirements of §5 284.1032 through
284.1038 must be incorporated when the
permit is reissued under S 124.15 or
reviewed under 5 270.50.
(Note The requirements of S J 264.1032
through 204.1036 apply to process vents on
hazardous waste recycling units previously
exempt under paragraph M1.6(c)(l). Other
exemptions under H 281.4.28244. and
264.1(8) are not affected by theM
requirements.)
§264.1031 DsfmttkJfia.
As used in this subpart all terms not
defined herein shall have the meaning
given them in the Act and parts 260-268.
Air stripping operation is a desorptioa
operation employed to transfer one or
more volatile components from a liquid
mixture into a gas (air) either with or
without the application of heat to the
liquid. Packed towers, spray towers, and
bubble-cap, sieve, or valve-type plate
towers are among the process
configurations used for contacting the
air and a liquid.
Bottoms receiver means a container
or tank used to receive and collect the
heavier bottoms fractions of the
distillation feed stream that remain in
the liquid phase.
Closed-vent system means a system
that is not open to the atmosphere and
that is composed of piping, connections.
and. if necessary, flow-inducing devices
that transport gas or vapor from a piece
or pieces of equipment to a control
device.
Condenser means a heat-transfer
device that reduces a thermodynamic .
fluid from its vapor phase to its liquid
phase.
Connector means flanged, screwed.
welded, or other joined fittings used to
connect two pipelines or a pipeline and
a piece of equipment For the purposes
of reporting and recordkeeping.
connector means flanged fittings that
are not covered by insulation or other
materials that prevent location of the
fittings.
Continuous recorder means a data-
recording device recording an
instantaneous data value at least once
every 15 minutes.
Control device means an enclosed
combustion device, vapor recovery
system, or flare. Any device the primary
function of which is the recovery or
capture of solvents or other organics for
use. reuse, or sale (e.g- a primary
condenser on a solvent recovery unit) is
not a control device.
Control device shutdown means the
cessation of operation of a control
device for any purpose.
Distillate receiver means a container
or tank used to receive and collect liquid
material (condensed) from the overhead
condenser of a distillation unit and from
which the condensed liquid is pumped
to larger storage tanks or other process
units.
Distillation operation means an
operation, either batch or continuous.
separating one or more feed stream(s)
into two or more exit streams, each exit
stream having component
concentrations different from those in
the feed stream(s). The separation is
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Federal Register / VoL 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 2S495
achieved by the redistribution of the
component* between the liquid and
vapor phase as they approach
equilibrium within the distillation unit
Double block and bleed system means
.two block valves connected in series
with a bleed valve or line that can vent
the line between the two block valves.
Equipment means each valve, pump.
compressor, pressure relief device.
sampling connection system, open-
ended valve or line, or flange, and any
control devices or systems required by
this subpart
Flame zone means the portion of the
combustion chamber in a boiler
occupied by the flame envelope.
flow indicator means a device that
indicates whether gas flow is present in
a vent stream.
First attempt at repair me.ans to take
rapid action for the purpose of stopping
or reducing leakage of organic material
to the atmosphere using beat practices;,
Fractioaation operation means a
distillation operation or method used to
separate a mixture of several volatile
• components of different boiling points in
successive stages, each stage removing
from the mixture some proportion of one
of the components.
Hazardous waste management unit
shutdown means « work practice or
operational procedure that stops
operation of a hazardous waste
management unit or part of a hazardous
waste management unit An
unscheduled work practice or
operational procedure that stops
operation of a hazardous waste
management unit or part of a hazardous
wast* management unit for less than 24
hours is not a hazardous waste
management unit shutdown. The us« of
spare equipment and technically
feasible bypassing of equipment without
stopping operation are not hazardous
waste management unit shutdowns.
Hot well means a container for
collecting condensate as in a steam
condenser serving a vacuum-jet or
steam-jet ejector.
la gas/vapor service means that the
piece of equipment contains or contacts
a hazardous waste stream that is in the
gaseous state at operating conditions.
In heavy liquid service means that the
piece of equipment is not in gas/vapor
service or in light liquid service.
In light liquid service means that the
niiwji of equipment contains or contacts
a waste stream where the vapor
pressure of one or more of the •
components' in the stream is greater than
O3 kilopascals (kPa) at 20 *C. the total
concentration of the pure components
having a vapor pressure greater than OJ
kPa at 20 *C is. equal to or greater than
20 percent by weight, and the fluid is a
liquid at operating conditions.
In situ sampling systems means
nonextractive samplers or in-line
samplers.
In vacuum service means that
equipment is operating at an internal
pressure that is at least 5 kPa below
ambient pressure.
Malfunction means any sudden
failure of a control device or a
hazardous waste management unit or
failure of a hazardous waste
• management unit to operate in a normal
or usual manner, so that organic
emissions are increased.
• Open-ended valve or line means any
valve, except pressure relief valves,
having one side of the valve seat IE .
contact with process fluid and one side
open to the atmosphere, either directly
or through open piping.
Pressure release means the emission
of materials resulting from the system
pressure being greater than the set
pressure of the pressure relief device;
Process heater means a device that
transfers heat liberated by burning fuel
to fluids contained in tubes, including all
fluids except water that are heated to
produce steam.
Process vent means any open-ended
pipe or stack that is vented to the
atmosphere either directly, through a
vacuum-producing system, or through a
tank (e.g., distillate receiver, condenser.
bottoms receiver. sufg£ control tank,
separator tank, or hot well) associated
with hazardous waste distillation.
fractionation. thin-film evaporation,
solvent extraction, or air or steam
stripping operations.
Repaired means that equipment is
adjusted, or otherwise altered, to
eliminate a leak.
Sensor meant a device that measures
a physical quantity or the change in a
physical quantity, such as temperature,
pressure, flow rate, pH, or liquid level.
Separator tank means a device used
for separation of two immiscible liquids.
Solvent extraction operation means
an operation or method of separation in
which a solid or solution is contacted
with a liquid solvent (the two being
mutually insoluble) to preferentially
dissolve and transfer one or more
components into the solvent
Startup means the setting in operation
of a hazardous waste management unit
or control device for any purpose.
Steam stripping operation means a
distillation operation in which
vaporization of the volatile constituents
of a liquid mixture takes place by the
introduction of steam directly into the
charge.
Surge control tank means a large-
sized pipe or storage reservoir sufficient
to contain the surging liquid discharge of
the process tank to which it is
connected.
Thin-film evaporation operation
means a distillation operation that
employs a heating surface consisting of
a large diameter tube that may be either
straight'or tapered, horizontal or
vertical. Liquid is spread on the tube
wall by a rotating assembly of blades
that maintain a close clearance from the
wall or actually ride on the film of liquid
on the wall
Vapor incinerator means any
enclosed combustion device that is used
for destroying organic compounds and '
docis not extract energy in the form of
steum or process heat
Vented means discharged through an
opening, typically an open-ended pipe or
stack, allowing the passage of a stream
of liquids, gases, or fumes into the
atmosphere. The passage of liquids,
gases, or fumes is caused by mechanical
meisns such as compressors or vacuum-
producing systems or by process-related
means such as evaporation produced by
hea ting and not caused by tank loading
and unloading (working losses) or by
natural means such as diurnal
temperature changes.
§244.1032 Standards: Proeen vent*.
(a) The owner or operator of a facility
with process vents associated with
distillation, fractionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operations managing
hazardous wastes with organic
concentrations of at least 10 ppraw shall
either
(11) Reduce total organic emissions
from all affected process vents at the
facility below 1.4 kg/h {3 Ib/h) and 2.3
Mg/yr (3.1 tons/yr], or
(2!) Reduce, by use of a control device.
total organic emissions from all affected
process vents at the facility by 95 weight
percent
(b) If the owner or operator installs a
dosied-vent system and control device
to comply with the provisions of
paragraph (a) of this section the closed-
vent system and control device must
meat the requirements of § 284.1033.
(c) Determinations of vent emissions
and emission reductions or total organic •
compound concentrations achieved by
add-on control devices may be based on
engineering calculations or performance
tests. If performance tests are used to
determine vent emissions, emission
reductions, or total organic compound
concentrations achieved by add-on
control devices, the performance tests
mutit conform with the requirements of
i 264.1034(c).
-------
(d) When an owner or operator and
the Regional Administrator do not agree
on determinations of vent emissions
and/or emission reductions or total
organic compound concentrations
achieved by add-on control devices
based on engineering calculations, the
procedures in § 284.1034(c) shall be used
to resolve the disagreement
§264,1033 Standard*: CioMd-vwrt
•ysteme and control device*.
(a)(l) Owners or operators of closed-
vent systems and control devices used
to comply with provisions of this part
shall comply with the provisions of this
•ection*
(2) The owner or operator of an
existing facility who cannot install a
closed-vent system and control device
to comply with the provisions of this
subpart on me effective date that the .
facility becomes subject to the
provisions of this subpart must prepare
an implementation schedule that
includes dates by which the .closed-vent.
system and control device will be
installed and in operation. The controls
must be installed as soon as possible.
but the implementation- schedule may
allow up to 18 months after the effective
date that the facility becomes subject to
this subpart for installation and startup.
All units that begin operation after
December 21.1990. must comply with
the rules immediately (i.e.. must hava
control devices installed and operating
oo startup of the affected unit); the 2-
year implementation schedule does not
apply to these units.
(b) A control device involving vapor
recovery (e.g.. a condenser or adsorber)
shall be designed and operated to
recover the organic vapors vented to it
with an efficiency of 95 weight percent
or greater unless the total organic
emission limits of 1284.1032(a)(l) for all
affected process vents can be attained
al an efficiency lew than 95 weight
percent*
(c) An enclosed combustion device
(e.g» a vapor incinerator, boiler, or
process heater) shall be designed and
operated to reduce the organic
emissions vented to it by 95 weight
percent or greater to achieve a total
organic compound concentration of 20
ppmv. expressed as the sum of the
actual compounds, not carbon
equivalents, on a dry basis corrected to
3 percent oxygen: or to provide a
TplnJr""^ residence time of 0.50 seconds
at a minimum temperature of 760 "C. If a
boiler or process heater is used as the
control device, then the vent stream
shall be introduced into the flame zone
of the boiler or process heater.
(d)(l) A flare shall be designed for
and operated with no visible emissions
as determined by the methods specified
in paragraph (e)(l) of this section.
except for periods not to exceed a total
of 5 minutes during any 2 consecutive
hours.
(2) A flare shall be operated with a
flame present at all times, as determined
by the methods specified hi paragraph
(f)(2J(iii) of this section.
(3) A flare shall be used only if the net
heating value of the gas being
combusted is 11.2 MJ/scm (300 Btu/scf)
or greater if the flare is steam-assisted
or air-assisted: or if the net heating
value of the gas being combusted is 7.45
MJ/scm (200 Btu/scf) or greater if the
flare is nonassisted. The net heating
value of the gas being combusted shall
be determined by the methods specified
in paragraph (e}(2) of this section.
(4)(i) A steam-assisted or nonassisted
flare shall be designed for and operated
with an exit velocity, as determined by
the methods specified in paragraph
(e}(3) of this section, less than 1&3 m/s
(60 ft/s). except as provided in
paragraphs (d}(4) (U) and (iii) of this
section.
(ii) A steam-assisted or nonassisted
flare designed for and operated with an
exit velocity, as determined by the
methods specified in paragraph (e)(3) of
this section, equal to or greater than 1&3
m/s (60 ft/s) but less than 122 m/s (400
ft/s) is allowed if the net heating value
of the gas being combusted is greater
than 37.3 MJ/wan (1,000 Btu/scf).
(iii) A steam-assisted or nonassisted
flare designed for and operated with an
exit velocity, as determined by the
methods specified hi paragraph (e)(3) of
this section, less than the velocity, Vma,
as determined by the method specified
in paragraph (e)(4) of this section and
less than 122 m/s (400 ft/s) is allowed.
(5) An air-assisted flare shall be
designed and operated with an exit
velocity less than the velocity. V^ as
determined by the method specified in
paragraph (e)(5) of this section.
(8) A flare used to comply with this
section shall be steam-assisted, air-
assisted, or nonassisted.
(e)(l) Reference Method 22 in 40 CFR
part 60 shall be used to determine the
compliance of a flare with the visible
emission provisions of this subpart The
observation period is 2 hours and shall
be used according to Method 22.
(2) The net heating value of the gas
being combusted in a flare shall be
calculated using the following equation:
where:
Hr-Nel heating value of the sample. MJ/
acm: where the net enthalpy per mole of
offgas is based on combustion at 28 °C
aad TOO mm Hg. but the standard
temperature for determining the volume
corresponding to 1 mol is 20 'C:
K-Constant I74xl0-'(l/ppm) (g mol/scm)
(Mf/kcal) where standard temperature
for (g mol/scm) is 20 'C:
(^•Concentration of sample component i in
ppm on a wet basis, as measured for
organic* by Reference Method 18 in 40
CFR part 60 and measured for hydrogen
and carbon monoxide by ASTM 01948-
82 (incorporated by reference as
specified in i 280.11): and
H|**Net heat of combustion of sample
," component i. kcal/9 moi at 25'C and 760
mm Hg. The heata of combustion may be
determined using ASTM O 2382-33
(incorporated by reference as specified
in i 260.11) if published values are not
" available or cannot be calculated.
(3) The actual exit velocity of a'flare
shall be determined by dividing the
volumetric flow rate (in units of
standard temperature and pressure), as
determined by Reference Methods 2,2A,
2C. or 2D in 40 CFR part 60 as
appropriate, by the unobstructed (free)
cross-sectional area of the flare tip.
(4) The maximum allowed velocity in
m/s. Vmua for a flare complying with
paragraph (d)(4)(iii) of this section shall
be determined by the following
equation:
HT-K[SCM]
where:
283-CoruUnt,
31Ji> Constant
HT-TTie net healing value as determined in
paragraph (e)(2) of ml* section.
(5) The maximum allowed velocity in
m/s. VM, for an air-assisted flare shall
be determined by the following
equation:
Vwr»a.706+0.70M (Hr)
where:
arm-Constant
0.7084-Constant
Hr-The net heating value as determined in
paragraph (e)(2) of this section.
(f) The owner or operator shall
' monitor and inspect each control device
required to comply with this section to
ensure proper operation and
maintenance of the control device by
implementing the following
requirements:
(1) Install, calibrate, maintain, and
operate according to the manufacturer's
specifications a flow indicator that
provides a record of vent stream flow
from each affected process vent to the
control device at least once every hour.
The flow indicator sensor shall be
. installed in the vent stream at the
nearest feasible point to the control
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Federal Register / VoL 55. No. 120 / Thursday, June 21, 1990 / Suleii and Regulations
2S487'
devic* Inlet but before the point at
which the vent streams ate combined.
(2) Install, calibrate, maintain, and
operate according to the manufacturer's
specifics Hens a device to ermttnyi^fjy
monitor control device operation at
specified below: .
(0 For a thermal vapor incinerate*, a
temperature monitoring device equipped
with a continuous recorder. The device
ifaall have an accuracy of ±1 percent of
the temperature being monitored In *C
or ±
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25498 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
procedures specified in Reference
Method 21.
(4) Calibration gases shall be:
(i) Zero air (less than 10 ppm of
hydrocarbon in air). ,
(ii) A mixture of methane or n-hexane
and air at a concentration of
approximately, but less than, 10,000 ppm
methane or n-hexane.
(5) The background level shall be
determined as set forth in Reference .
Method 21.
(6) The instrument probe shall be .
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference.
Method 21.
(7) The arithmetic difference between
the maximum concentration indicated
by the instrument and the background
* level is compared with 500 ppm for
determining compliance.
(c) Performance tests to determine
compliance with § 264.1032(a) and with
the total organic compound
concentration limit of § 264.1033(c) shall
comply with the following:
(1) Performance tests to determine
total organic compound concentrations
and mass flow rates entering and exiting
control devices shall be conducted and
data reduced in accordance with the
following reference methods and
calculation procedures:
(i) Method 2 in 40 CFR part 60 for
velocity and volumetric flow rate.
B
E»=Q.- { 2 QMW, j [aonej [WTT
(ii) Method 18 in 40 CFR part 60 for
organic content
(iii) Each performance test shall
consist of three separate runs: each run
conducted for at least 1 hour under the
conditions that exist when the
hazardous waste management unit is
operating at the highest load or capacity
level reasonably expected to occur. For
the purpose of determining total organic
compound concentrations and mass
flow rates, the average of results of all
runs shall apply. The average shall be
computed on a time-weighted basis.
(iv) Total organic mass flow rates
shall be determined by the following
equation:
where:
Efi^Totai organic mass flow rate, kg/te
. Q^= Volumetric flow rate of gases entering
or exiting control device, a* determined
by Method 2. dson/h;
n - Number of organic compounds in the vent
gas:
C.= Organic concentration in ppm. dry basis.
of compound I in the vent gas. as
determined by Method 1ft
MW,=- Molecular weight of organic
compound i in the vent gas. kg/kg-mok
O.O418=" Conversion factor for molar volume.
kg-mol/m3 (@ 293 K and 760 mm Hgfc
10"*=* Conversion from ppm. ppm" '. '
(v) The annual total organic emission
rate shall be determined by the
following equation:
where:
E,=* Total organic mass emission rate, kg/y;
En=Tptal organic mass flow rate for the
process vent, kg/h:
ll=ToUl annual hours of operations for the
affected unit h.
(vi) Total organic emissions from ail
affected process vents at the facility
shall be determined by summing the
hourly total organic mass emission rates
(Efc as determined in paragraph (c)(l)(iv)
of this section) and by summing the
annual total organic mass emission rates
(E». as determined in paragraph (c)(l)(v)
of this section) for all affected process
vents at the facility.
(2) The owner or operator shall record
such process information as may be
necessary to determine the conditions of
the performance tests. Operations
during periods of startup, shutdown, and
malfunction shall not constitute
representative conditions for the
purpose of a performance test . •
(3) The owner or operator of an
affected facility shall provide, or cause
to be provided, performance testing
facilities as follows:
(i) Sampling ports adequate for the
test methods specified in paragraph
(c)(l) of this section.
(ii) Safe sampling platform(s).
(iii) Safe access to sampling
platform(s).
(iv) Utilities for sampling and testing
equipment
(4) For the purpose of making
compliance determinations, the time-
weighted average of the results of the
three runs shall apply. In the event that
a sample is accidentally lost or
conditions occur, in which one of the
three runs must be discontinued because
of forced shutdown, failure of an
irreplaceable portion of the sample
train, extreme meteorological
conditions, or other circumstances
beyond the owner or operator's control,
compliance may. upon the Regional
Administrator's approval, be determined
using the average of the results of the
two other runs.
(d) To show that a process vent
associated with a hazardous waste
distillation, fractionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operation is not subject
to the requirements of this subpart, the
owner or operator must make an initial
determination that the time-weighted,
annual average total organic
concentration of the waste managed by
the waste management unit is less than
10 ppmw using one of the following two
methods:
(1) Direct measurement of the organic
concentration of the waste using the
following procedures:
(i) The owner or operator must take a
minimum of four grab samples of waste
for each waste stream managed in the
affected unit under process conditions
expected to cause the maximum waste
organic concentration.
(ii) For waste generated onsite. the
grab samples must be collected at a
point before the waste is exposed to the
atmosphere such as in an enclosed pipe
or other closed system that is used to
transfer the waste after generation to
the first affected distillation.
fractionation, thin-film evaporation,
solvent extraction, or air or steam'
stripping operation. For waste generated
offsite, the grab samples must be
collected at the inlet to the first waste
management unit that receives the
waste provided the waste has been
transferred to the facility in a closed
system such as a tank truck and the
waste is not diluted or mixed with other
waste.
(iii) Each sample shall be analyzed
and the total organic concentration of
the sample shall be computed using
Method 9060 or 8240 of SW-848
(incorporated by reference under
} 260.11).
(iv) The arithmetic mean of the results
of the analyses of the four samples shall
apply for each waste stream managed in
the unit in determining the time-
weighted, annual average total organic
concentration of the waste. The time-
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Federal Register / VdL 55. No. 120 / Thursday. June ZL 1996 / Rulen and Regulation* 2S3B§
welghted-ewerageit to be calculated
using the annual quantity of each wast*
stream processed and the mean organic
concentration of-each waste stream
tna&agedfinths) unit.
(2) Using knowledge of the waste ta
datcnnine -that its total organic
concentration is lets than 10 ppmw.
Documentation of the wast*
dsterminsiion is required. Examples of
documentation that shall b* Died to
support A {latarmi&ation iimfof *hi«
provision include production peaces*
information di?5?iimffnHng that no'Organic
compounds an used, information that
the waste is generated by a process that
is identical to « process at the same or
another facility that has previously been
demonstratediby direct measurement to
generate a waste stream having a total
organic content less than 10 ppmw. or
prior spedation analysis results on the
same wnte stream where it can also be
documented that no process-changes
have occurred since that analysis that
could affect the waste total organic
concentration.
IP) The determination that distillation,
fractionatlon. thin-film evaporation!
solvent extraction, or air or steam
stripping operations manage hazardous
wastes-with time-weighted, annual
average total organic concentrations
less than 10 ppmw shall be made as
follows:
(1) By the-efleclive date that the
fadHry teeomes zubiect to the
previsions of this subpart or by the date
when the waste-is first managed in a
waste management unit, wbichever-is
later, and
(2) For continuously generated waste.
aonaalry, or
(3) Whenever there Is a change in the
waste being managed or a change in the
process that generates or treats the
waste.
(f) When an owner or operator and
the Regional Administrator do not agree
on whether a distillation, fractionation.
thin-film evaporation, solvent
extraction, or air or steam stripping
operation manages a hazardous waste
with organic concentrations of at least
10 ppmw based on knowledge-of the
waste, the procedures in Method 6240
may be used to resolve the dispute.
J2M.103S fteconttCMpIng nqukamwitt.
(a)fl) Each owner or operator subject
to the provisions of this suhpart shall
comply with the recordkeeping
requirements of this section.
(2) An owner or operator of more than
one hazardous waste management unit
subject to the provisions of this subpart
may comply with the recordkeeping
requirements for these hazardous waste
management units in one recordkeeping
system if the ay item identifies each
record by each hazardous waste
management-unit
•(b) Owners and operators must record
the following information ic the facility
operating xecord:
(1) For facilities mat comply with the
provisions of 1 2644033(a)(2J, an
implementation schedule that includes .
dates by which the dosed- vent .system
and control -device will be installed and
in operation. The schedule must also
include a rationale -of why the
^n1?^ be completsd at an
earlier data. The implementation
schedul* must-be in die facility
operating record by the effective date
that the facility becomes subject to the
provisions of this sabpart
(2) Up-to-date documentation of
compliance with the process vent
standards hi I 264.1032. including:
(ij Information and data identifying all
affected process vents, annual
throughput and operating hours of each
affected-unit, .estimated emission rates
for each affected vent and for the
overall facility (La» the total emissions
for all affected vents at the -facility). and
the approximate location within the
facility of each affected unit (e.g..
identify the hazardous waste
management units on a facility plot
plan).
(ii) Information and data supporting
determinations of -rent emissions and
emission reductions achieved by add-on
control devices basea on engineering
calculations or-source tests. Forthe
purpose of determining compliance.
determinations of vent emissions and
emission reductions must be made Basing
operating parameter-values (e.g.,
temperatures, flow rates, or •vest stream
• organic compounds and concentrations)
that represent -the conditions that result
in maximum organic emissions, such aa
when the waste management unit is
operating at the highest load or capacity
level reasonably expected to occur. If
the owner or operator takes any action
(e.g.. managing a waste of different
composition or increasing operating
hours of -affected waste management
units) that would result in an increase in
total organic emissions from affected
process vents at the facility, then a new
determination is required.
(3) Where an owner or operator
chooses to use-test data to determine the
organic removal efficiency or total
organic compound concentration
achieved by the control device, a
performance test plan. The test plan
must include:
(i) A description of how it is
determined tout the planned test is going
to b« conducted when the hazardous
waste management unit is operating at
the highest load or capacity level
reasonably expected to occur. This shall
include the«rtimated or design flow rate
and organic-contest of each vent stream
and define,the acceptable operating
ranges isflcey-procesa and control device
parameters dicing the test program.
(if) & detailed engineering description
of the closed-vent system and control
device including;
(A) Manufacturer's name and model
number of control device.
(B) T;rpe of control device.
(C) 'Dimensions of the control device.
(D) Capacity.
IE] Gjnstruction materials.
(iiij A detailed description of sampling
and monitoring procedures, including
sampling and-monitoring locations in the
system, the-equipment to be used.
sampling and monitoring frequency, and
planned.analytical procedures for
sample analysis.
{«! Oocumentatioa of compliance with
| 2B4.KB3shall indude the following
infonnsiSian:
•(i) A list of all information references
and sources used in preparing the
documentation.
(ii) Risoords indudhig the-dales of
each compliance lest required by
f 284.ieB3(k).
(Ui) If engineering calculations are
used..a design analysis, specifications,
drawings, schematics, and piping and
instrumentation diagrams based on the
appropriate sections of "APT! Course
415: Control of Caseous Emissions"
(incorporated by reference as specified
hi S 26CL11) or other engineering texts
acceptable 4o the Regional
Administrator that present basic control
device design information.
DocumiuUation provided oy the control
device manufacturer or vendor that
describes the control device design hi
accordance with paragraphs
(b)(4MUi}(A) through (b)(4)(iii](G) of this
section may be used to comply with this
requirement The design analysis shall
addresii the vent stream characteristics
and control device operation parameters
as specified below.
(A) For a thermal vapor incinerator.
the design analysis shall consider the
vent stream composition, constituent
concentrations, and flow rate. The
design unalysis shall also establish the
design minimum and average
temperature in the combustion zone and
the combustion zone residence time.
(B) For a catalytic vapor incinerator.
the design analysis shall consider the
vent stream composition, constituent
concenlirations. and Sow rate. The
design analysis shall also establish the
design minimum and average
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25380 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 19SO / Rules and Regulations
temperatures across the catalyst bed
inlet and outlet.
(C) For a boiler or process heater, the
design analysis shall consider the vent
stream composition, constituent
concentrations, and flow rate. The
design analysis shall also establish the
design minimum and average flame zone
temperatures, combustion zone
residence time, and description of
method and location where the vent
stream is introduced into the
combustion zone.
(Dl For a flare, the design analysis
shall consider the vent stream
composition, constituent concentrations,
and flow rate. The design analysis shall
also consider the requirements specified
in S 284.1033(d).
(E) For a condenser, the design
analysis shall-consider the vent stream
composition, constituent concentrations,
flow rate, relative humidity, and
temperature. The design analysis shall
also establish the design outlet organic
compound concentration level, design
average temperature of the condenser
exhaust vent stream, and design average
temperatures of the coolant fluid at the
condenser inlet and outlet
(F) For a carbon adsorption system
such as a fixed-bed adsorber that
regenerates the carbon bed directly
ooiite in the control device, the design
analysis shall consider the vent stream
composition, constituent concentrations.
flow rate, relative humidity, and
temperature. The design analysis shall
also establish the design exhaust vent
stream organic compound concentration
level, number and capacity of carbon
beds, type and working capacity of
activated carbon used for carbon beds.
design total steam flow over the period
of each complete carbon bed
regeneration cycle, duration of the
carbon bed steaming and cooling/drying
cycles, design carbon bed temperature
after regeneration, design carbon bed
regeneration time, and design service
life of carbon.
(G) For a carbon adsorption system
such as a carbon canister that does not
regenerate the carbon bed directly
onsite in the control device, the design
analysis shall consider the vent stream
composition, constituent concentrations,
flow rate, relative humidity, and
temperature. The design analysis shall
also establish the design outlet organic
concentration level, capacity of carbon
bed. type and working capacity of
activated carbon used for carbon bed.
and design carbon replacement interval
based on the total carbon working
capacity of the control device and
source operating schedule.
(iv) A statement signed and dated by
the owner or operator certifying that the
operating parameters used in the design
analysis reasonably represent the
conditions that exist when the
hazardous waste management unit is or
would be operating at the highest load
or capacity level reasonably expected to
occur.
(v) A statement signed and dated by
the owner or operator certifying that the
control device is designed to operate at
an efficiency of 95 percent or greater
unless the total organic concentration
limit of § 2S4.1032(a) is achieved at an
efficiency less than 95 weight percent or
the total organic emission limits of
S 264.1032(a) for affected process vents
at the facility can be attained by a
control device involving vapor recovery
at an efficiency less than 95 weight
percent A statement provided by the
control device manufacturer or vendor
certifying that the control equipment'
meets the design specifications may be
used to comply with this requirement
(vi) If performance tests are used to
demonstrate compliance, all test results.
(c) Design documentation and
monitoring, operating, and inspection
information for each closed-vent system
and control device required to comply
with the provisions of this part shall be
recorded and kept up-to-date in the
facility operating record. The
information shall include:
(1) Description and date of each
modification that is made to the closed-
vent system or control device design.
(2) Identification of operating
parameter, description of monitoring
device, and diagram of monitoring
sensor location or locations used to
comply with 5 264.1033 (f)(l) and (f)(2).
(31 Monitoring, operating, and
inspection information required by
paragraphs (f) through (k) of § 204.1033.
(4) Date. time, and duration of each
period that occurs while the control
device is operating when any monitored
parameter exceeds the value established
in the control device design analysis as
specified below:
(i) For a thermal vapor incinerator
designed to operate with a minimum
residence time of 0.50 second at a
minimum temperature of 760 "C. period
when the combustion temperature is
below 760 "C.
(ii) For a thermal vapor incinerator
designed to operate, with an organic
emission reduction efficiency of 95
weight percent or greater period when
the combustion zone temperature is
more than 28 *C below the design
average combustion zone temperature
established as a requirement of
paragraph (b)(4)(iii)(A] of this section.
(iii) For a catalytic vapor incinerator.
period when: ,
(A) Temperature of the vent stream at
the catalyst bed inlet is more than 28 'C
below the average temperature of the
inlet vent stream established as a
requirement of paragraph (b)(4)(iii)(B] of
this section, or ^
(B) Temperature difference across the
catalyst bed is less than 80 percent of
the design average temperature
difference established as a requirement •
of paragraph (b)(4)(iii)(B) of this section.
(iv) For a boiler or process heater.
period when:
(A) Flame zone temperature is more
than 28 *C below the design average
•flame zone temperature established as a
requirement of paragraph (b)(4Miii)(C) of
this section, or
(B) Position changes where the vent
stream is introduced to the combustion
zone from the location established as a
requirement of paragraph (b)(4)(iii)(C) of
this section.
(vj For a flare, period when the pilot
flame is not ignited.
(vi) For a condenser that complies
with S 284.1033(f)(2)(vi){A)..period when
the organic compound concentration
level or readings of organic compounds
in the exhaust vent stream from the
condenser are more than 20 percent
greater than the design outlet organic
compound concentration level
established as a requirement of
paragraph (b)(4)(iii)(E) of this section.
(vii) For a condenser that complies
with S 264.1033(fK2)(vi)(B), period when:
(A) Temperature of the exhaust vent
•tream from the condenser is more than
6 *C above the design average exhaust
vent stream temperature established as
a requirement of paragraph (b)(4)(iii)(E)
of this section: or
(B) Temperature of die coolant fluid
exiting the condenser is more than 8 *C
above the design average coolant fluid
temperature at the condenser outlet
established as a requirement of
paragraph (b)(4)(iii)(E) of this section.
(viii) For a carbon adsorption system
such as a fixed-bed carbon adsorber
that regenerates the carbon bed directly
onsite in the control device and
complies with S 264.1033(f)(2)(vii)(A).
period when the organic compound
concentration level or readings of
organic compounds in the exhaust vent
stream from the carbon bed are more
than 20 percent greater than the design
exhaust vent stream organic compound
concentration level established as a
requirement of paragraph (b)(4)(iii)(F) of
this section.
(ix) For a carbon adsorption system
such as a fixed-bed carbon adsorber
that regenerates the carbon bed directly
onsite in the control device and
complies with S 2e4.1033(f)(2)(vii)(B).
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rul«s and Regulations. 25501
period when the vent stream continues
to flow through the control device
- beyond the predetermined carbon bed
regeneration time established as a
requirement of paragraph (b)(4)(iii)[F) of
this section.
(5) Explanation for each period
recorded under paragraph (4) of the
cam* for control device operating
parameter exceeding the design value
and the measures implemented to
correct the control device operation.
(0) For a carbon adsorption system
operated subject to requirements
specified in i 284.1033(g) or
. i 2S4.1033(h)(2). date when existing
carbon in the control device is replaced
with fresh carbon.
(7) For a carbon adsorption system
operated subject to requirements
. specified in { 284,1033(h](l), a log that
records:
(i) Date and time when control device
is monitored for carbon breakthrough
and the monitoring device reading.
(it) Date when existing carbon in the
control device is replaced with fresh
carbon.
(8) Date of each control device startup
and shutdown..
(d) Records of the monitoring,
operating, and inspection information
required by paragraphs (cpHc}(8) of
this section need be kept only 3 years.
(e) For a control device other than a
thermal vapor incinerator, catalytic
vapor incinerator, flare, boiler, process
heater, condenser, or carbon adsorption
system, the Regional Administrator will
specify the appropriate recordkeeping
requirements.
. (f) Up-to-date information and data
used to determine whether or not a
process vent is subject to the
requirements in 1284.1032 including
supporting documentation as required
by 1264.1034(d)(2) when application of
the knowledge of the nature of the
hazardous waste stream or the process
by which it was produced is used, shall
be recorded in a log that is kept in the
facility, operating record.
(Approved by the Office of Management and
Budget under control number 2080-0195)
1284.103* Reporting requirements.
(a) A semiannual report shall be
submitted by owners and operators
subject to the requirements of this
subpart ta the Regional Administrator
by dates specified by the Regional
Administrator. The report shall include
the following information:
(1) The Environmental Protection
Agency identification number, name.
and address of the facility.
(2) For each month during the
semiannual reporting period, dates
when the control device exceeded or
operated outside of the design .
specifications as defined in
S 284.1035(c)(4) and as indicated by the
control device monitoring required by
i 2&4.1033(f) and such exceedances
were not corrected within 24 hours, or
that a flare operated with visible
emissions as defined in § 284.1033(d)
and as determined by Method 22
monitoring, the duration and cause of
each exceedance or visible emissions.
and any corrective measures taken.
(b) If. during the semiannual reporting
period, the control device does not
exceed or operate outside of the design
specifications as defined in
I 264.103S(c)(4J for more than 24 hours
or a flare does not operate with visible
emissions as defined in § 264.1033(d}. a
report to the Regional Administrator is
not required.
(Approved by the Office of Management and
Budgefunder control number 2060-0195)
$§264.1037-284.1649 [Reserved!.
11/40 CFH part 284 is amended fay
adding subpart BB to read as follows:
Subpart 88—Air Emission Standards for
Equipment Leaks
204.1050 Applicability.
284.1051 Definitions.
264.1052 Standards: Pump* in light liquid
service.
284-1053 Standards: Compressors.
284.1054 Standards: Pressure relief devices
in gas/vapor service.
254.1055 Standards: Sampling connecting
systems.
264.1058 Standards: Open-ended valves or
lines.
2S4.1057 Standards: Valves in gas/vapor
service or in light liquid service.
284.1058 Standards: Pumps and valve* in
heavy liquid service, pressure relief
devices in light liquid or heavy liquid
service, and flanges and other
connectors.
204.1059 Standards: Delay of repair.
264.1000 Standards: Closed-vent systems
and control devices.
264.1081 Alternative standards for valves in
gas/vapor service or in light liquid
service: percentage of valves allowed to
leak. '
264.1062 Alternative standards for valves in
gas/vapor service or in light liquid
service: skip period leak detection and
repair.
264.1063 Test methods and procedures.
264.1064 Recordkeeping requirements.
284.1065 Reporting requirements.
264.1066-264.1079 (Reserved)
Subpart BB—Air Emission Standards
for Equipment Leaks
§284.1050 Applicability.
(a) The regulations in this subpart
apply to owners and operators of
facilities that treat, store, or dispose of
hazardous wastes (except as provided
in § 2M.1).
(b) ISxcept as provided in
§ 284.ll084(k). this subpart applies to
equipment that contains or contacts
hazardous wastes with organic
concentrations of at least 10 percent by
weighll that are managed in:
(i) Units that are subject to the
permitting requirements of part 270. or
(2) Hazardous waste recycling units
that aiw located on hazardous waste
• management facilities otherwise subject
to the permitting requirements of part
270.
(c) 11; the owner or operator of
equipment subject to the requirements
of §| 264.1052 through 264.1065 has
received a permit under section 3005 of
RCRA prior to December 21. 1990. the
requirements of §§ 284.1052 through
284.10(15 must be incorporated when the
permit is reissued under 1 124.15 or
reviewed under § 270.50.
(d) Black piece of equipment to which
this subpart applies shall be marked in
such a manner that it can be
distinguished readily from other pieces
of equipment
(e) Equipment that is in vacuum
service is excluded from the
requirements of 5 264.1052 to § 264.1060
if it is identified as required in
S 2B4.1064(g}(5).
[Note: The requirements of $$264.1052 '
through 264.1085 apply to equipment
associated with hazardous waste recycling
units prsviously exempt under $ 261.6(c)(l).
Other exemptions under §§ 261.4. 262.34. and
264.1(g) are not affected by these
requirements.]
§ 264.KIS1 Definitions.
As uiied in this subpart, all terms shall
have the meaning given them in
§ 284.11)31. the Act and parts 260-2G6.
i 264.10 52 Standards: Pumps In light liquid
(a)(l] Each pump in light liquid service
shall bit monitored monthly to detect
leaks by the methods specified in
S 284.1()63(b), except as provided in
paragraphs (d), (e), and (f) of this
section,
(2! Each pump in light liquid service
shall b<> checked by visual inspection
each calendar week for indications of
liquids dripping from the pump seal.
(b)(l) If a instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(2) If there are indications of liquids •
dripping from 'the pump seal, a leak is
detected.
(c)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
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IS9Q I Rules and Regulations
detected, except as provided in-
§264.1059.
(2j A first attempt at repair (e.g,
tightening the packing gland] shall be
made no later than 5 calendar days after
each leak is detected.
(d) Each pump equipped with a dual.
mechanical seal system that includes a
' barrier fluid system is exempt from the
requirements of paragraph (a) of this
section, provided the following
requirements are met:
(1) Each dual mechanical seal system
must bes
(i) Operated with the barrier fluid at a
pressure that is at all times greater than
the pump stuffing box pressure, or
(ii) Equipped with' a barrier fluid
degassing reservoir that is connected by
a closed-vent system to a control device
that complies with the requirements of
§ 264.1080. or
(iii) Equipped with a system that
purges the barrier fluid info a hazardous.
waste stream with no detectable
emissions to the atmosphere.
(2) The barrier fluid system must not
be a hazardous waste with organic
concentrations 10 percent or greater by
weight
(3) Each barrier fluid system must be
equipped with a sensor that will detect
failure of the seal system, the barrier
fluid system, or both.
(4) Each pump must be checked by
visual inspection, each calendar week.
for indications of liquids dripping from
the pump seals.
(5](i) Each sensor as described in
paragraph (d](3) of this section must be
checked daily or be equipped with aa
audible alarm that must be checked
monthly to ensure that it is functioning
property.
(ii) The owner or operator must
determine, based on design
considerations and operating
experience, a criterion that indicates
failure of the seal system, the barrier
fluid system, or both.
(6)(i) If there are indications of liquids
dripping from the pump seal or the
sensor indicates failure of the seal
system, the barrier fluid system, or both
based on the criterion determined in
paragraph (d);S)(ii) of this section, a leak
is detected.
(ii) When a leak is detected, it shall be
repaired'as soon as practicable, but not
later than 15 calendar days after it is
detected, except as provided in
§264.1059.
(iii) A first attempt at repair (e.g..
relapping the seal) shall be made no
later than 5 calendar days after each
leak is detected.
(e) Any pump that is designated, as
described in § 2S4.1064(g)(2). for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, is exempt from the
requirements of paragraphs (a), (c), and
(d) of this section if the pump meets the
following requirements!
(1) Must have no externally actuated
shaft penetrating the pump housing.
(2) Must operate with no detectable
emissions as indicated by an Instrument
reading of less than 500 ppm above
background as measured by the
methods specified in § 264.l063(c).
(3) Must be tested for compliance with
paragraph (e}(2) of this section initially
upon designation, annually, and-at other
times as requested by the Regional
Administrator.
(!) If any pump is equipped with a .
closed-vent system capable of capturing
and transporting any leakage from the
seal or seals to a control device that
complies with the requirements of .
§ 284.1060, it is exempt from the
requirements of paragraphs (a) through
(e) of this section.
§264.1053 Standards: Compressor*.
(q) Each compressor shall be equipped
with e seal system that includes a
barrier fluid system and that prevents
leakage of total organic emissions to the
atmosphere, except as provided in
paragraphs (h) and (i) of this section.
(b) Each compressor seal system as
required in paragraph (a) of this section
shall be:
(1) Operated with the barrier fluid at a
pressure that is at all times greater than
the compressor stuffing box pressure, or
(2) Equipped with a barrier fluid
system that is connected by a closed-
vent system to a control device that
complies with the requirements of
§ 284.1060, or .
(3) Equipped with a system that
purges the barrier fluid into a hazardous
waste stream with no detectable
emissions to atmosphere.
(c) The barrier fluid-must not be a
hazardous waste with organic
concentrations 10 percent or greater by
weight
(d) Each barrier fluid system as
described in paragraphs (a) through (c)
of this section shall be equipped with a
sensor that will detect failure of the seal
system, barrier fluid system, or both.
(e)(l) Each sensor as required in
paragraph (d) of this section shall be
checked daily or shall be equipped with
an audible alarm that must be checked
monthly to ensure that it is functioning
properly unless the compressor is
located within the boundary of an
unmanned plant site, in which case the
sensor must be checked daily.
(2) The owner or operator shall
determine, based on design
considerations and operating
experience, a criterion that indicates
failure of the seal system, the barrier
fluid system, or both.
(f) If the sensor indicates failure of the
seal system, the barrier fluid system, or
both based on the criterion determined
under paragraph (e](2) of this section, a
leak is detected.
(g)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than 13 calendar days after it is
detected, except as provided in
] 264.3059.
(2) A first attempt at repair (e.g.,
tightening the packing gland) shall be
made no later than 5 calendar days after
each leak is detected.
(h) A compressor is exempt from the
requirements of peragraphs (a) and (b)
of this section if it is equipped with a
closed-vent system capable of capturing
and transporting any leakage from the
seal to a control device that complies
with the requirements of § 284.1060,
except as provided in paragraph (i) of
this section.
(i) Any compressor that is designated,
as described in § 284.1064(g)(2). for no
detectable emissions as indicated by an
instrument reading of less than 500 ppm
above background is exempt from the
requirements of paragraphs (a) through
(h) of this section if the compressor:
(1) Is determined to be operating with
no detectable emissions, as indicated by
an instrument reading of less than 500
ppm above background, as measured by
the method specified in § 284.1063(c).
(2) Is tested for compliance with
paragraph (i)(l) of this section initially
upon designation, annually, and at other
times as requested by the Regional
Administrator.
$264.1054 Standards: Pressure relief
device* In gas/vapor service.
(a) Except during pressure releases.
each pressure relief device in gas/vapor
service shall be operated with no
detectable emissions, as indicated by an
Instrument reading of less than 500 ppm
above background, as measured by the
method specified in S 264.1063(c).
(b)(l) After each pressure release, the
pressure relief device shall be returned
to a condition of no detectable
emissions, as indicated by an instrument
reading of less than 500 ppm above
background, as soon as practicable, but
no later than 5 calendar days after each
pressure release, except as provided in
§ 264.1059.
(2} No later than 5 calendar days after
the pressure release, the pressure relief
device shall be monitored to confirm the
condition of no detectable emissions, as
indicated by an instrument reading of
less than 500 ppm above background, as
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Federal Register / Vol. 55t No. 120 / Thursday. June 21. 1980 / Rules and Regulations 25503
measured by the method specified In
12C4.lOB3(c).
(c) Any pressure relief device that li
•quipped with • cioted-vent «y»tem
capable of capturing and transporting
leakage from the pressure relief device
to a control device as described in
1284.1060 is exempt from the
requirements of paragraphs (a) and (b)
of this section.
! 204.1035 Standards: Sampling
coofiecun^i system*.
(a) Each sampling connection system
shall be equipped with a closed purge
system or closed-vent system.
(b) Each closed-purge system or
closed-vent system as required tar
paragraph (a) shall:
(1} Return the purged hazardous waste
stream directly to the hazardous waste
management process line with no
detectable emissions to atmosphere, or
(2) Collect and recycle the purged
hazardous waste stream with no
detectable emissions to atmosphere, or
(3) Be designed and operated to
capture and transport all the purged
hazardous waste stream to 'a control
device that complies with the
requirements of § 264.1060. .
(c) In »iiu sampling systems are
exempt from the requirements of
paragraphs (a) and (b] of this section.
12*4.105* Standards; Open-ended valve*
or few*.
(a)(l) Each open-ended valve or line
shall be equipped with a cap. blind
flange, plug, or a second valve.
(2) The cap, blind flange, plug, or
second valve shall seal the open end at
all times except during operations .
requiring hazardous waste stream flow
through the open-ended valve or line.
(b) Each open-ended valve or line
equipped with a second valve shall be
operated in a manner such that the
valve on the hazardous waste stream
end is closed before the second valve is
closed.
(c) When a double block and bleed
system is being used, the bleed valve or
line may remain open during operations
that require venting the line between the
block valves but shall comply with
paragraph (a) of this section at all other
times.
12*4.1057 Standards:Vatv«*togas/vapor
service or In KoM Squid aenric*.
(a) Each valve In gas/vapor or light
liquid service shall be monitored
monthly to detect leaks by the methods
specified in i 2B4.l003(b) and shall
comply with paragraphs (b) through (e)
of this section, except as provided in
paragraphs (f). (g), and (h) of this
section, and 15 264.1081 and 264.1062.
(b) If an instrument reading of 10,000
ppm or greater is measured, a leak is
detected.
(c](l) Any valve for which a leak is
not detected for two successive months
may be monitored the first month of
every succeeding quarter, beginning
with the next quarter, until a leak is
detected.
(2) If a leak is detected, the valve shall
be monitored monthly until a leak is not
detected for two successive months,
(d)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
no later than 15 calendar days after the
leak is detected, except as provided in
I 284.1059.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(e) First attempts at repair include, but
are not limited-to, the following best
practices where practicable:
(1) Tightening of bonnet bolts.
(2) Replacement of bonnet bolts.
(3) Tightening of packing gland nuts.
(4) Injection of lubricant into
lubricated packing.
(f] Any valve that is designated, as
described in i 2B4.1064(g)(2). for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, is exempt from the
requirements of paragraph (a) of this
section if the valve:
(1) Has no external actuating
mechanism in contact with the
hazardous waste stream.
(2) Is operated with emissions less
than 500 ppm above background as
determined by the method specified in
I 284.1063(0).
(3) Is tested for compliance with
paragraph (f)(2) of this section initially
upon designation, annually, and at other
times as requested by the Regional
Administrate?.
(g) Any valve that is designated, as
described In S 284.l064(h)(l). as an
unsafe-to-monitor valve is exempt from
the requirements of paragraph (a) of this
section if:
(1) The owner or operator of the valve
determines that the valve is unsafe to
monitor^because monitoring personnel
would be exposed to an immediate
danger as a consequence of complying
with paragraph (a) of this section.
(2) The owner or operator of the valve
adheres to a written plan that requires
monitoring of the valve as frequently as
practicable during safe-to-monitor times.
(h) Any valve that is designated, as
described in § 2S4.1064(h)(2), as a
difficult-to-monitor valve la exempt from
the requirements of paragraph (a) o&this
section if:
(1) The owner or operator of the valve
determines that the valve cannot be
monitored without elevating the
monitoring personnel more than 2
meteirs above a support surface.
(2) The hazardous waste management
unit within which the valve is located
was in operation before June 21,1990.
(3) The owner or operator of the valve
follows e written plan that requires
monitoring of the valve at least once per
calendar year.
§2S4.105S Standards: Pumpa and valves
In heiivy liquid service, pressure relief
devtoM In light liquid or heavy liquid
eervka, and flange* and other connectors.
(a) Pumps and valves in heavy liquid
service, pressure relief devices in light
liquid! or heavy liquid service, and
flanges and other connectors shall be
monitored within 5 days by the method
specified in 9 264.1063(b) if evidence of
a potential leak is found by visual.
audible, olfactory, of any other
detection method.
(b) If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(e)(I) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than IS calendar days after it is
detected, except as provided in
S 264.1059.
• (2) 'Hie first attempt at repair shall be
. made no later than 5 calendar days after
each lleak is detected.
(d) first attempts at repair include.
but ai« not limited to, the best practices
described under § 2B4.10S7(e). .
§264.1059 Standards: Delay of repair.
(a) Delay of repair of equipment for
whicti leaks have been detected will be
allowed if the repair is technically
infeaiibie without a hazardous waste
management unit shutdown. In such a
case, irepair of this equipment shall
occur before the end of the next
hazardous waste management unit
shutdown.
(b) Delay of repair of equipment for
which leeks have been detected will be
allowisd for equipment that is isolated
from the hazardous waste management
unit and that does not continue to
contain or contact hazardous waste with
organic concentrations at least 10
percent by weight
(c) Delay of repair for valves will be
allowed if:
(1) irhe owner or operator determines
that emissions of purged material
resulting from immediate repair are
greater than the emissions likely'to
result from delay of repair.
(2) When repair procedures are
effected, the purged material is collected
and destroyed or recovered in a-control
devica complying with § 264.1060.
-------
(d) Delay of repair for pumps will be
allowed if:
(1) Repair requires the use of a dual
mechanical seal system that includes a
barrier fluid system.
(2) Repair is completed as soon as *
practicable, but not later than 5 months
after the leak was detected.
(e) Delay of repair beyond a
hazardous waste management unit
shutdown will be allowed for a valve if
valve assembly replacement is
necessary during the hazardous waste
management unit shutdown, valve
assembly supplies have been depleted,
and valve assembly supplies had been
sufficiently stocked before the supplies
were depleted. Delay of repair beyond
the next hazardous waste management
unit shutdown will not be .allowed
unless the next hazardous waste
management unit shutdown occurs
sooner than 8 months after the first
hazardous waste management unit, •
shutdown.
§284.1060 Standard* Closed-vent
system* and control device*.
Owners or operators of closed-
vent systems and control devices shall
comply with the provisions of
5 264.1033.
$264.1061 Alternative standard* for
valve* to gas/vapor service or In light liquid
service; percentage of valve* allowed to
teak.
(a) An owner or operator subject to
the requirements of § 264.1057 may elect
to have all valves within a hazardous
waste management unit comply with an
alternative standard that allows no
greater than 2 percent of the valves to
leak.
(b) The following requirements shall
be met if an owner or operator decides
to comply with the alternative standard
of allowing 2 percent of valves to leak:
(1) An owner or operator must notify
the Regional Administrator that the
. owner or operator has elected to comply
with the requirements of this section.
(2) A performance test as specified in
paragraph (c) of this section shall be
conducted initially upon designation.
annually, and at other times requested
by the Regional Administrator.
(3) If a valve leak is detected, it shall
be repaired in accordance with
§ 264.1057(d) and (e).
(c) Performance tests shall be
conducted in the following manner
(1) All valves subject to the
requirements in § 264.1057 within the
hazardous waste management unit shall
be monitored within 1 week by the
methods specified in 5 284.1063(b).
(2) If an instrument reading of 10,000
ppm or greater is measured, a leak is
detected.
(3) The leak percentage shall be
determined by dividing the number of
valves subject to the requirements in
§ 264.1057 for which leaks are detected
by the total number of valves subject to
the requirements in § 264.1057 within the
hazardous waste management unit
(d) If an owner or operator decides to
comply with this section no longer, the
owner or operator must notify the
Regional Administrator in writing that
' the work practice standard described in
§ 264.1057(a) through (e) will be
followed.
§264.1062 Alternative standards for
valve* In gas/vepor service or in Ufiht liquid
sendee: skip period leak detection and
(a)(l) An owner or operator subject to
the requirements of § 264.1057 may elect
for all valves within a hazardous waste
management unit to comply with one of
the alternative work practices specified
in paragraphs (b) (2) and (3) of this
section.
(2) An owner or operator must notify
the Regional Administrator before
implementing one of the alternative
work practices.
(b)(l) An owner or operator shall
comply with the requirements for
valves, as described in J 264.1057,
except as described in paragraphs (b)(2)
and (b)(3) of this section. • •
(2) After two consecutive quarterly
leak detection periods with the
percentage of valves leaking equal to or
less than 2 percent, an owner or
operator may begin to skip one of the
quarterly leak detection periods for the
valves subject to the requirements in
1 264.1057.
(3) After five consecutive quarterly
leak detection periods with the
percentage of valves leaking equal to or
less than 2 percent, an owner or
operator may begin to skip three of the
quarterly leak detection periods for the
valves subject to the requirements in
§ 264.1057.
(4) If the percentage of valves leaking
is greater than 2 percent, the owner or
operator shall monitor monthly in
compliance with the requirements in
§ 284.1057, but may again elect to use
this section after meeting the
requirements of § 264.1057(c)(l).
(Approved by the Office of Management and
Budget under control number 2060-0195)
{264.1063 Te«t methods and procedure*.
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the test methods and
procedures requirements provided in
this section.
(b) Leak detection monitoring, as
required in §§ 264.1052-264.1062. shall
comply with the following requirements:
(1) Monitoring shall comply with
Reference Method 21 in 40 CFR part.60.
(2) The detection instrument shall
meet the performance criteria of'
Reference Method 21.
(3) The instrument shall be calibrated
before use on each day of its use by the
procedures specified in Reference
Method 21.
(4) Calibration gases shall be:
(i) Zero air (less than 10 ppm of
hydrocarbon in air).
(ii> A mixture of methane or n-hexane
and air at a concentration of
approximately, but less than. 10.000 ppm
methane or n-hexane.
(5) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21. ' •
' (c) When equipment is tested for
compliance with no detectable
emissions, as required in §§ 264.l052(e),
264.1053(i), 264.1054. and 264.1057{f). 'he
test shall comply with the following
requirements:
(1) The requirements of paragraphs
(b)(l) through (4) of this section shall
apply.
(2) The background level shall be
determined as set forth in Reference
Method 21.
(3) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(4) The arithmetic difference between
the maximum concentration indicated
by the instrument and the background
level is compared with 500 ppm for
determining compliance.
(d) In accordance with the waste
analysis plan required by 5 284.13(b), an
owner or operator of a facility must
determine, for each piece of equipment.
whether the equipment contains or
contacts a hazardous waste with
organic concentration that equals or
exceeds 10 percent by weight using the
following:
(1) Methods described in ASTM
Methods D 2267-88. E169-87. E 168-88,
E 260-85 (incorporated by reference
under $ 260.11);
(2) Method 9060 or 824aof SW-S48
(incorporated by reference under
§ 260.11): or
(3) Application of the knowledge of
the nature of the hazardous waste
stream or the process by which it was
produced. Documentation of a waste
determination by knowledge is required.
Examples of documentation that shall
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Federal-Register / VoL 55, No. 120 / Thursday. June 21. 1998 / Rules and Regulations 2S50S
be used to support • determination
under this provision include production
process Information documenting that
no organic compound* are used.
Information that the waste is generated
by a process that Is identical to a
process at the same or another facility
that has previously been demonstrated
by direct measurement to have a total
organic content less than 10 percent or
prior spedation analysis results on the
same waste stream where it can also be
documented that no process changes
have occurred since that analysis that
could affect the waste total organic
concentration.
(e) If an owner or operator determines
that a piece of equipment contains or
contacts a hazardous waste with
organic concentrations at leest 10
percent by weight the determination
can be revised only after following the
procedures in paragraph (d](l) or (d){2)
of this section.
(f) When an owner or operator end
the Regional Administrator do not agree
OB whether a piece of equipment
contains or contacts a hazardous waste
with organic concentrations at least 10
percent by weight the procedures in
paragraph [d)(l) or (d](2) of this section
can.be used to resolve the dispute.
Cj] Samples used in determining the
percent organic content shall be
representative of the highest total
organic content hazardous waste that Is
expected to be contained in or contact
the equipment
(h) To determine if pumps or valves
are In light liquid service, the vapor
pressures of constituents may be
obtained from standard reference texts
of may be determined by ASTM D-
2879-60 (Incorporated by reference
under I2ao.ll).
(ij Performance tests to determine if a
control device achieves 85 weight
percent organic emission reduction shall
comply with the procedures of
i 284,1034(c](l) through (c){4).
I3M.10S4 Reeenfteeptaa requirements.
(a)(l) Each owner or operator subject
to the provisions of this subpert shall
comply with the recorakeeping
requirements of this section.
(2) An owner or operator of more than
one hazardous waste management unit
subject to the provisions of this subpart
may comply with the recordkeeping
requirements for these hazardous waste
management units In one recordkeeping
system If the system identifies each
record by each hazardous waste
management unit
(b) Owners and operators must record
'ho following information in the facility
operating record:
(1) For each piece of equipment to
which Subpart BB of Part 284 applies:
(!) Equipment identification number
and hazardous waste management unit
identification.
(U) Approximate locations within the
facility (e.g« identify the hazardous
waste management unit on a facility plot
plan).
(iii) Type of equipment (e.g- a pump or
pipeline valve).
(iv) Percent-by-weight total organic*
in the hazardous waste stream at the
equipment
(v) Hazardous waste state at the
equipment (e.g., gas/vapor or liquid).
(vi) Method" of compliance with the
standard (e.g, "monthly leak detection
and repair" or "equipped with dual
mechanical seals").
(2) For facilities that comply with the
provisions of S 284.1033(a)(2). an
implementation schedule as specified in
i 264.1033(a)(2).
(3) Where aa owner or operator
chooses to use test data to demonstrate
the organic removal efficiency or total
organic compound concentre- ioo
achieved by the control device, a
performance test plan as specified in
§ 264.103S(b)(3).
(4) Documentation of compliance with
S 284.1060, including the detailed design
documentation or performance test
results specified in i 284.103S(b)(4),
(c) When each leak ia detected as
specified ia § S 284.1032.284.1053,
. 264.1057. and 284.1058. the following
requirements apply:
, (1) A weatherproof and readily visible
identification, marked with the
equipment identification number, the
date evidence of a potential leak was
found ia accordance with i 264.1058(a).
and the date the leak waa detected.
shall be attached to the leaking
equipment
(2) The identification oh equipment
except on a valve, may be removed after
it has been repaired.
(3) The identification on a valve may
be removed after it has been monitored
for 2 successive months as specified in
i i 2B4.10S7f c) and no leak has been
detected during those 2 months.
(d) When each leak is detected as
specified In 5 5 284.1052, 284.1053.
284.1057. and 284.1058. the following
information shall be recorded in an
inspection log and shall be kept in the
facility operating record:
(1) The instrument and operator
Identification numbers and the
equipment identification number.
(2) The date evidence of a potential
leak was found in accordance with
! 264.l05B(a).
(3) The date the leak was detected
and thu.dates of each attempt to repair
the leak.
(4) Repair methods applied in each
attempt to repair the leak
(5) "Above 10.000" if the maximum
instrument reading measured by the
methods specified in § 284.1083(b) after
each mpair attempt is equal to or greater
than 10,000 ppm.
(8) "Repair delayed" and the reason
for the delay if a leak is not repaired
within 15 calendar days after discovery
of the leak,
(7) Documentation supporting the
delay of repair of a valve in compliance
with S 284.1059(c).
(S) The signature of the owner or
operator (or designate) whose decision
it was that repair could not be effected
without a hazardous waste management
unit shutdown.
(9) The expected date of successful
repair of the leak if a leak is not
repaired within IS calendar days.
(10) The date of successful repair of
the leak.
(e) Design documentation and
monitoring, operating, and inspection
information for each closed-vent system
and control device-required to comply
with the provisions of S 284.1060 shall
be recorded and kept up-to-date In the .
facility operating record as specified in
§ 264.1035(c). Design documentation is
spedfiod ia § 284.1035 (c)(l) and (c)(2)
and monitoring, operating, and
inspection Information in
|284.1lJ35(c)(3)-(c)(8).
(f) For a control device other than a
thermal vapor incinerator, catalytic
vapor incinerator, flare, boiler, process
heater, condenser, or carbon adsorption
system, the Regional Administrator will
specify the appropriate recordkeeping
requirements.
(g) Tie following information
pertaining to all equipment subject to
the requirements in 19 284.10S2 through
284.1060 shall be recorded In a log that
is kept ia the facility operating record:
(1) A list of identification numbers for
equipment (except welded fittings)
subject to the requirements of this
lubp&rL
(2)(i) A list of identification numbers
for equipment that the owner or
operator elects to designate for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, under the provisions
of IS 2(34.1052(o). 264.1053(1), and
264.1057(f).
(ii) The designation of this, equipment
as subject to the requirements of
§§ 264.ZOS2(e), 284.1053(1). or 264.1057(0
shall bo signed by the owner or
operator.
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2SS06 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
(3) A list of equipment identification
numbers for pressure relief devices
required to comply witX 1284.1054(a).
(4)(i) The dates of each compliance
lest required in §5 264.1052(e),
2B4.1053(i). 264.1054. and 264.1057(0-
(ii) The background level measured
during each compliance test.
(iii) The maximum instrument reading
measured at the equipment during each .
compliance test
(5) A list of identification numbers for
equipment in vacuum service.
(h) The following information
pertaining to all valves subject to the
requirements of § 264.1057 (g) and (h)
shall be recorded in a log that is kept in
the facility operating record:
(1) A list of identification numbers for
valves that are designated as unsafe to
monitor, an explanation for each valve
stating why the valve is unsafe to
monitor, and the plan-for monitoring
each valve.
(2) A list of identification numbers for
valves that are designated as difficult to
monitor, an explanation for each valve
stating why the valve is difficult to
monitor, and the planned schedule for
monitoring each valve.
(i) The following information shall be
recorded in the facility operating record
for valves complying with § 264.1062:
(1) A schedule of monitoring.
(2) The percent of valves found
leaking during each monitoring period.
(j) The following information shall be
recorded in a log that is kept in the
facility operating record:
(1) Criteria required in
§ 264.1052(d)(5)(ii) and § 284.1053(e)(2)
and an explanation of the design
criteria.
(2) Any changes to these criteria and
the reasons for the changes.
(k) The following information shall be
recorded in a log that is kept in the
facility operating record for use in
determining exemptions as provided in
the applicability section of this subpart
and other specific subparts:
(11 An analysis determining the design
capacity of the hazardous waste
management unit.
(2) A statement listing the hazardous
waste influent to and effluent from each
hazardous waste management unit
subject to the requirements in
Si 264.1052 through 264.1060 and an
analysis determining whether these
hazardous wastes are heavy liquids.
(3) An up-to-date analysis and the
supporting information and data used to
determine whether or not equipment is
subject to the requirements in
55 264.1052 through 264.1060. The record
shall include supporting documentation
as required by i 264.1063(d)(3) when
application of the knowledge of the
nature of the hazardous waste stream or
the process by which it was produced is
used. If the owner or operator takes any
action (e.g« changing the process that
produced the waste) that could result in
'an increase in the total organic content
of the waste contained in or contacted
by equipment determined not to be
subject to the requirements in
if 264.1052 through 264.1060, then a new
determination is required. "'
(1) Records of the equipment leak
information required by paragraph (d) of
this section and the operating
information required by paragraph (e) of
this section need be kept only 3 years.
(m) The owner or operator of any
facility that is subject to this subpart
and to regulations at 40 CFR part 60,
subpart W, or 40 CFR part 61, subpart
V, may elect to determine compliance
with this subpart by documentation
either pursuant to j 264.1064 of this
subpart or pursuant to those provisions
of 40 CFR part 60 or 61. to the extent
that the documentation under the
regulation at 40 CFR part 60 or part 61
duplicates the documentation required
under this subpart The documentation
under the regulation at 40 CFR part"60 or
part 61 shall be kept with-or made
readily available with the facility
operating record.
(Approved by the Office of Management and
Budget under control number 2060-0195)
§ 264.1065 Reporting raquirwwnta.
(a) A semiannual report shall be
submitted by owners and operators
subject to the requirements of this
subpart to the Regional Administrator
by dates specified by the Regional
Administrator. The report shall include
the following information:
(1) The Environmental Protection
Agency identification number, name.
and address of the facility.
(2) For each month during the
'semiannual reporting period:
(i) The equipment identification
number of each valve for which a leak
was not repaired as required in
S 264.10S7(d).
(ii) The equipment identification
number of each pump for which a leak
was not repaired as required in
§ 264.1052 (c) and (d)(6).
(iii) The equipment identification
number of each compressor for which a
leak was not repaired as required in
§ 264.1053(g).
(3) Dates of hazardous waste
management unit shutdowns that
occurred within the semiannual
reporting period.
(4) For each month during the
semiannual reporting period, dates
when the control device installed as
required by I 264.1052.254.1053,
264.1054. or 264.1055 exceeded or
operated outside of the design
specifications as defined in I 264.1064(e)
and as indicated by the control device
monitoring required by § 264.1060 and
was not corrected within 24 hours, the
duration and cause of each exceedance,
and any corrective measures taken.
' (b) If, during the semiannual reporting
period, lejaks from valves, pumps, and
compressors are repaired as required in
ii 264.1057 (d). 264.1052 (c) and (d)(6).
and 264.1053 (g), respectively, and the
control device does not-exceed or
operate outside of the design
specifications as defined in § 2S4.1064(«)
for more than 24 hours, a report to the
Regional Administrator is not required.
(Approved by the Office of Management and
Budget under control number 2060-0195]
§§264.1066-264.1079 [Reserved]
PART 265—INTERIM STATUS
STANDARDS FOR OWNERS AND
OPERATORS OF HAZARDOUS WASTE
TREATMENT, STORAGE, AND
DISPOSAL FACILITIES
12. The authority citation for part 265
continues to read as follows:
Authority: 42 U.S.C. 6095. 6912(3). 6924.
6925, and 8935.
Subpart B—General Facility Standards
13. Section 265.13 is amended by
revising paragraph (b)(6) to read as
follows:
§265.13 General waste analysis.
• • • • •
(b) * * '
(6) Where applicable.'the methods
that will be used to meet the additional
waste analysis requirements for specific
waste management methods as
specified in §§ 265.193.265.225. 265.252.
285.273. 265.314. 265.341. 265.375. 265.402.
265.1034(d). 265.1063(d), and 208.7 of this
chapter.
14. Section 265.15 is amended by
revising the last sentence of paragraph
(b)(4) to read as follows:
§ 265.15 G«n«raJ inspection requirements.
(b)
(4) *- * * At a minimum, the inspection
schedule must'include the terms and
frequencies called for in 51 265.174.
265.193. 265.195. 285.228. 265.347. 265.3?7,
265.403. 265.1033. 265.1052. 265.1053. and
265.1058.
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Federal Register / VoL S3, No. 120 / Thursday, Juns 21. 1990 / Rules and Regulations 25507
Subpart E— ManH **t System,
IS. Section 285^3 la amended by
wising paragraphs (b)(3) and (b)(6) to
read as follow*;
1 24*73 Operating record.
(3) Record* and results of wast*
analyses and trial tests performed as
specked in il 285.13. 265.193. 285.225.
28i252. 265^73. 285.314. 285J41. 285J75,
285.402. 285.1034. 285.1063. 28&4(a). and
2S&7 of this chapter.
(6) Monitoring, testing or analytical
data when required by i§ 28530. 28534.
285.191. 285.193. 285.195. 285£7B. 285278.
2S5J90(dHl), 285347. 2S&377.
283.1<»4{c}-2SS.1034(f). 285.1035.
28&1063(d)-2S5.1063(i}. and 285.1064.
IS. Section 285J7 is amended by
adding paragraph (d) «s follows:
|3t&77 AddWonal reports.
(d) As othenvis* required by Subparts
AAandBB.
17. 40 CFR part 285 is amended by
adding Subpart AA to read as follows:
Sobpwt AA-Ak EariMie*) SUad*rd* tot
289.1030 Applicability.
284.1031 DtflniUom.
283.1032 SUodardc Prpcen vent*.
283.1033 Slindardc Qo*ed-vent syitea* and
control device*.
233.1034 T«tt SMtfaod* and procedure*.
289.1039 Recordkeeping requimmnU.
2S3.103S— 285.1049 [ReMTved]
Subpcrt AA— Air Emission Standards
for Process Vsnts
I3M.T030 AppfcaMtty.
(a) Th* regulations in this subpart
apply to owners and operators of
facilities that treat, store, or dispose of
hazardous wastes (except as provided
In 1 285.1).
(b) Except for IS 285.1034(d) and
28S.103S(d). this subpart applies to
process vent* associated with
distillation, fractionation. thin-film
evaporation, solvent extraction, or air or
steam stripping operations that manage
hazardous wastes with organic
concentrations of at least 10 ppmw. if
these operations are conducted in:
(1) Units that are subject to the
permitting requirements of part 270. or
(2) Hazardous waate recycling unit*
that are located on hazardous waste
management facilities otherwise subject
to the permitting requirements of part
270.
(Note The requirements of It 285.1032
through 285.1038 apply to process vent* on
hazardous waite recycling units previously
exempt under paragraph 26l£(c)(l). Oth*r
exemptions under IS 2614, 26Z34, and
2SS.l(c) are not aBected by the<«
requirements.)
I28S.193S Definition*.
As used in this subpart all terns shall
have the meaning given them in
i 284.1031. the Act and part* 280-266.
f 265.1033 Standards: Pracas* vents.
(a) The owner or operator of a facility
with process vents associated with
distillation, fractionation, thin-film
' evaporation, solvent extraction or air or
steam stripping operations managing
hazardous wastes with organic
concentrations at least 10 ppmw shall
either
(1) Reduce total organic emissions
from all affected process vents at the
facUity below 1.4 kg/h (3 Ib/h) and 23
Mg/yr (3.1 tons/yr)', or
(2) Reduce, by use of a control device,
total organic emissions from all affected
process vents at the facility by 95 weight
percent. . _
(b) If the owner or operator installs a
closed-vent system and control device
to comply with the provisions of
paragraph (a) of this section, the closed*
vent system and control device must
meet the requirements of 1 285.1033.
(cj Determinations of vent emissions
and emission reductions or total organic
compound concentrations achieved by
add-oa control devices may be based on
engineering calculations or performance
tests. If performance tests are used to
determine vent emissions, emission
reductions, or total organic compound
concentrations achieved by add-on
control devices, the performance tests
must conform with the requirement* of
! 285.1034(6).
' (d) When an owner or operator and
the Regional Administrator do not agree
on determinations of vent emissions
and/or emission reductions or total
organic compound concentrations
achieved by add-on control devices
based on engineering calculations, the
test methods in § 285.1034(e) shall be
used to resolve the disagreement
{285.1033 Standards: Ctoaed-eent
systems and control devices*
(a)(l) Owners or operators of closed-
vent systems and control devices used
to comply with provisions of this part
shall comply with the provisions of this
section.
(2) The owner or operator of an
existing facility who cannot install a
closed-vent system and control device
to comply with the provisions of this
subpart on the effective date that the
facility becomes subject to the
provisions of this subpart must prepare
an implementation schedule that
includes dates by which the closed-vent
system and control device will be
installed and in operation. The controls
must be ilastalled as soon as possible.
but the implementation schedule may
allow up to 18 months after the effective
date thai: the facility becomes subject to
this subpiart for installation and startup.
All unite that begin operation after
December 21.1990 must comply with the
rules immediately (Le- must have
control devices installed and operating
on startup of the affected unit); the 2-
year implementation schedule does not
apply to these units.
(b) A control-device involving vapor
recovery (e-g» a condenser or adsorber)
shall be. (designed and operated to
recover the organic vapors vented to it
with an efficiency of 95 weight percent
or greaUr.unless the total organic
emission limits of ! 285.1032(a)(l) for all
affected process vents can be attained
at an efficiency less than 95 weight
percent
(c) An enclosed combustion device
(e.g* a viipor incinerator, boiler, or
process Iteater) shall be designed and
operated to reduce the organic
emissions vented to it by 95 weight
percent or greater to achieve a total
organic compound concentration of 20
ppmv. expressed as the sum of the
actual compounds, not carbon
equivalent*, on a dry basis corrected to
3 percen.it oxygen: or to provide a
minimum residence time of 0.50 seconds
at a minimum temperature of 760 *C If a
boiler or process heater is used as the
control device, then the vent stream
shall be (introduced into the flame
combustion zone of the boiler or process
heater.
(d)(l) A flare shall be designed for
and operated with no visible emissions
as determined by the methods specified
in paragraph (e)(l) of this section.
except for periods not to exceed a total
of 5 minutes during any 2 consecutive
hours.
(2) A flare shall be operated with a
flame prissent at all times, as determined
by the methods specified in paragraph
(f)(2)(iii) of this section.
(3) A flare shall be used only if the net
heating value of the gas being
combustisd is 11.2 MJ/scra (300 Btu/scfl
or greater, if the flare is steam-assisted '
or air-asiiistedi or if the net heating
value of the gas being combusted is 7.45
Ml/sent (200 Btu/scl) or greater if the
flare is ndnassisted. The net heating
value of the gas being combusted shall
be determined by the methods specified
in paragraph (e)(2) of this section. '
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Federal .Restate / Vol. 53. No. 120 / Thursday. June 21. 1990 / Rules and Regulation.
25568
(4){i) A steam-assisted or nonassisted
flare shall be designed for and operated
with an exit velocity, as determined by
the methods specified in paragraph
(e|(3) of this section, of less than 18.3 m/
s (60 ft/s). except as provided in
paragraphs (d)(4) (ii) and (iii) of this
section.
(ii) A steam-assisted or nonassisted
flare designed for and operated with an
exit velocity, as determined by the
methods specified in paragraph (e)(3) of
this section, equal to or greater than 1&3
m/s (60 ft/s) but less than 122 m/s (400
ft/s) is allowed if the net heating value
of the gas being combusted is greater
than 37.3 Mf/scm (1,000 Btu/scfJ.
(iii) A steam-assisted or nonassisted
flare designed for and operated with an
exit velocity, as determined by the
methods specified in paragraph (e)(3) of
this section, less than the velocity. V,^.
as determined by the method specified
in paragraph (e](4) of this section, and
less, than 122 m/s (400 ft/s) is allowed.
(5) An air-assisted flare shall be
designed and operated with an exit
velocity less than the velocity. V,.,, as
determined by the method specified in
paragraph (e)(5) of this section.
(6) A flare used to comply with this
section shall be steam-assisted, air-
assisted, or nonassisted.
(e](l) Reference Method 22 in 40 CFR
part 80 shall be used to determine the
compliance of a flare with the visible
emission provisions of this subpart. The
observation period is 2 hours and shall
be used according to Method 22.
(2) The net heating value of the gas
being combusted in a flare shall be
calculated using the following equation:
where:
HT=*Net heal'ng value at the sample. M)/
sum: when the net enthalpy per mole of
ofTgas is based on combustion at 25 *C
and 780 mm Hg. but the standard
temperature for determining the volume
corresponding to 1 mol is 20 *C:
K =. Constant. 1.74x10"' (1/ppm) (g mol/scm)
(MJ/kcal) where standard temperature
for (g mol/scm) i* 20 *C
d*> Concentration of sample component i in
ppm on a wet basis, a* measured for
organic! by Reference Method 18 in 40
CITl part 80 and measured for hydrogen
and carbon monoxide by ASTM 01946-
82 (incorporated by reference as
specified in 5 260.11): and
H,=Net heat of combustion of sample
component i. kcal/g mol at 25 'C and 760
mm Hg. The heats of combustion may be
determined using ASTM D 2382-83
(incorporated by reference as specified
in 5 260.11) if published values are not
.'available or cannot be calculated.
(3) The actual exit-velocity of a flare
shall be determined by dividing the
volumetric flow rate (in units of
standard temperature and pressure), as
determined by Reference Methods 2.2A.
2C, or 2D in 40 CFR part 60 as
appropriate, by the unobstructed (free)
crass-sectional area of the flare tip.
(4) The maximum allowed velocity in
m/s. V^ for a flare complying with
paragraph (d)(4)(iii) of this section shall
be determined by the following
equation:
Log,,
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Federal Register / Vol. 55. No. 120 / Thursday, June 21. 1990 / Rules and Regulations , 25509
parameter that indicates the carbon bed
is regenerated on a regular.
predetermined time cycle.
(3) Inspect the readings from each
monitoring device required by
paragraphs (fl (1) and (2) of this section
at least once each operating day to
check control device operation and. if
necessary, immediately implement the
corrective measures-necessary to ensure
the control device operates in
compliance with the requirements of this
section.
(g) An owner or operator using a
carbon adsorption system such as a
fixed-bed carbon adsorber that
regenerates the carbon bed directly
onsita in the control device, shall
replace the existing carbon in the
control device with fresh carbon at a
regular, predetermined time interval that
is no longer than the carbon service life
established as a requirement of
§2«5.1035{bK4)lHl)(F). • .
' (h) An owner or operator using a
carbon adsorption system such as a
carbon canister that does not regenerate
the carbon bed directly onsite in the
control device shall replace the existing
carbon in the control device with fresh
carbon on a regular basis by using one
of the following procedures:
(1) Monitor the concentration level of
the organic compounds in the exhaust
vent stream from the carbon adsorption
system on a regular schedule and
replace the existing carbon with fresh
carbon immediately when carbon
breakthrough is indicated. The
monitoring frequency shall be daily or at
an interval no greater than 20 percent of
the time required to consume the total
carbon working capacity established as
a requirement of { 285.1035(b)(4)(iii](G).
whichever is longer.
(2) Replace the existing carbon with
fresh carbon at a regular, predetermined
time interval that Is less than the design
carbon replacement interval established
as a requirement of
$ 28S.l035{b)(4Hiii)(G).
(i) An owner or operator of an
affected facility seeking to comply with
the provisions of this part by using a
control device other than a thermal
vapor incinerator, catalytic vapor
incinerator, flare, boiler, process heater.
condenser, or carbon adsorption system
is required to develop documentation
including sufficient information to
describe the control device operation
• and identify the process parameter or
parameters that indicate proper
operation and maintenance of the
control device.
(j](l) Closed-vent systems shall be
designed for and operated with no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
.above background and by visual
inspections, as determined by the
methods specified as 1265.1034(b).
(2) Closed-vent systems shall be
monitored to determine compliance with
this section during the initial leak
detection monitoring which shall be
conducted by the date that the facility.
becomes subject to the provisions of this
section, annually, and at other times as
requested by the Regional
Administrator.
(3) Detectable emissions, as indicated
by an instrument reading greater than
500 ppm and visual inspections, shall be
controlled as soon as practicable, but
not later than 15 calendar days after the
emission is detected.
(4) A first attempt at repair shall be
made no later than 5 calendar days after
the emission is detected.
(k) Closed-vent systems and control
devices used to comply with provisions
of this subpart shall be operated at all
times when emissions may be vented to
them.
§ 265.1034 Teat methods and procedures.
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the test methods and
procedures requirements provided in
this section.
(b) When a closed-vent system is
tested for compliance with no detectable
emissions, as required in § 285.1033(j),
the test shall comply with the following
requirements:
(1) Monitoring shall comply with
Reference Method 21 in 40 CFR part 60.
(2) The detection instrument shall
meet the performance criteria of
Reference Method 21.
(3) The instrument shall be calibrated
before use on each day of its use by the
procedures specified in Reference
Method 21.
(4) Calibration gases shall be
(i) Z«ro air (less than 10 ppm of
hydrocarbon in air).
(ii) A mixture of methane or n-hexane
and ail1 at a concentration of
approximately, but less than. 10.000 ppm
methane or n-hexane.
(5) The background level shall be
determined as set forth in Reference
Method 21.
(6) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(7) The arithmetic difference between
the maximum concentration indicated
by the Instrument and the background;
level is compared with 500 ppm for
determining compliance.
(c) Performance tests to determine
compliance with § 265.1032(a) and with
the tottii organic compound
concentration limit of § 26S.1033(cj shall
comply with the following:
(1) Performance tests to determine
total organic compound concentrations
and mass flow rates entering and exiting
control devices shall be conducted and
data reduced in accordance with the
following reference methods and
calculation procedures:
(i) Method 2 in 40 CFR part 60 for
velocity and volumetric flow rate.
(ii) Method IS in 40 CFR part 60 for
organic: content.
(iii) liach performance test shall
consist of three separate runs: each run
conducted for at least 1 hour under the
conditions that exist when the
. hazardous waste management unit is
operating at the highest load or capacity
level reasonably expected to occur. For
the purpose of determining total organic
compound concentrations and mass
flow rates, the average of results of all
runs shall apply. The average shall be
computed on a time-weighted basis.
(iv) Total organic mass flow rates
shall b» determined by the following
equation:
2 C.MW, (0.04161
where:
E,-ToUl organic muss flow rule, kg/h:
(1* m Volumetric flow rate of gases entering
or exiting control device, as determined
by Method 2. dscm/h:
n- Number of organic compounds in the vent
gux
C,=Organic concentration in ppm. dry basis.
of compound i in the vent gas. as
determined by Method IB:
MW(» Molecular weight of organic
compound i in the vent gas. kg/kg-mol:
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255-10 " Federal Register / Vol. 55. No. 120 / Thursday. June-21. 1990 / Rules and Regulations
OMlOvConvenion factor for molar volume.
kg-mol/m>(@ 293 K and 760 mm Hgfc
HTe=« Conversion from ppra. ppm*1.
(v) The annual total organic emission
rate shall be determined by the
following equation:
E.-(E.HH)
where:
E»- Total organic masa emission rate, kg/y,
£,=-Total organic miss flow rate for the
process vent kg/'h:
H~Total annual hours of operation* for the
affected unit, h.
(vi) Total organic emissions horn all
affected process vents at the facility
shall be determined by summing the
hourly total organic mass emission rates
(E,,. as determined in paragraph (c)(l)(v)
of this section) and by summing the
annual total organic mass emission rates
(E/u as determined in paragraph .(c)(l)(v)
of this section) for all affected process
vents at the facility.
(2)-The owner or operator shall record
such process information aa may be
necessary to determine the conditions of
the performance tests. Operations
during periods of startup, shutdown, and
malfunction shall not constitute
representative conditions for the
purpose of • performance-test
(3) The owner or operator of an
affected facility shall provide, or cause
to be provided, performance testing
facilities as follows:
(i) Sampling ports adequate for the
test methods specified in paragraph
(c)(l) of this section.
(ii) Safe sampling platform(s).
(Hi) Safe access to sampling
platform(s).
(iv) Utilities for sampling and testing
equipment.
(4) For the purpose of making
compliance determinations, the time- .
weighted average of the results of the
three runs shall apply. In the event that
a sample is accidentally lost or
conditions occur in which one of the
three runs must be discontinued because
of forced shutdown, failure of an
irreplaceable portion of the sample
train, extreme meteorological
conditions, or other circumstances
beyond the owner or operator's control.
compliance may. upon the Regional
Administrator's approval, be determined
using the average of the results of the
two other runs.
(d) To show that a process vent
associated with a hazardous waste
distillation, fractionation, thin-film
. evaporation, solvent extraction, or air or
steam stripping operation is not subject
to the requirements of this subpart. the
owner or operator must make an initial
determination that the time-weighted.
iinmiiil average total organic
concentration of the waste managed by
the waste management unit is less than
10 ppmw using one of the following two
methods:
(1) Direct measurement of the organic
concentration of the waste using the
following procedures:
(i) The owner or operator must take a-
minimum of four grab samples of waste
for each waste stream managed in the
affected unit under process conditions
expected to cause the maximum waste
organic concentration.
(ii) For waste generated onsite. the
grab samples must be collected at a
point before the waste is exposed to the
atmosphere such as in an enclosed pipe
or other closed system that is used to
transfer the waste after generation to
the first affected distillation
fractionation, thin-film evaporation.
solvent extraction, or air or steam
stripping operation. For waste generated
offsite. the grab samples must be
collected at the inlet to the first waste
management unit that receives the
waste provided the waste has been
transferred to the facility in a closed
system such as a tank truck and the
.waste is not diluted or mixed with other
waste.
(iii) Each sample shall be analyzed
and the total organic concentration of
the sample shaU be computed using
Method 9060 or 8240 of SW-848
(incorporated by reference under
S 280.11).
(iv) The arithmetic mean of the results
of the analyses of the four samples shall
apply for each waste stream managed in
the unit in determining the time-
weighted, annual average total organic
concentration of the waste. The time-
weighted average is to be calculated
using the annual quantity of each waste
stream processed and the mean organic
concentration of each waste stream
managed in the unit.
(2) Using knowledge of the waste to
determine that its total organic
concentration is less than 10 ppmw.
Documentation of the waste
determination is required. Examples of
documentation that shall be used to
support a determination under this
provision include production process
information documenting that no organic
compounds are used., information that
the waste is generated by a process that
is identical to a process at the same or
another facility that has previously been
demonstrated by direct measurement to
generate a waste stream having a total
organic content less than 10 ppmw. or
prior speciation analysis results on the
same waste stream where it can also be
documented that no process changes
have occurred since that analysis that
could affect the waste total organic
concentration.
(e) The determination that distillation
fractionation. thin-film evaporation,
solvent extraction, or air or steam
stripping operations manage hazardous
wastes with time-weighted annual
average total organic concentrations
less than 10 ppmw shall be made as
follows:
(1) By the effective date that the
facility becomes subject to the
provisions of this subpart or by the date
when the waste is first managed in a
waste management unit, whichever is
laten and
(2) For continuously generated waste.
annually: or
(3) Whenever there is a change in the
waste being managed or a change in the
process that generates or treats the
waste.
(f) When an owner or operator and
the Regional Administrator do not agree •
on whether a distillation, fractionation.
thin-film evaporation, solvent
extraction, or air or steam stripping
operation manages a hazardous waste
with organic concentrations of at least
10 ppmw based on knowledge of the
waste, the procedures in Method 8240
can be used to resolve the dispute.
§263.1035 Recordkeeptna requirements.
(a)(l) Each owner or operator subject
to tHe provisions of this subpart shall
comply with the recordkeeping
requirements of this section.
(2) An owner or operator of more than
one hazardous waste management ur.it
subject to the provisions of this subpart
may comply with the recordkeeping
requirements for these hazardous waste
management units in one recordkeeping
system if the system identifies each
record by each hazardous waste
management unit
(b) Owners and operators must record
the following information in the facility
operating record:
(1) For facilities that comply with '.he
provisions of § 26S.1033(a)(2), an
implementation schedule that includes
dates by which the closed-vent system
and control device will be installed and
in operation. The schedule must also
include a rationale of why the
installation cannot be completed at an
earlier date. The implementation
schedule must be in the facility
operating record by the effective date
that the facility becomes subject to the
provisions of this subpart.
(2) Up-to-date documentation of
compliance with the process vent .
- standards in 5 205.1032. including:
(i) Information and data identifying all
affected process vents, annual
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Federal Register / VoL 5S. No. 120 / Thursday, June 21. 1990 / Rules and Regulations 2SS11
throughput end operating hours of each
affected unit estimated emission rates
for each affected vent and for the
overall facility (i.e., the total emissions
for all affected vents at the facility), and
the approximate location within the
facility of each affected unit (e.g.,
identify the hazardous waste
management units on a facility plot
plan]; and
(11) Information and data supporting
determinations of vent emissions and
emission reductions achieved by add-on
control devices based on engineering
calculations or source tests/Fpr the
purpose of determining compliance.
determinations of vent emissions and
emission reductions must be made using
operating parameter values (e.g.,
• temperatures, flow rates or vent stream
oqjinlc compounds and concentrations)
that represent the conditions that result
in maximum organic emissions, such as
when the waste management unit is
operating at the highest load or capacity
level reasonably expected to occur. If
the owner or operator takes any action
(e,gn managing a waste of different
compoaition or-increasing operating
hours of affected waste management
units) thaf would result in an increase in
total organic emissions from affected
process vents at the facility, then a new
determination is required.
(3) Where an owner or operator
chooses to use test data to determine the
organic removal efficiency or total
organic compound concentration
achieved by the control device, a
performance test plan. The test plan
must include:
(i) A description of how it is
determined that the planned test is going
to be conducted when the hazardous
waste management unit is operating at
the highest load or capacity level
reasonably expected to occur. This shall
Include the estimated or design flow rate
and organic content of each vent stream
and define the acceptable operating
ranges of key process and control device
parameters during the test program.
(11) A detailed engineering description
of the closed-vent system and control
device Including:
(A) Manufacturer's name and model
number of control device.
(B) Type of control device.
(C) Dimensions of the control device.
(D) Capacity.
(E) Construction materials.
(Hi) A detailed description of sampling
and monitoring procedures, including
sampling and monitoring locations in the
system, the equipment to be used.
sampling and monitoring frequency, and
planned analytical procedures for
sample analysis.
(4) Documentation of compliance with
§ 269.1033 shall include the following
information:
(i) A list of all information references
and sources used in preparing the
documentation.
(ii) Records including the dates of
each compliance test required by
§ 285.1033(j).
(iii) If engineering calculations are
used, a design analysis, specifications,
drawings, schematics, and piping and
instrumentation diagrams based on the
appropriate sections of "APTI Course
415: Control of Gaseous Emissions"
(incorporated by reference as specified
in 1260.11) or othec, engineering texts
acceptable to the Regional
Administrator that present basic control
device design information.
Documentation provided by the control
device manufacturer or vendor that
describes the control device design in
accordance with paragraphs
(b)(4)(iii)(A) through (b](4)(iil)(G) of this
section may be used to comply with this
requirement The design analysis shall
address the vent stream characteristics
and control device'operation parameters
as specified below.
(A) For a thermal vapor incinerator,
the design analysis shall consider the
vent stream composition, constituent
concentrations, and flow rate. The
design analysis shall also establish the
design minimum and average
temperature in the combustion zone and
the combustion zone residence time.
(B) For a catalytic vapor incinerator.
the design analysis shall consider the
vent stream composition, constituent
concentrations, and flow rate. The
design analysis shall also establish die
design minimum and average
temperatures across the catalyst bed
inlet and outlet
(C) For a boiler or process heater, the
design analysis shall consider the vent
stream composition, constituent
concentrations, and flow rate. The
design analysis shall also establish the
design minimum and average flame zone
temperatures, combustion zone
residence time, and description of
method and location where the vent
stream is introduced into the
combustion zone.
(D) For a flare, the design analysis
shall consider the vent stream
composition, constituent concentrations,
and flow rate. The design analysis shall
also consider the requirements specified
in ! 285.1033(d).
(E) For a condenser, the design
analysis shall consider the vent stream
composition, constituent concentrations,
flow rate, relative humidity, and
temperature. The design analysis shall
also establish the design outlet organic
compound concentration level, design
average temperature of the condenser
exhaust vent stream, and design average
temperatures of the coolant fluid at the
condenser inlet and outlet.
(F) For A carbon adsorption system
such as a fixed-bed adsorber that
regenerates the carbon bed directly
onsite in the control device, the design
analysis shall consider the vent stream
composition, constituent concentrations.
flow rate, relative humidity, and
temperature. The design analysis shall
also establish the design exhaust vent
stream organic compound concentration
level, number and capacity of carbon
beds, type and working capacity of
activated carbon used for carbon beds.
design total steam flow over the period
of each complete carbon bed
regeneration cycle, duration of the
carbon bed steaming and cooling/drying
cycles, denign carbon bed temperature
after regeneration, design carbon bed
regeneration time, and design service
life of carbon.
(C) For a carbon adsorption system
such as a rarbon canister that does not
regenerate! the carbon bed directly
onsite in tile control device, the design
analysis shall consider the vent stream
composition, constituent concentrations,
flow rate, relative humidity, and
temperature. The design analysis shall
also establish the design outlet organic
concentration level, capacity of carbon
bed. type and working capacity of •
activated carbon used for carbon bed.
and design carbon replacement interval
based on the total carbon working
capacity of the control device and
source operating schedule.
(iv) A statement signed and dated by
the owner or operator certifying that the
operating parameters used in. the design
analysis reasonably represent the'
conditions that exist when the
hazardous waste management unit is or
would be operating at the highest load
or capacity level reasonably expected to
occur.
(v) A statement signed and dated by
the owner or operator certifying that the
control device is designed to operate at
an efficiency of 93 percent or greater
unless the total organic concentration
limit of { 2i35.1032(a) is achieved at an
efficiency less than 95 weight percent or
the total organic emission limits of
§ 28S.1032(a) for affected process vents
at the facility can be attained by a
control device involving vapor recovery
at an efficiency less than 95 weight
percent A statement provided by the
control device manufacturer or vendor
certifying that the control equipment
meets the design specifications may be
used to comply with this requirement.
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25512
Federal Register / Vol. 55, No. 120 / Thursday. June 21. 1990 / Rutes and Regulations
fvi) If performance tests are used to
demonstrate compliance, all teat results.
(c) Design documentation and
monitoring,, operating, and inspection
information for each closed-vent system
and control device required to comply
with the provisions of this part shall be
recorded and kept up-to-date in the
facility operating record. The
information shall include:
(IJ Description and date of each
modification that is mad* to the closed-
vent system or control device design.
(2} Identification of operating
parameter, description of monitoring
device, and diagram of monitoring
sensor location or locations used to
comply with 3 265.1033(3(1} and (f)(Z).
(3) Monitoring, operating and
inspection information required by
paragraphs (f) through (j) of 3 265.1033.
(4) Date. time, and duration of each
period that occurs while the control
device is operating when any monitored
parameter exceeds the value established
in the control device design analysis as
specified below:
(i) For a thermal vapor incinerator
designed to operate with a minimum
residence time of 0.50 seconds at a
minimum temperature of 780 "C. period
when the combustion temperature i*
below 76O°C.
' (ii) For • thermal vapor incinerator
designed to operate with an organic
emission reduction efficiency of 95
percent or greater, period when the
combustion zone temperature is more
than 28 *C below the design average
combustion zone temperature
established as a requirement of
paragraph (b)(4)(iii}(A) of this section.
(iii) For a catalytic vapor incinerator.
period when:
(A) Temperature of the vent stream at
the catalyst bed inlet is more than 28 *C
below the average temperature of the
inlet vent stream established as a
requirement of paragraph (b)(4)(iii)(B) of
this section: or
(B) Temperature difference across the
catalyst bed is less than 80 percent of
the design average temperature
difference established as a requirement
of paragraph (b)(4)(iiiKB) of this section.
(iv) For a boiler or process heater.
period when:
(A) Flame zone temperature is more
than 28.*C below the design average
flame zone temperature established as a
requirement of paragraph (b)(4)(iii)(C) of
this section; or
(B) Position changes where the vent
stream is introduced to the combustion
zone from the location established as a
requirement of paragraph (b)(4)(iii](C} of
this section.
(v) For a flare, period when the pilot
flame is not ignited.
(vi) For a condenser that complies
with 126S.1033(f)(2)(vi](A>. period when
the organic compound concentration
level or readings of organic compounds
in the exhaust vent stream from the
condenser are more than 20 percent
greater thaa the design outlet organic
compound concentration level
established as a requirement of
paragraph (b)(4)(iii)(E} of this section.
fvii) For » condenser that complies
with } 28&.1033(f)(2)(vi)(B}, period when:
(AJ Temperature of the exhaust vent
stream from the con denser is more than
6 °C above the design average exhaust
vent stream temperature established as
a requirement of-paragraph (b)(4J(in)(El
of this section; or
(B) Temperature of the coolant fluid
exiting the condenser is more than S *C
above the design average coolant fluid
temperature at die condenser outlet
established as a requirement of
paragraph (b)(4)(iii](E) of this section.
(viii) For a carbon adsorption system
such as a fixed-bed carboa adsorber
that regenerates the carbon bed directly
onsite in the control device .and
complies with § 2e5.1033(n(2)(vuKA].
period when the organic compound
concentration level or readings of
organic compounds hi the exhaust vent
stream from the carbon bed are more
than 20 percent greater than the design
exhaust vent stream, organic compound
concentration level established as a
requirement of paragraph (b)(4)(iU)CF] of
this section.
(tx) For a carbon adsorption system
such as a fixed-bed carbon adsorber
that regenerates the carbon bed directly
onsite in the control device and
complies with $ 2flS.1033(f)(2)(vii)(B).
period when the vent stream continues
to flow through the control device
beyond the predetermined carbon bed
regeneration time established as a
requirement of paragraph (b)(4Kiii}(Fi of
this section.
(5) Explanation for each period
recorded under paragraph (3) of the
cause for control device operating
parameter exceeding the design value
and the measures implemented to
correct the control device operation,
(8) For carbon adsorption systems
operated subject to requirements
specified in i 285.1033(g) or
§ 2B5.1033(h)(2}. date when existing
carbon in the control device is replaced
with fresh carbon.
(7) For carbon adsorption systems
operated subject to requirements
specified in 3 26S.l033(h)(l). a log that
records:
(i) Date and time when control device
is monitored for carbon breakthrough
and the monitoring device reading.
(ii) Date when existing carbon in the
control device is replaced with fresh
carbon.
(8) Date of each control device startup
and shutdown.
(d? Records of the monitoring.
operating, and inspection information
required by paragraphs (c)(3) through
(c)(8) of this section need be kept only 3
years.
(e> For a control device other than a
thermal vapor incinerator, catalytic
vapor incinerator, flare, boiler, process
heater, condenser, or carbon adsorption
system, monitoring and inspection
information indicating proper operation
and maintenance of the control device
must be recorded in the facility
operating record.
(f) Up-to-date information and data
used to determine whether or pot a
process vent is. subject to the
requirements in § 265.1032 including
supporting documentation as required
by 3 265.l034(d)(2) when application of
the knowledge of the nature of the
. hazardous waste stream or the process
by which it was produced is'used. shall
be recorded in a log that is kept m the
facility operating record.
(Approved by the Office of Management and
Budget under control number 2060-01951
SS285.1038-385.1049 [Reserved]
18.40 CFR part 265 is amended by
adding subpart BB to read as follows:
Subpart BB—Afr Emission Standards for
Equipment Leak*
285.1030 Applicability.
265.1051 Definitions.
233.1052 Standards: Pumps in light liquid
service.
285.1053 Standards: Compressors.
285.1054 Standards: Pressure relief devices in
gas/v«por service.
285.1055 Standards: Sampling connecting
systems.
265.1058 Standards: Open-ended valves or
line*.
205.1057 Standards: Valves in gas/vapor
service or in light liquid service.
285.1058 Standards: Pumps and valves in
heavy liquid service, pressure relief devices
' io light liquid or heavy liquid service, and
flanges and other connectors.
285.1059 Standards: Delay of repair.
285.1060 Standards: Closed-vent s'ystems and
control devices.
265.1081 Alternative standards for valves in
. gas/vapor service or in light liquid service:
percentage of valves allowed to leak.
265.1082 Alternative standards for valves in
gas/vapor service or in light liquid service:
skip period leak detection and repair.
265.1083 Test methods and procedures.
265.1064 Recordkeeping requirements.
265.1085-265.1079 (Reserved)
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Federal Register / VoL 55. No. 120 / Thursday. June a. 19SO / Rules and Regulations 25513
Subpact BS— Air Emission Standard*
for Equipment Leaks
{2*3.1050 Applicability.
(•) The regulation* in this subpatt
apply to owneta and operators of
facilities that beau store.
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25514
Federal Register / Vol. 55. No. 120 / Thuraday.'june 2L 1990 / Rules and Regulations
failure of the seal system, the barrier
fluid system or both.
(f) If the sensor indicates failure of the
llj fti UAB &VUQW& ti»WI«*»»»««» avtmmmmm^f <•» —•«
seal system, the barrier fluid system, or
both based on the criterion determined
under paragraph (e)(2) of this section, a
leak is detected.
(g)(lj When a leak ii detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it it
detected, except as provided in
§265.1059.
(2) A Erst attempt at repair (e.g,
tightening the packing gland) shall be
made no later than 5 calendar days after
each leak is detected.
(h) A compressor is exempt from the
requirements of paragraphs (a) and (b)
of this section if it is equipped with a
closed-vent system capable of capturing
and transporting any leakage from the
seal to a control device that complies
with the requirements of § 285.1060.
except as provided in paragraph (i) of
fhis section.
(!) Any compressor that is designated.
as described in S 265.1064(g)(2). for no
detectable emission as indicated by an
instrument reading of less than 500 ppm
above background is exempt from the
requirements of paragraphs (a) through
(h) of this section if the compressor
(1) Is determined to be operating with
no detectable emissions, as indicated by
an instrument reading of less than 500
ppm above background, as measured by
the method specified in § 285.1063(c).
(2) Is tested for compliance with
paragraph (i)(l) of this section initially
upon designation, annually, and at other
times as requested by the Regional
Administrator.
9265.1054
idantePr
irvraflef
device* in gas/vapor senrte*.
(a) Except during pressure releases.
each pressure relief device in gas/vapor
service shall be operated with no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, as measured by the
method specified in 5 26S.1083(c).
(b)(l) After each pressure release, the
pressure relief device shall be returned
to a condition of no detectable
emissions, as indicated by an instrument
reading of less than 500 ppm above
background, as soon as practicable, but
no later than 5 calendar days after each
pressure release, except as provided in
§ 265.1059.
(2) No later than 5 calendar days after
the pressure release, the pressure relief
device shall be monitored to confirm the
condition of no detectable emissions, as
indicated by an instrument reading of
less than 500 ppm above background, as
. measured by the method specified in
I 265.1063(c).
(c) Any pressure relief device that is
equipped with a closed-vent system
capable of capturing and transporting
leakage from the pressure relief device
to a control device as described in
3 265.1080 is exempt from the
requirements of paragraphs (a) and (b)
of thia section.
} 265.1055 Standard* Sampling
connecting systems.
•(a) Each sampling connection system
shall be equipped with a closed-purge
system or closed-vent system.
(b) Each closed-purge system or
closed-vent system as required in
paragraph (a) shall:
(1) Return the purged hazardous waste
stream directly to the hazardous waste
management process line with no
detectable emissions to atmosphere, or
(2) Collect and recycle the purged
hazardous waste stream with no
detectable emissions to atmosphere, or
(3) Be designed and operated to
capture and transport all the purged
hazardous waste stream to a control
device that complies with the
requirements of § 265.1060.
(c) In situ sampling systems are.
exempt from the requirements of
paragraphs (a) and (b) of this section. •
§283.1056 Standards: Open-ended valve*
or tine*.
(a)(l) Each open-ended valve or line
shall be equipped with a cap, blind
flange, plug, or a second valve.
(2) The cap, blind flange, plug, or
second valve shall seal the open end at
all times except during operations
requiring hazardous waste stream flow
through the open-ended valve or line.
(b) Each open-ended valve or line
equipped with a second valve shall be
operated in a manner such that the
• valve on the hazardous waste stream
end is closed before the second valve is
closed.
(c) When a double block and bleed
system is being used, the bleed valve or
line may remain open during operations
that require venting the line between the
block valves'but shall comply with
paragraph (a) of this section at all other
times.
§265.1057 Standard*: Valves In gas/vapor
Mrvtc* or In Hght liquid «*rvlc*.
(a) Each valve in gas/vapor or light
liquid service shall be monitored
monthly to detect leaks by the methods
specified in ! 28S.1083(b) and shall
comply with paragraphs (b) through (e)
of this section, except as provided in
paragraphs (f), (g). and (h) of this
section' and §§ 265.1061 and 265.1062.
(b) If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(c)(l) Any valve for which a leak is
not detected for two successive months
may be monitored the first month of
every succeeding quarter, beginning
with the next quarter, until a leak is
detected.
(2) If a leak is detected, the valve shall
be monitored monthly until a leak is not
detected for 2 successive months.
(d)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
no later than 15 calendar days after the
leak is detected, except as provided in -
{ 28511059.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(e) First attempts at repair include, but
are not limited to. the following best
practices where practicable:
(1) Tightening of bonnet bolts.
(2) Replacement of bonnet bolts.
(3) Tightening of packing gland niits.
(4) Infection of lubricant into
lubricated packing.
(f) Any valve that is designated, as
described in § 265.1064(gH2). for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, is exempt from the
requirements of paragraph (a) of this
section if the valve:
(1) Has no external actuating
mechanism in contact with the
hazardous waste stream.
(2) Is operated with emissions less
than 500 ppm above background as
determined by the method specified in
§ 285.1063(c).
(3) Is tested for compliance with
paragraph (f)(2) of this section initially
upon designation, annually, and at other
times as requested by the Regional
Administrator.
(g) Any valve that is designated, as
described in § 28S.1064(h)(l), as an
unsafe-to-monitor valve is exempt from
the requirements of paragraph (a) of this
section if:
(1) The owner or operator of the valve
determines that the valve is unsafe to
monitor because monitoring personnel
would be exposed to an immediate
danger as a consequence of complying
with paragraph (a) of this section.
(2) The owner or operator of the valve
adheres to a written plan that requires
monitoring of the valve as frequently as
practicable during safe-to-monitor times.
(h) Any valve that is designated, as
described in § 26S.1064(h){2). as a
difficult-to-monitor valve is exempt from
the requirements of paragraph (a) of this
section if:
(1) The owner or operator of the valve
determines that the valve cannot be
monitored without elevating the
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Federal Register / Vol. 55. No. 120 / Thursday, ftine 21. 1990 / Rules and Regulations 25515
monitoring personnel more than 2
meters above a support surface.
(2) The hazardous waste management
unit within which the valve is located
was in operation before June 21.1S9O.
(3) The owner or operator of the valve
follows a written plan that requires '
monitoring of the valve at least once per
calendar year.
I265.10SS Standards:Pump*andvalve*
to heavy BquM service, pressure relief
device* to Ugh* BquW or heavy Bqukf
service, and ffangea and other connectors*
(a) Pumps and valves in heavy liquid
service, pressure relief devices in light
liquid or heavy liquid service, and
flanges and other connectors shall be
monitored within 5 days by the method
specified in J 265.1063(fa j if evidence of
a potential leak is found by visual.
audible, olfactory, or any other
detection method.
(b] If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(cKl) When a leak i» detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected, except as provided in
{265.1059.
(2) The first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(d) First attempts at repair include.
but are not limited to. the best practices
described under § 2B5.l057(e].
J 2*1.105* Standards:Octavo* rapakv.
(a) Delay of repair of equipment for
which leaks have been detected wilfbe
allowed if the repair is technically
infeaiible without a hazardous waste
management unit shutdown. In such •
case, repair of this equipment shall
occar before the end of the next
hazardous waate management unit
shutdown.
(b) Delay of repair of equipment for
which leaks have been detected will be
allowed for equipment that ia isolated
from the hazardous waste management
unit and that doe* not continue to.
contain or contact hazardous waste with
organic concentrations at least 10
percent by weight '
(c) Delay of repair for valves will be •
allowed if:
(1) Tb* owner or operator determines
that emissions of purged material
resulting from immediate repair are
greater than the emissions likely to
result from delay of repair.
(2) When repair procedures are '
effected, the purged material is collected
and destroyed or recovered in a control
device complying with § 265.1060.
(d) Delay of repair for pumps will be
allowed ifc
(1) Repair requires the use of a dual
mechanical seal system that includes a
barrier fluid system.
(2) Repair is completed as soon as
practicable, but not later than 6 months
after the leak was detected.
(e) Delay of repair beyond a
hazardous waste management unit
shutdown will be allowed for a valve if
valva assembly replacement is
necessary during the hazardous waste
management unit shutdown, valve
assembly supplies have been depleted.
and valve assembly supplies had been
sufficiently stocked before the supplies
were depleted. Delay of repair beyond
the next hazardous Waste management
unit shutdown will not be allowed
unless the next hazardous waste
management unit shutdown occurs
sooner than 6 months after the first
hazardous waste management unit
shutdown.
5 285. tOCO Standards: Cfoced-vent
systemic and eonfiro4 dsvfecst.
Owners or operators of closed-
vent systems and control devices shall
comply with the provisions of '
§285.1033.
i SSS.1M1 Alternative standards for
valve* In gas/vapor service or In light (quid
sarvtea: percentaga'of valves allowed to
leak.
(a) Aa owner or operator subject to
the requirement* of § 285.1057 may elect
to have ail valves withia a hazardous
waste management unit comply with an
alternative standard which allows no
greater thaa 2 percent of the valves to
leak.
(b) The following requirements shall
be met if an owner or operator decides
to comply with the alternative standard
of allowing 2 percent of valves to lealc
. (1) An owner or operator must notify
the Regional Administrator that the
owner or operator has elected to comply
with the requirements of this section.
(2) A performance test as specified in
paragraph (c) of this section shall be
conducted initially upon designation,
annually, and at other times requested
by the Regional Administrator.
(3) If a valve leak is detected, it shall
be repaired in accordance with
§ 265.1057 (d) and (e).
(c) Performance tests shall be
conducted in the following manner
(1) All valves subject to the
requirements in § 265.1057 within the
hazardous waste management unit shall
be monitored within 1 week by the
methods specified in i 285.1063(b).
(2) If an instrument reading of 10,000
ppm or greater is measured, a leak is
detected.
(3) The leak percentage shall be
determined by dividing the number of •
values subject to the requirements in
§ 28ii.l057 for which leaks are detected
by the total number of valves subject to
the requirements in § 255.1057 within the
hazardous waate management unit.
(djl If an owner or operator decides no
longer to comply with this section, the
owner or operator must notify the
Regional Administrator in writing that
the work practice standard described in
! 26!i.l057 (a) through (e) will b?
followed.
§265.1062 Alternative standards for
vahras In gas/vapor service or In light liquid
service: skip period leak, detection and
repair.
(a)(l) An owner or operator subject to
the requirements of 1 265.1057 may elect
•for a II valves within a hazardous waste
management unit to comply with one of
• the alternative work practices specified
in paragraphs (b) (2J and (3) of this
section.
(2) An owner or operator must notify
the Regional Administrator .before
implementing one of the alternative
work; practices.
(b](l) An owner or operator shall
comply with the requirements for
valviis. as described in § 265.1057,
except as described in paragraphs (b}(2)
and |b)(3) of this section.
(2) After two consecutive quarterly
leak detection periods with the
percitntage of valves leaking equal to or
less Itaaa 2 percent an owner or
operator may begin to skip one of the
quarterly leak detection periods for the
valveis subject to the requirements in
! 265.1057.
(3) After five consecutive quarterly
leak detection periods with the
percentage of valves leaking equal to or
less than Z percent an owner or
operator may begin to skip three of the
quarterly leak detection periods for the
valves subject to the requirements in
§ 265.1057.
(4) If the percentage of valves leaking
is greater than 2 percent, the owner or
operators hall monitor monthly in
compliance with the requirements in
§ 285.1057. but may again elect to use
this section after meeting the
requirements of § 285.l057(c)(l).
5285.1043 Teat matheda and procedure*,
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the test methods and
procedures requirements provided in
this section.
(b) Leak detection monitoring, as
required in §§ 265.1052-265.1062. shall
comply with the following requirements:
(1) Monitoring shall comply with
Reference Method 21 in 40 CFR Part 60.
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2S316 Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations
(2) The detection instrument shall
meet the performance criteria of
Reference Method 21.
(3) The instrument shall be calibrated
before use on each day of its use by the
procedures specified in Reference
Method 21.
(4) Calibration gases shall be:
(i) Zero air (less than 10 ppm of
hydrocarbon in air). ' . .
(ii) A mixture of methane or n-hexane
and air at a concentration of
approximately, but-less than. 10.000 ppm
methane or n-hexane.
(5] The instrument probe shall be
traversed around ail potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(c) When equipment is tested for
compliance with no detectable
emissions, as required in SI 26S.10S2(e).
285.1053(1], 265.1054. and 285.1057(f). the
test shall comply with the following
requirements:
(1) The requirements of paragraphs (b)
(1) through (4) of this section shall apply.
. (2) The background level shall be
determined, as set forth in Reference
Method 21.
(3) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(4) The arithmetic difference between
the maximum concentration indicated •
by the instrument and the background
level it compared with 500 ppm for
determining compliance.
(d) In accordance with the waste
analysis plan required by J 28S.13(b), an
owner or operator of a facility must
determine, for each piece of equipment.
whether the equipment contains or
contacts a hazardous waste with
organic concentration that equals or
exceeds 10 percent by weight using the
following:
(1) Methods described in ASTM
Methods D 2287-88, E169-87. E168-88.
E 260-85 (incorporated by reference
under 5 260.11):
(2) Method 9060 or 8240 of SW-848
(incorporated by reference under
J 280.11): or
(3) Application of the knowledge of
the nature of the hazardous waste
stream or the process by which it was
produced. Documentation of a waste
determination by knowledge is required.
Examples of documentation that shall
be used to support a determination
under this provision include production
process information documenting that
no organic compounds are used.
information that the waste is generated
by a process that is identical to a
process at the same or another facility
that has previously been demonstrated
by direct measurement to have a total
organic content less than 10 percent or
prior speciation analysis results on the
same waste stream where it can also be
documented that no process changes
have occurred since that analysis that
could affect the waste total organic
concentration.
(e) If an owner or operator determines
that a piece of equipment contains or
contacts a hazardous waste with
. organic concentrations at least 10
percent by weight the determination
can be revised only after following the
procedures in paragraph (d](l) or (d)(2)
of this section."
(f) When an owner or operator and
the Regional Administrator do not agree
on whether a piece of equipment
contains or contacts a hazardous waste ;
with organic concentrations at least 10
percent by weight the procedures in
paragraph (d](l) or (d)(2) of this section
can be used to resolve the dispute.
(g) Samples used in determining the
percent organic content shall be
representative of the highest total
organic content hazardous waste that is
expected to be contained in or contact
the equipment
(h) To determine if pumps or valves
are in light liquid service, the vapor
pressures of constituents may be
obtained, from standard reference texts '
or may be determined by ASTM D-
2879-88 (incorporated by reference
under § 260.11).
(i) Performance tests to determine if a
control device achieves 95 weight
percent organic emission reduction shall
comply with the procedures of
§ 265.1034 (c)(l) through (c)(4).
§288.1084
• . (a)(l) Each owner or operator subject
to the provisions of this subpart shall
comply with the recordkeeping
requirements of this section.
' (2) An owner or operator of more than
one hazardous waste management unit
subject to the provisions of this subpart
may comply with the recordkeeping
requirements for these hazardous waste
management units in one recordkeeping
system if the system identifies each
record by each hazardous waste
management unit.
(b) Owners and operators must record
the following information in the facility
operating record:
(1) For each piece of equipment to
which subpart BB of part 265 applies:
(i) Equipment identification number
and hazardous waste management unit
identification.
(ii) Approximate locations within the
facility (e.g.. identify the hazardous
waste management unit on a facility plot
plan).
(iii) Type of equipment (e.g.. a pump or
pipeline valve).
(iv) Percent-by-weight total organics
in the hazardous waste stream at the
equipment
(v) Hazardous waste state at the
equipment (e.g.. gas/vapor or liquid).
(vi) Method of compliance with the
standard (e.g.. "monthly leak detection
and repair" or "equipped with dual
mechanical seals").
(2) For facilities that comply with the
provisions of $ 265.1033(a)(2). an
implementation schedule as specified in
$ 265.1033(a}(2). -,
(3) Where an owner or operator
chooses to use test data to demonstrate
the organic removal efficiency or total
organic compound concentration
achieved by the control device, a
performance test plan as specified in
§ 265.103S(b)(3).
(4) Documentation of compliance with
§ 2654060, including the detailed design
documentation or performance test
results specified in § 2S5.1035(b)(4).
(c) When each leak is detected as
specified in §§ 265.1052.265.1953.
265.1057. and 265.1058. the following
requirements apply:
(1} A weatherproof and readily visible
identification, marked with the
equipment identification number, the
date evidence of a potential leak was
found in accordance with $ 265.1058(a),
and the date the leak was detected.
shall be attached to the leaking
equipment
(2) The identification on equipment
except on a valve, may be removed after
it has been repaired.
(3) The identification on a valve may
be removed after it has been monitored
for 2 successive months as specified in
S 265.1057(c) and no leak has been
detected during those 2 months.
(d) When each leak is detected as
specified in §§ 265.1052. 265.1053.
265.1057. and 265.1058. the following
information shall be recorded in an
inspection log and shall be kept in the
facility operating record:
(1) The instrument and operator
identification numbers and the
equipment identification number.
(2) The date evidence of a potential
leak was found in accordance with
§ 265.1058(a).
(3) The date the leak was detected
and the dates of each attempt to repair
the leak.
(4) Repair methods applied in each
attempt to repair the leak.
(5) "Above 10.000" if the maximum
instrument reading measured by the
methods specified in | 265.1063(b) after
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Federal Register / Vol. 55. No. 120 / Thursday. June 21. 1990 / Rules and Regulations 2S5I7
each repair attempt is equal to or greater
than 10,000 ppm.
(6) "Repair delayed" and the reason
for the delay if a leak a not repaired
within 15 calendar days after discovery
of the leak.
(7) Documentation supporting the
delay of repair of a valve in compliance
with f 2S5.105S(c).
(8) The signature of the owner or
operator (or designate) whose decision
It WHS that repair could not be effected
without a hazardous waste management
unit shutdown. ,
(9) The expected date of successful
repair of the leak if a leak is not
repaired within 15 calendardays. ~
(10) The date of successful repair of
the leak.
(e) Design documentation and
monitoring, operating, and inspection
information for each closed-vent system
and control device required to comply
with the provisions of § 285.1060 shall
be recorded and kept up-to-date in the
facility operating record as specified in
I 26S.l035(c). Design documentation is
specified in | 265.1035 (c)(l) and (c}(2)
end monitoring, operating, and
inspection information in { 285.1035
(cK3Hc}C8).
(f) For a control device other than a
thermal vapor incinerator, catalytic
vapor Incinerator, flare, boiler, process
heater, condenser, or carbon adsorption
system, monitoring and inspection
information indicating proper operation
and maintenance of the control device
must be recorded hi the facility
operating record.
(3) The following information
pertaining to all equipment subject to
the requirements in §5 285.1052 through
285.1060 shall be recorded in a log that
is kept in the facility operating record:
(1) A list of identification numbers for
equipment (except welded fittings)
subject to the requirements of this
subpart
(2)(i) A list of identification numbers
for equipment that the owner or
operator elects to designate for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, under the provisions
of S| 26S.10S2(e). 285.1053(i), and
285.1057(1).
(li) The designation of this equipment
as subject to the requirements of " "
iS 265.1052(e). 205.1053(0, or 285.10S7(f)
shall be signed by the owner or
'operator.
(3) A list of equipment identification
numbers for pressure relief devices
required to comply with § 285.1054(a).
(4)(i) The dates of each compliance
tust required in 5 § 265.1052(e).
20S.1053(i). 285.1054. and 285.1057(f).
(ii) The background level measured
during each compliance test
(iii) The maximum instrument reading
measured at the equipment during each
compliance test
(5) A list of identification numbers for
equipment in vacuum service.
(hj The following information
pertaining to all valves subject to the
requirements of 1265.1057 (g) and (h)
shall be recorded in a log that is kept in
the facility operating record:
(1) A list of identification numbers for
valves that are designated as unsafe to
monitor, an explanation for each valve
stating why. the valve is unsafe to
monitor, and the plan for monitoring
each valve.
(2) A list of identification numbers for
valves that are designated as difficult to
monitor, an explanation for each valve
stating Why the valve is difficult to
monitor, and the planned schedule for
monitoring each valve..
(i) The following information shall be
recorded in the facility operating record
for valves' complying with § 285.1062:
(1) A schedule of monitoring.
(2) The percent .of valves found
leaking during each monitoring period.
(j) The following information shall be
recorded in a log that is kept in the
facility operating record:
(1) Criteria required in
§1 285.1052(d)(5)(ii) and 265.1053(e)(2)
and an-explanatioh of the criteria.
(2) Any changes to these criteria and
the reasons for the changes.
(k) The following information shall be
recorded in a log that is kept in the
facility operating record for use in
determining exemptions as provided in
the applicability section of this subpart
and other specific subparts:
(1) An analysis determining the design
capacity of the hazardous waste
management unit
(2) A statement listing the hazardous
waste influent to and effluent from each
hazardous waste management unit
subject to the requirements in
II 285.1052 through 285.1060 and an
analysis determining whether these
hazardous wastes are heavy liquids.
(3) An up-to-date analysis and the
supporting information and'data used to
determine whether or not equipment is
subject to the requirements in
13 285.1052 through 265.1060. The record
shall include supporting documentation
as required by | 265.1063(d)(3) when
application of the knowledge of the
nature of the hazardous waste stream or
the process by which it was produced is
used. If the owner or operator takes any
action (e.g., changing the process that
produced the waste) that could result in
an increase in the total organic content
of the waste contained in or contacted
by equipment determined not to be
subject to the requirements in
II 285.1052 through 265.1060, then a new
determination is required.
(1) Records of the equipment leak
inclination required by paragraph (d) of
this section and the operating
information required by paragraph (e) of
this section need be kept only 3 years.
(mi) The owner or operator of any
facility that is subject to this subpart
and to regulations at 40 CFR part 60,
subp art W, or 40 CFR part 61, subpart
V, may elect to determine compliance
with this subpart by documentation
eithtir pursuant to 5 285.1064 of this
subpart. or pursuant to those provisions
of 40 CFR part 60 or 61, to the extent
that the documentation under the'
regulation at 40 CFR part 80 or part 61
duplicates the documentation required
under this subpart The documentation
under the regulation at 40 CFR part 60 or
part 81 shall be kept with or made
readily available with the facility
operating record. • •
(Approved by the Office of Management and
Budgijt under control number 2060-0195)
§§26ltO«S-2«5J079 [Reserved]
PART 270—EPA-ADMINISTERED
PERMIT PROGRAMS: THE
HAZARDOUS WASTE PERMIT
PROGRAM
19. The authority citation for part 270
continues to read as follows:
Authority: 42 U.S.C. 6905.6912.8921-6927,
6930. 6S34. 6935.6937-6939. and 6974.
Subpart B—Permit Application
20. Section 270.14 is amended by
revising the last sentence of paragraph
(b)(5'| and by revising paragraphs (b)(8)
(iv). |'v), and by adding paragraph
(b)(8jl(vi) to read as follows:
5270,14 Contenta-of Part & General
requirements
• • • • •
(b) * ' *
(5) * * * Include, where applicable,
as part of the inspection schedule.
specific requirements in §5 284.174.
204.103(0. 264.195, 264.228, 264.254.
264.273, 284.303. 264.602. 264.1033.
264.11)52.284.1053, and 264.1053.
(8) • •, •
(iv]l Mitigate effects si equipment
failure and power outages:
(v) Prevent undue exposure of
personnel to hazardous waste (for
example, protective clothing); and
(vi] Prevent releases to atmosphere.
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.25518- Federal Register / Vol. 55, No. 120 / Thursday. June 21. 1990 / Rules and Regulations
Section 27O24 is added to read as
follows:
§37024 Specific Part B Information
requirement* for process vents.
Except aa otherwise provided in
5 264.1. owners and operators of
facilities that have process vents to .
which subpart AA of part 264 applies
must provide the following additional
information:
(a) For facilities that cannot install a
closed-vent system and control device
to comply with the provisions of 40 CFR
2S4 subpart AA on the effective date
that the facility becomes subject to the
provisions of 40 CFR 284 or 283 subpart
AA. an implementation schedule as
specified in 12S4.1033(a)(2).
(b) Documentation of compliance with
the process vent standards in J 284.1032.
including:
(1) Information and data identifying
all affected process vents, annual
throughput and operating hours of each
affected unit estimated emission rates
for each affected vent and for the
overall facility (i.e.. the total emission*
for all affected vents at the facility), and
the approximate location within die
facility of each affected unit (e.g»
identify the hazardous waste
management nnits oa a facility plot
plan).
(2) Information and data supporting
estimates of vent emissions and
• emission reduction achieved by add-on
control devices based on engineering
calculations or source tests. For the
purpose of determining compliance.
estimates, of vent emissions and
emission reductions must be made using
operating parameter values (e.g>
temperatures, flow rates, or
concentrations) that represent the
conditions that exist when the waste
management unit is operating at the
highest load or capacity level
reasonably expected to occur.
(3) Information and data used to
determine whether or not a process vent
is subject to the requirements of
§264.1032.
(c) Where an owner or operator
applies for permission to use a control
device other than a thermal vapor
incinerator, catalytic vapor incinerator.
flare, boiler, process heater, condenser.
or carbon adsorption system to comply
with the requirements of 5 264.1032. and
chooses to use test data to determine the
organic removal efficiency or the total
organic compound concentration
achieved by the control device, a
performance test plan as specified in
§ 264.103S(b)(3).
(d) Documentation of compliance with
§ 204.1033. including:
(1) A list of all information.referenees
and sources used in preparing the
documentation.
(2) Records including the dates of
each compliance test required by
§ 2&U03(k).
(3) A design analysis, specifications.
drawings, schematics, and piping and
instrumentation diagrams based on the
appropriate sections of "APT! Course
415: Control of Gaseous Emissions"
(incorporated by reference as specified
in S 260.11? or other engineering texts
acceptable to the Regional
Administrator that present basic control
device design information. The design
analysis shall address "the vent stream
characteristics and control device
operation parameters as specified in
§ 284.1035{b)(4Hiii).
(4) A statement signed and dated by
the owner or operator certifying that the
operating parameters used in the design
analysis reasonably represent the
conditions that exist when die
hazardous waste management unit is or
would be operating at the highest load
or capacity level reasonably expected to
occur.
{$) A statement signed and dated by
the owner or operator certifying that to*
control device is designed to operate at
an efficiency of 95 weight percent or
greater unless the total organic emission
limit* of § 284.1032(a) for affected
process vents at the facility can be
attained by a control device involving
vapor recovery at an efficiency less than
95 weight percent.
(Approved by the Office of Management and
Budgat tmdar control number 2060-0195)
22. Section 27O2S is added as follows:
I2T02S Specific part BtnformaUon
requirements for equipment
Except as otherwise provided hi
§ 2S4.1. owners and operators of
facilities that have equipment to which
subpart BB of part 284 applies must
provide the following additional
information:
(a) For each piece of equipment to
which subpart BB of part 284 applies:
(1) Equipment .identification number
and hazardous waste management unit
identification.
(2) Approximate locations within the
facility (e.g* identify the hazardous
waste management unit on a facility plot
plan).
(3) Type of equipment (e.g., a pump or
pipeline valve).
(4) Percent by weight total organic* in
the hazardous waste stream at the
equipment
(S) Hazardous waste state at the
equipment (e.g.. gas/vapor or liquid).
(6) Method of compliance with the
standard (e.g.. "monthly leak detection
and repair" or "equipped with dual
mechanical seals").
(b) For facilities that cannot install a
closed-vent system and control device
to comply with the provisions of 40 CFR
264 subpart BB on the effective date that
the facility becomes subject to the
provisions of 40 CFR 264 or 285 subpart
BB. an implementation schedule as
specified in } 284.1033(a)(2).
(c) Where an owner or operator
applies for permission to use a control
device other than a thermal vapor
incinerator, catalytic vapor incinerator.
flare, boiler, process heater, condenser.
or carbon adsorption system and
chooses to use test data to determine the
organic removal efficiency or the total
organic compound concentration
achieved by the control device, a
performance test plan as specified in
§ 264.103S(b)(3).
(d) Documentation that demonstrates
. compliance with the equipment
standard* in II 284.1052 to 284.1059.
This documentation shall contain the
record* required under § 264.1084. The
Regional Administrator may request
further documentation before deciding if
compliance has been demonstrated.
(e) Documentation to demonstrate
compliance with 3 264.1060 shall include
the following information:
(1) A list of all.information references
and source* used is preparing die
documentation.
(2) Records including the dates of
each-compliance test required by
§ 264.10330).
(3) A design analysis, specifications.
drawings, schematics, and piping and
instrumentation diagrams based on the
appropriate sections of "ATPl Course
415: Control of Gaseous Emissions"
(incorporated by reference as specified
in i 260.11) or other engineering texts
acceptable to the Regional
Administrator that present basic control
device design information. The design
analysis shall address die vent stream
characteristics and control device
operation parameter* as specified in
§ 264.1035(bH4)(iii).
(4) A statement signed and dated by
the owner or operator certifying that the
operating parameters used in the_design
analysis reasonably represent the
conditions that exist when the
hazardous waste management unit'is
operating at the highest load or capacity
level reasonably expected to occur.
(5) A statement signed and dated by
the owner or operator certifying that the
control device is designed to operate at
an efficiency of 95 weight percenter
greater.
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Federal Register / Vol. 55. No. 120 / Thursday. ]une 21, 1990 / Rules and Regulations
(Approved by the Office of Management and
Budget under control number 2060-0915)
PART 271— REQUIREMENTS FOR
AUTHORIZATION OF STATE
HAZARDOUS WASTE PROGRAMS
23. The authority citation for part 271
continues to read as follows:
Authority: 42 U.S.C. 6005. 6812(a). and 6BS8.
Subpart A— R*quiraflMnta for Final
Authorization
24, Section 271.1(j) is amended by
adding the following entry to Table 1 in
chronological order by date of
publication:
1271.1 Purpose and scop*.
• •"•"••
OJ .....
TABLE 1. REGUIATIONS IMPLEMENTING
TH€ HAZARDOUS AND Souo WASTE
AM6NOM6NTS OF 1984
THtoof
due
PTOC«H V«n* Untun
dMed wdEquipnMni FB
put*- LMkOiQirae ra«-
otionl. AirEnieaion
SUndentttor on
(Imwt
diM.1
Opmional
of
ll
Slortae,and
[FR Doc. 90-142M Filed 0-20-90:8:45 am)
cooc im n •
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APPENDIX B ' '
METHOD 21. DETERMINATION OF VOLATILE
ORGANIC COMPOUND LEAKS
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APPENDIX B
METHOD 21. DETERMINATION OF VOLATILE
ORGANIC COMPOUND LEAKS
1. Applicability and Principle
1,1 Applicability. This method applies to the determination of vola-
tile organic compound' (VOC) leaks from process equipment. These sources
include, but are not limited.to, valves, flanges and other connections,
pumps and compressors, pressure relief devices, process drains, open-ended
valves, pump and compressor seal system degassing vents, accumulator vessel
vents, agitator seals, and access door seals.
1.2 Principle. A portable instrument is used to detect VOC leaks-
from individual sources. The instrument detector type is not specified,
but it must meet the specifications and performance criteria contained in
Section 3. A leak definition concentration based on a reference compound
is specified in each applicable regulation. This procedure is intended to
locate and classify leaks only, and is not to be used as a direct measure
of mass emission rates from individual sources.
2. Definitions
2.1 Leak Definition Concentration. The local VOC concentration at
the surface of a leak source that indicates that a VOC emission (leak) is
present. The leak definition is an instrument meter reading based on a
reference compound.
2.2 Reference Compound. The VOC species selected as an instrument
calibration basis for specification of the leak definition concentration.
[For example: If a leak definition concentration is 10,000 ppmv as
methane,, then any source emission that results in a local concentration
that yields a meter reading of 10,000 on an instrument calibrated with
methane would be classified'as a leak. In this example, the leak
definition is 10,000 ppmv, and the reference compound is methane.]
B-3
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2.3 Calibration Gas. The VOC compound used to' adjust the instrument
meter reading to a known value. The calibration gas is usually the refer-
ence compound at a concentration approximately equal to the leak definition
concentration.
2.4 No Detectable Emission. The local VOC concentration at thre
surface of a leak source that indicates that a VOC emission (leak) is not
present. Since background VOC concentrations may exist, and to account for
instrument drift and imperfect reproducibility, a difference between the
source surface concentration and the local ambient concentration is deter-
mined. A difference based on meter readings of less than 5 percent of the
leak definition concentration indicates that a VOC emission (leak) is not
present. (For example, if the leak- definition in a regulatidn is 10,000
ppmv, then the allowable increase in surface concentration versus local
ambient concentration would be 500 ppmv based on the instrument meter
readings.)
2.5 Response Factor. The ratio of the known concentration of a VOC
compound to the observed meter reading when measured using an instrument
calibrated with the reference" compound specified in the application
regulation.
2.6 Calibration Precision. The degree of agreement between measure-
ments of the same known value, expressed as the relative percentage of the
average difference between the meter readings and the kinown concentration
to the known concentration.
2.7 Response Time. The time interval from a step change in VOC
concentration at the input of the sampling system to the time at which 90
percent of the corresponding final value is reached as displayed on the
instrument readout meter.
3.0 Apparatus
3.1 Monitoring Instrument.
3.1.1 Specifications.
a. The VOC instrument detector shall respond to the compounds being
processed. Detector types which may meet this requirement include, but are
not limited to, catalytic oxidation, flame ionization, infrared absorption,
and photoionization.
B-4
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b. The instrument shall be capable of measuring the leak definition
concentration specified in the regulation.
c. The scale of the instrument meter shall be readable to ±5 percent
of the specified leak definition concentration.
d. The instrument shall be equipped with a pump so that a continuous
sample is provided to the detector. The nominal sample flow rate shall be
1/2 to 3 liters per minute.
e. The instrument shall be intrinsically safe for operation .in
explosive atmospheres as defined by the applicable U.S.A. standards (e.g.,
National Electrical Code by the National Fire Prevention Association).-
3.1.2 Performance Criteria.
a. The instrument response factors for the individual compounds to be
measured must.be less than 10.
• • b. The instrument response time must be equal to or less than 30
seconds. The response time must be determined for the instrument configur-
ation to be used during testing.
c. The calibration precision must be equal to or less than 10 percent
»
of the calibration gas value.
d. The evaluation procedure for each parameter is given in Section
4.4.
3.1.3 Performance Evaluation Requirements.
a. A response factor must be determined for each compound that is to
be measured, either by testing or from reference sources. The response
factor tests are required before placing the analyzer into service/ but" do
not have to be repeated at subsequent intervals.
b. The calibration precision test must be completed prior to placing
the analyzer into service, and at subsequent 3-month intervals or at the
next use whichever is later.
c. The response time test is required prior to placing the instrument
into service. If a modification to the sample pumping system of -flow
configuration is made that would change the response time, a new test is
required prior to further use.
3.2 Calibration Gases. The monitoring instrument is calibrated in
terms of parts per million by volume (ppmv) of the reference compound
specified in the applicable regulation. The calibration gases required for
B-5
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monitoring and instrument performance evaluation are a zero gas (air,
<10 ppmv VOC) and a calibration gas in air mixture approximately equal to
the leak definition specified in the regulation. If cylinder calibration
gas mixtures are used, they must be analyzed and certified by the manufac-
turer to be within ±2 percent accuracy, and a shelf life must be specified.
Cylinder standards must be either reanalyzed or replaced at the end of the
specified shelf life. Alternately, calibration gases may be prepared by
the user according to any accepted gaseous standards preparation procedure
that will yield a mixture accurate to within ±2 percent. Prepared stand-
ards must be replaced each day of use unless it can be demonstrated that
degradation does not occur during storage.
Calibrations may be performed using a compound other than the refer-
ence compound if a conversion factor is determined" for that alternative
compound so that the resulting meter readings during source surveys can be
converted to reference compound results..
4. Procedures
4.1 Pretest Preparations. Perform the instrument evaluation proce-
u
dures given in Section 4.4 if the evaluation requirements .of Section 3.1.3
have not been met.
4.2 Calibration Procedures. Assemble and start up the VOC analyzer
according to the manufacturer's instructions. After the appropriate warmup
period and-zero or internal calibration procedure, introduce the calibra-
tion gas into the instrument sample probe. Adjust the instrument meter
readout to correspond to the calibration gas value. [Note: If the meter
readout cannot be adjusted to the proper value, a malfunction of the
analyzer is indicated and corrective actions are necessary before use.]
4.3 Individual Source Surveys.
4.3.1 Type I—Leak Definition Based on Concentration. Place the
probe inlet at the surface of the component interface where leakage could
occur. Move the probe along the interface periphery while observing the
instrument readout. If an increased meter reading is observed, slowly
sample the interface where leakage is indicated until the maximum meter
t
reading is obtained. Leave the probe inlet at this maximum reading
location for approximately two times the instrument response time. If the
B-6
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maximum observed meter reading is greater than the leak definition in the
applicable regulation, record and report the results as specified in the
regulation reporting requirements. Examples of the application of this
general technique to specific equipment types ares
a. Valves—The most common source of leaks from valves is at the seal
between the stem and housing. Place the probe at the interface where the
stem exits the packing gland and sample the stem circumference. Also,
place the probe at the interface of the packing gland take-up flange seat
and sample the periphery. In addition, survey valve housings of multipart
assembly at the surface of all interfaces where leaks could occur.
b. Flanges and Other Connections—For welded flanges, place the probe
at the outer edge of the flange-gasket interface and sample the circumfer-
ence of the flange. Sample other types of nonpermanent joints (such as
threaded connections) with a similar traverse.
c. Pumps and Compressors—Conduct a circumferential traverse at the
outer surface of the pump or compressor shaft and seal interface. If the
source is a rotating shaft, position -the probe inlet within 1 cm of the
shaft seal interface for the survey. If the housing configuration prevents
a complete traverse of the shaft periphery, sample all accessible portions.
Sample all other joints on the pump or compressor housing where leakage
could occur.
d. Pressure Relief Devices—The configuration of most pressure relief
devices prevents sampling at the sealing seat interface. For those devices
equipped with an enclosed extension, or horn, place the probe inlet at
approximately the center of the exhaust area to the atmosphere.
e. Process Drains—For open drains, place the probe inlet at approxi-
mately the center of the area open to the atmosphere. For covered drains,
place the probe at the surface of the cover interface and conduct a peri-
pheral traverse.
f. Open-Ended Lines or Valves—Place the probe inlet at approximately
the center of the opening to the atmosphere.
g. Seal System Degassing Vents and Accumulator Vents—Place the probe
inlet at approximately the center of the opening to the atmosphere.
h. Access Door Seals—Place the probe inlet at the surface of the
door seal interface and conduct a peripheral traverse.
B-7
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4.3.2 Type II—"No Detectable Emission".
Determine the local ambient concentration around the source by moving
the probe inlet randomly upwind and downwind at a distance of one to two
meters from the source. If an interference exists with this determination
due to a nearby emission or leak, the. local ambient concentration may be
determined at distances closer to the source, but in no case shall the
distance be less than 25 centimeters. Then move the probe inlet to the
surface of the source and conduct a survey as described in 4.3.1. If an
increase greater than 5 percent of the leak definition concentration is
obtained, record and report the results as specified by the regulation.
For those cases where the regulation requires a specific device
installation, or that specified vents be ducted or piped to a control
device, the existence of these conditions shall be-visually confirmed.
When the regulation also requires that no detectable emissions exist,
visual observations and sampling surveys are required. Examples of this
technique are:
(a) Pump or Compressor Seals—If applicable, determine the type of
shaft seal. Perform a survey of the local area ambient VOC concentration
and determine if detectable emissions exi-st as'described above.
(b) Seal System Degassing Vents, Accumulator Vessel Vents, Pressure
Relief Devices—If applicable, observe whether or not the applicable
ducting or piping exists. Also, determine if any sources exist in the
ducting or piping where emissions could occur prior to the control device.
If the required ducting or piping exists and there are no sources where the
emissions could be vented to the atmosphere prior to the control device,
then it is presumed that-no detectable emissions are present.
4.4 Instrument Evaluation Procedures. At the beginning of the
instrument performance evaluation test, assemble and start up the instru-
ment according to the manufacturer's instructions for recommended waqnup
period and preliminary adjustments.
4.4.1 Response Factor. Calibrate the instrument with the reference
compound as specified in the applicable regulation. For each organic
species that is to be measured during individual source surveys, obtain or
prepare a known standard in air at a concentration of approximately 80
percent of the applicable leak definition unless limited by volatility or
B-8
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explosivity. In these cases, prepare a standard at 90 percent of the
saturation concentration, or 70 percent of the lower explosive limit,
respectively. Introduce this mixture to the analyzer and record the
observed meter reading. Introduce zero air until a stable reading is
obtained. Make a total of three measurements by alternating between the
known mixture and zero air. Calculate the response factor for each repeti-
tion and the average response factor.
Alternatively, if response factors have been published for the com-
pounds of interest for the instrument or detector type, the response factor
determination is not required, and existing results may be referenced.
Examples of published response factors for flame ionization and catalytic
oxidation detectors are included in Section 5.
4.4.2 Calibration Precision. Make.a total of three measurements by
alternately using zero gas and the specified calibration gas. Record the
meter readings. Calculate the average algebraic difference between the
meter readings and the known value. Divide this average difference by the
known calibration value and multiply by 100 to express the resulting cali-
bration precision as a percentage.
4.4.3 Response Time. Introduce zero gas into the instrument .sample
probe. When the meter reading has stabilized, switch quickly to the speci-
fied calibration gas. Measure the time from switching to when 90 percent
of the final stable reading is attained. Perform this test sequence three
times and record the results. Calculate the average response time.
5. Bibliography
5.1 DuBose, D. A., and 6. E. Harris. Response Factors of VOC
Analyzers at a Meter Reading of 10,000 ppmv for Selected Organic Compounds.
U.S. Environmental Protection Agency, Research Triangle Park, N.C.
Publication No. EPA 600/2-81-051. September 1981.
5.2 Brown, G. E., et al. Response Factors of VOC Analyzers
Calibrated with Methane for Selected Organic Compounds. U.S. Environmental
Protection Agency, Research Triangle park, N.C. Publication No. EPA 600/2-
81-022. May 1981.
5.3 DuBose, D. A,, et al. Response of Portable VOC Analyzers to
Chemical Mixtures. U.S. Environmental Protection Agency, Research Triang.le
Park, N.C. Publication No. EPA 600/2-81-110. September 1981.
B-9
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APPENDIX C
EXAMPLE CONDENSER DESIGN
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