Compliance Assistance Tool for
Clean Air Act Regulations: Subpart
GGG of40 CFR NESHAPS for
Source Category Pharmaceutical
Production
August 2002
Office of Enforcement and Compliance Assurance
Office of Enforcement
Compliance Assessment and Media Programs Division
Air, Hazardous Waste and Toxics Branch
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Table of Contents
Page
Chapter 1 - Purpose 1-1
1.1 Purpose of the Document 1-1
1.2 Document Organization 1-1
1.3 Disclaimer 1-2
Chapter 2 - Overview of the Regulations 2-1
2.1 Purpose of the Rule 2-1
2.2 Statutory Background 2-1
2.3 Major Components of the Rule 2-3
2.4 Standards 2-5
Chapter 3 - Applicability and Compliance Dates 3-1
3.1 Overview 3-1
3.2 Applicability 3-1
3.3 Other Important Applicability Definitions 3-7
3.4 Compliance Dates 3-13
3.5 Consistency with Other Regulations 3-14
Chapter 4 - Requirements for Storage Tanks 4-1
4.1 Overview 4-1
4.2 Structure of the Regulation 4-1
4.3 Applicability 4-2
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4.4 Standards 4-5
4.5 Emissions Averaging 4-7
4.6 Initial Compliance Demonstration 4-7
4.7 Monitoring On-Going Compliance 4-9
Chapter 5 - Requirements for Process Vents 5-1
5.1 Overview 5-1
5.2 Structure of the Regulation 5-1
5.3 Applicability 5-1
5.4 Standards 5-2
5.5 Initial Compliance Demonstration Procedures 5-14
5.6 Emissions Averaging 5-15
5.7 Monitoring On-Going Compliance 5-16
Chapter 6 - Requirements for Equipment Leaks 6-1
6.1 Overview 6-1
6.2 Structure of the Rule 6-1
6.3 Applicability 6-1
6.4 References to Subpart H 6-5
6.5 Standards 6-5
Chapter 7 - Requirements for Wastewater 7-1
7.1 Overview - Suppression and Control 7-1
7.2 Structure of the Regulation 7-2
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7.3 Applicability 7-2
7.4 Standards 7-10
7.5 Compliance Demonstration 7-26
Chapter 8 - Initial Compliance Demonstrations and Testing Procedures 8-1
8.1 Overview 8-1
8.2 Structure of the Regulation 8-2
8.3 Exemptions from Compliance Demonstrations 8-2
8.4 Compliance Demonstration Procedures - Summary 8-3
8.5 Compliance Demonstration Procedures for Process Vents 8-6
8.6 Compliance Demonstration Procedures for Storage Tanks 8-25
8.7 Initial Compliance Demonstration Procedures for Wastewater Sources 8-25
8.8 Submittal of Compliance Demonstrations 8-32
Chapter 9 - Monitoring Procedures 9-1
9.1 Overview 9-1
9.2 Structure of the Regulation 9-1
9.3 Basis for Monitoring Control Devices 9-2
9.4 Establishing Operating Parameters for Monitoring Control Devices 9-3
9.5 Establishing Averaging Periods for Monitoring 9-8
9.6 Monitoring for the Mass Emissions Limit Standard (2,000 lb/yr) 9-9
9.7 Wastewater Monitoring Procedures 9-9
9.8 Exceedances of Operating Parameters, Excursions, and Violations 9-13
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Chapter 10 - Pollution Prevention 10-1
10.1 Overview 10-1
10.2 Structure of the Regulation 10-1
10.3 Applicability 10-1
10.4 Standards 10-2
10.5 Compliance Demonstration 10-3
10.6 Monitoring 10-6
10.7 Examples 10-7
Chapter 11 - Emissions Averaging 11-1
11.1 Overview 11-1
11.2 Structure of the Regulation 11-1
11.3 Applicability 11-1
11.4 Standards 11-2
11.5 Compliance Demonstration 11-2
11.6 Recordkeeping 11-3
11.7 Reporting 11-3
11.8 Hazard or Risk Equivalency Determination 11-4
Chapter 12 - Recordkeeping 12-1
12.1 Overview 12-1
12.2 Structure of the Regulation 12-1
12.3 Recordkeeping Requirements from the General Provisions 12-1
12.4 Purpose of Keeping Records of "Operating Scenarios" 12-8
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Chapter 13 - Reporting 13-1
13.1 Overview 13-1
13.2 Structure of the Regulation 13-1
13.3 Reporting Requirements from the General Provisions, Subpart A 13-1
13.4 Reporting Requirements from the Pharmaceutical MACT, Subpart GGG .. 13-3
Appendices
Appendix EE: Emissions Estimation Procedures for Process Vents
Appendix PT: Emissions Performance Testing - Test Methods and Approach
Appendix WWT: Wastewater Treatment Performance Testing - Test Methods and Approach
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Chapter 7
Requirements for Wastewater
7.1 Overview - Suppression and
Control
The wastewater provisions of the MACT
differ from the provisions for tanks and
process vents in that they are concerned with
both suppressing air emissions within the
wastewater treatment chain (i.e. individual
drain systems, treatment tanks, etc) as well
as reducing HAP in the wastewater itself
through performance standards.
Additionally, any air emissions vented
during the treatment process must be
controlled via traditional air pollution
control devices and equipment leak
provisions apply to vapor collection systems,
closed vent systems, roofs, covers or other
enclosures used to comply with the rule.
Residuals created from treatment processes
must either be recycled, returned to the
treatment process or destroyed. Although
not considered wastewater, this
Chapter 7 at a Glance
7.1
Overview
7.2
Structure of the Regulation
7.3
Applicability
7.4
Standards
7.5
Compliance Demonstration
Procedures
chapter also describes requirements for heat
exchangers and equipment in open systems.
The suppression and control requirements
are summarized below:
TYPE OF STANDARD
MEDIA
PURPOSE
Vapor Suppression (VS)
air
Use equipment specs and operating practices to
minimize HAP losses to the air from tanks, surface
impoundments, containers, and individual drain
systems (i.e., cover equipment to limit emissions)
Performance Standards
(PS)
1. Wastewater
Treatment
(WWT)
water
i Use wastewater treatment processes to
reduce the HAP content in the wastewater
(i.e. removal, destruction, treatment in bio
units, etc)
2. Air Emissions
Control (EC)
air
i Use control device specs or performance
standards for air pollution control devices
(APCDs) to reduce HAP emissions (i.e., use
APCDs) vented from treatment processes
7-1
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These two types of standards - VS and PS
(with EC and WWT subsets) - will appear
throughout this chapter, since they establish
the structure of the regulations for
wastewater.
The rule contains many of the same
requirements found in the wastewater
section of Subpart G of the HON (§63.131-
.149). This includes vapor suppression
requirements, air pollution control device
(APCD) requirements, compliance
demonstration procedures, inspection and
monitoring requirements, and requirements
for certain liquid streams in open systems.
Please be aware that the HON regulations
are not exactly the same as the
pharmaceutical MACT regulations, and the
HON regulations should not be used to
interpret specific requirements of the
pharmaceutical MACT.
7.2 Structure of the Regulation
The pharmaceutical MACT addresses
wastewater requirements in several sections.
General applicability provisions are
contained in §63.1250 and definitions are
provided in §63.1251. More specifically,
§63.1256 covers wastewater standards and
§63.1257(e) covers initial compliance
demonstration procedures for wastewater.
Wastewater also is addressed in §63.1252
(Standards: General) and §63.1258-1260
(Monitoring, Record Keeping and
Reporting). The primary components of the
wastewater provisions are shown in Figure
7-1.
What Wastewaters are Subject to
the Pharmaceutical MACT ?
7.3 Applicability
A wastewater stream is subject to this
regulation if it meets the definition of a
wastewater stream, per §63.1251.
Wastewater Stream Definition
The definition of a wastewater stream is:
1. Water that is discarded from a
PMPU through a single Point of
Determination (POD),
2. Has a concentration of Partially
Soluble HAP (PSHAP) and /or
Soluble HAP (SHAP) compounds of
at least 5 parts per million by weight
(ppmw), and
3. Has a Total HAP load of at least 0.05
kg/yr.
Point of Determination - Point where a
wastewater stream exits the process,
storage tank, or last recovery device. If
the soluble or partially soluble HAPs
are not recovered for re-use before
discharge, then the discharge point
from the process equipment or storage
tank is the POD. There can be more
than one POD per process or PMPU.
The regulated wastewater compounds
identified above as Partially Soluble HAP
(PSHAP) and Soluble HAP (SHAP) are
listed in Tables 2 and 3 of the regulation.
The sum of PSHAP and SHAP compounds
is referred to as Total HAP.
7-2
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Exemptions
The following are not considered regulated
wastewaters per the definition of wastewater
stream:
Stormwater from segregated sewers,
Water from firefighting & deluge
systems (including testing of such
systems),
Spills,
Water from safety showers,
Samples of a reasonable size for
analysis,
Equipment leaks,
Wastewater drips from procedures
such as disconnecting hoses after
clearing lines, and
Noncontact cooling water.
Scrubber Effluent
If a scrubber is being used to control vent
streams containing partially soluble HAP
(PSHAP), in order to meet the process vent
standards in §63.1254, the effluent from the
scrubber is considered an affected
wastewater stream and is therefore subject to
the wastewater provisions in the MACT.
Multiphase Wastewater Streams
The regulations at §63.1256(a)(3) provide
that a separate phase that can be isolated
through gravity separation cannot be
discharged to a waste management or
treatment unit, unless it is discharged to a
RCRA unit.
Table 2 to Subpart GGG. Partially
Soluble HAP
1.1.1-Trichlorocthanc (methyl chloroform)
1.1.2.2-Tctrachlorocthanc
1.1.2-T richlorocthanc
1.1-Dichlorocthvlcnc (vinylidcnc chloride)
1.2-Dibromocthanc
1.2-Dichloroethane (ethylene dichloride)
1.2-Dichloropropane
1.3-Dichloropropcne
2.4.5-Trichlorophenol
2-Butanone (mek)
1.4-Dichlorobcnzcne
2-Nitropropanc
4-Mcthyl-2-pcntanonc (mibk)
Acctaldchvdc
Acrolein
Acrylonitrile
Allyl chloride
Benzene
Benzyl chloride
Biphenyl
Bromoform (tribromomcthane)
Bromomcthane
Butadiene
Carbon disulfide
Chlorobenzene
Chloroethane (ethyl chloride)
Chloroform
Chloromethane
Chloroprcne
Cumcnc
Dichloroethyl ether
Dinitrophenol
Epichlorohvdrin
Ethyl acrvlate
Ethylbenzene
Ethylene oxide
Hcxachlorobcnzcne
Hexachlorobutadicne
Hcxachloroethane
Methyl methacrylate
Methyl-t-butvl ether
Methvlene chloride
7-3
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Table 2 to Subpart GGG. Partially
Soluble HAP (cont.)
N.N-dimcthylaniline
Propionaldchvdc
Propylene oxide
Styrcnc
Tctrachlorocthcne (pcrchlorocthvlcnc)
Tctrachloromcthanc (carbon tetrachloride
Toluene
Trichlorobcnzcne (1.2.4-)
Trichlorocthylcnc
Trimcthvlpcntanc
Vinyl acetate
Vinyl chloride
Xylene (m)
Xylene (o)
Xylene (p)
N-hexane
Table 3 to Subpart GGG. Soluble
HAP
1.1 -Dimethylhydrazine
1.4-Dioxane
Acctonitrile
Acctophcnone
Diethyl sulfate
Dimethyl sulfate
Dinitrotolucnc
Ethylene glycol dimethyl ether
Ethylene glycol monobutvl ether acetate
Ethylene glycol monomethyl ether acetate
Isophorone
Methanol (methyl alcohol)
Nitrobenzene
Toluidene
7-4
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Wastewater (WW)
Applicability
.1251 and. 1256
Wastewater
Standards
.1256
Wastewater
Compliance
Demonstrations
.1257(e)
Applicability
Determinations
Vapor Suppression
Performance Standards-
Emissions Control
Performance Standards-
WW Treatment
WW Treatment
WW Definitions
WW Exemptions
.1251
.1256(a)(3)
WW Concentration and
Load Determinations -1256(a)(1 )(i)
Affected WW
Designations
Equipment
Specifications
Operating Practices
l&M Procedures
Equipment
Specifications
APCD Performance
Requirements
Treatment Type
Standards
.1256(a)(1)(H)
.1256(b)(f)
.1256(b)(f)
.1256(b)(f)
.1256(h)(2)(4)
.1256(h)(2)(4)
1256(g)
Applicability
Vapor Suppression
Emissions Control
Treatment Performance
Requirements _i ^bb(g)
Methods for Determining
Applicability .1257(e)(1)
Document Equipment 19(-o/iwi \
Type and l&M
Performance Testing .1257(e)(3)(i)
Design Evaluation .1257(e)(3)(ii)
Performance Testing .I257(e)(3)(iii)
Design Evaluation .I257(e)(2)(ii)
Wastewater
Monitoring
.1257(e)
Vapor Suppression
Emissions Control
Wastewater Treatment
Startup, Shutdown,
and Malfunction
Production Level
Monitoring Frequency
and Averaging Time
l&M Procedures
APCD Parameters
WWT Parameters
1258(g)(h)
.1258(b)
.1258(g)(23)
Startup, Shutdown, and ,,Q,aU,.
Malfunction Parameters -1iioaww
Production Level
Parameters
. 1259(b)(c)
Establish Monitoring .1258(g)(13)
Frequency and Averaging Time
Figure 7-1. Primary Components of Wastewater Provisions (not including Recordkeeping or
Reporting)
7-5
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Maintenance Wastewater
Wastewater generated during maintenance
activities is not subject to the full extent of
the MACT standards. There are, however,
substantive requirements for maintenance
wastewater. Primarily, the regulations
require that the owner/operator follow a
written plan to control emissions to the
atmosphere.
Maintenance Wastewater - Wastewater
generated by the draining of process fluid
from components in the pharmaceutical
manufacturing process unit into an
individual drain system prior to or during
maintenance activities. Maintenance
wastewater can be generated during
planned and unplanned shutdowns and
during periods not associated with a
shutdown. Examples of activities that can
generate maintenance wastewaters include
descaling of heat exchanger tubing bundles,
cleaning of distillation column traps,
draining of pumps into an individual drain
system, and draining ofportions of the
pharmaceutical manufacturing process unit
for repair. Wastewater from cleaning
operations is not considered maintenance
wastewater.
Owners/operators with maintenance
wastewater containing HAPs must comply
with the following four requirements:
1. Prepare a description of management
for wastewater generated from the
emptying and purging of equipment
during temporary shutdowns for
inspections, maintenance, and repair
AND during periods that are not
shutdowns (i.e. routine
maintenance). In the description:
Identify process equipment or
maintenance tasks that are
anticipated to create
wastewater during
maintenance activities,
Describe the procedures that
will be followed to manage
the wastewater and control
HAP emissions to the air, and
Describe the procedures that
will be followed when
clearing materials from
process equipment.
2. Modify the information provided in
1. as needed after each maintenance
procedure, based on actual
procedures followed and wastewater
generated.
3. Follow these plans as part of the
startup, shutdown and malfunction
(SSM) plan required under
§63.6(e)(3).
4. Maintain a record of the information
needed to prepare the description
under 1.) and the adjustments under
2.). The recorded information must
be maintained.
Heat Exchange Systems
Heat exchange systems that cool process
equipment or materials used in a
pharmaceutical manufacturing operation
must be checked for releases of HAPs if the
process equipment contains materials that
are greater than 5% HAPs. The specific
requirements are provided at §63.104 and
63.1252(c)(2). For equipment that meets
current good manufacturing practice
(CGMP) requirements in 21 CFR Part 211,
the owner/operator may elect to use the
physical integrity of the reactor as the
surrogate indicator of heat exchanger system
7-6
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leaks around the reactor. If a leak is
detected, the system must be repaired no
later than 45 days.
If CGMP is not used to identify leaks in heat
exchange systems, then one of the following
methods from §63.104 must be used.
Cooling water in heat exchanger systems
may be monitored quarterly using HAP,
TOC, or an alternative constituent that will
identify the presence of leaks. If the cooling
water in a heat exchange system is subject to
NPDES permit limits on HAP, TOC, or a
related compound, and such limits are 1
ppmw or less, then the NPDES permit
compliance monitoring can be used to detect
cooling system leaks.
If the heat exchange system is operated with
a minimum pressure on the cooling water
side at least 35 kPa greater than the
maximum pressure on the process side,
cooling water monitoring is not required.
If a leak is detected by any of the above
methods, the system must be repaired no
later than 45 days following detection.
Equipment in Open Systems - Drains,
Manholes, Lift Stations, Trenches, Pipes,
Oil/Water Separators, Tanks
Section 63.1252(f) of the MACT regulations
requires that steps be taken to prevent
releases in systems upstream of the point of
determination (POD). Drains or drain hubs,
manholes, lift stations, trenches, pipes,
oil/water separators, and tanks that handle
affected liquid streams are subject to these
requirements. The specific requirements are
listed in Table 5 of the regulations. They
essentially require tightly-fitting solid
covers; emissions can be vented to process
or to a control device that meets the
wastewater control device standards at
§63.1256(h)(2). The intent of this section is
to require the closure of systems such as in-
process recycle/recovery systems. It is not
intended to be applied to process and storage
tanks with vents that are in compliance with
the process vent standards.
7.3.1 Affected Wastewater Criteria
If a wastewater meets the definition of a
"wastewater stream" and the HAP
concentration and load threshold levels
described below, it must meet the
requirements of this regulation. This
document describes the 4 affected
wastewater categories as shown below in
Figure 7-2.
NOTE - PMOs opting to comply with the
wastewater standards by using the 95%
mass reduction option for biological
treatment processes are subject to more
stringent suppression standards. In this
circumstance any wastewater stream (i.e.
any stream containing at least 5 ppmw
PSHAP or SHAP) is subject lo I he vapor
suppression standards and all wastewater
streams must be included in the percent
reduction demonstration. Under the other
compliance options only "affected"
wastewater streams are subject to the vapor
suppression standards.
7-7
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New or Existing
New
New or Existing
Wastewater has total
HAP from the
PMPU >0.25 Mg/yr
Annual average
PSHAP at the
POD > 1300 ppmw
OR
Annual average total
HAP at the
POD >5200 ppmw
A
,1256(a)(1)(i)(A)
B
,1256(a)(1)(i)(B)
Wastewater has total
HAP from the
facility >1 Mg/yr
Annual average total
HAP at the
POD > 10,000 ppmw
C
-1256(a)(1)(i)(C)
Wastewater has total
HAP from the
PMPU >1 Mg/yr
Annual average
SHAP > 110,000 ppmw
D
,1256(a)(1){i)(D)
*Note - Regardless of annual loading or concentration, wastewater from a scmbber used to control
PSHAP containing vent streams in order to comply with the process vent standards is considered to be an
affected wastewater stream.
Figure 7-2. Four Affected Wastewater Categories A-D
¦»..£< Note on Wastewater HAP
Concentrations: Wastewater FIAP
V""y concentration is used in two ways
throughout this rule. One is what
can be called the wastewater HAP emission
potential concentration and the other is just
the wastewater HAP concentration. The
emission potential concentration is the
portion of a wastewater HAP compound that
theoretically volatilizes into air. Emission
potential values are determined by dividing
true HAP wastewater concentration by the
compound specific fraction measured (Fm)
factors listed in Table 8 of the regulation.
The rule does not specifically use the term
"emission potential concentration," but
whenever Method 305! is mentioned, this
means emission potentials, (i.e., Method
305 is used to determine wastewater HAP
emission potential concentration).
If method 305 is used to determine PSHAP
and SHAP concentrations in wastewater, the
measured concentrations must be adjusted
by
the Fm value to determine if a wastewater is
affected. If any of the other analytical
methods listed in 63.1257(a)(10) are used
for the determination, the measured PSFIAP
and SHAP concentrations are not adjusted.
*Method 305 = Measurement of Emissions Potential
of Individual Volatile Organic Compounds in Waste
7-8
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Where is a Wastewater Stream
Characterized for Determining
Applicability ?
7.3.2 Characterizing or Designating
Wastewater as Affected
For determining whether a wastewater is
affected, an owner/operator (O/O) can
either:
1) Characterize a wastewater stream at
each Point of Determination (POD),
OR
2) Designate a wastewater stream as
affected.
If the
owner/
operator..
Characterizes
the
wastestream
Designates
the
wastestream
Then....
Owner/operator must determine annual
average concentration and load (see 4
categories A-D on previous page)
Owner/operator not required to
determine annual average concentration
and load.
Must meet same standards as those
applicable to characterized streams.
The wastewater handling equipment
upstream of point of determination must
meet vapor suppression and emissions
control standards (discussed in section
7.1).
Downstream of the point of
determination, wastewater must meet
treatment standards as well as vapor
suppression and control requirements.
Wastewater treatment options for
designated streams do not include
treating streams to 50 ppmw PSHAP,
520 ppmw SHAP or using enhanced
biological treatment.
multiple potential affected wastewater
streams without having to determine
applicability for each one. There are no
restrictions on where a wastewater stream is
Recovery device - an individual unit of equipment
usedfor recovering chemicals for fuel value, use,
reuse, or for sale for fuel value, use, or reuse.
Examples include decanters, strippers, and thin-
film evaporation units.
designated, other than that it must be at or
downstream from the point of determination
(POD).
7.3.3 POD
If a wastewater stream is to be
characterized for determining applicability,
the characterization must be at a POD. A
POD means the point where the stream exits
the process, storage tank, or last recovery
device. If HAPs are not recovered for reuse
from the water before discharge, the
discharge point at the process equipmjent or
storage tank is the POD, as shown in the
example below for Site #2. If streams are
routed to a recovery device, the discharge
from the recovery device is the POD, as
shown below for Site #1.
There can be more than 1 POD per process
or PMPU.
Figure 7-3 presents sample process
wastewater flow layouts showing example
PODs and PMPUs.
The O/O may use a combination of
characterization or designation for different
affected wastewaters generated at the source.
The designation procedure allows an O/O to
choose a location further downstream of
7-9
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Figure 7-3. Example Wastewater Flow Scheme Showing POD Locations.
7.4 Standards
If a wastewater stream (including scrubber
blowdown from units that treat PSHAPs)
falls into one of the four criteria categories
(referred to as A-D in Figure 7-2) and is not
excluded as listed above, the facility is
subject to Subpart GGG wastewater
standards. The requirements can be
separated into:
vapor suppression standards (cover
and operate equipment to avoid
losses to the air),
performance standards
wastewater treatment standards
air emissions control standard (use
APCDs to control emissions of
PSHAPs and SHAPs vented during
wastewater treatment)
7.4.1 Vapor Suppression Standards
Summary
Vapor Suppression (VS) requirements are
provided for five kinds of waste
management units:
wastewater tanks
surface impoundments
containers
individual drain systems
oil water separators
(treat wastewater to remove HAPs)
and
7-10
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Vapor suppression standards, summarized in
Table 7-1 below, include:
equipment specifications
operating practices, and
equipment inspection and monitoring
(I and M) procedures.
Table 7-1. SUMMARY OF
WASTEWATER VAPOR
SUPPRESSION STANDARDS
Standard
Specification
Equipment
Specifications
specified equipment types
designed to minimize loss of
airborne HAPs to the
atmosphere (e.g., tank roofs,
surface impoundment covers,
container vent systems,
sewer drain water seals)
Operating
Practices
specified procedures to
follow to minimize loss of
HAP vapors (e.g. wastewater
container filling guidelines)
Inspection
and
Monitoring
Procedures
periodic inspections
conducted to minimize HAP
losses from worn equipment
or improper operating
practices (e.g., visually
inspect for cracks, gaps, or
holes in wastewater junction
box covers)
In characterizing a wastestream to
determine applicability of MACT
wastewater provisions, is the owner or
operator required to determine the annual
average concentration of Partially Soluble
HAPs and Soluble HAPs ? The O/O may
choose to designate a wastewater stream as
affected. If this is done, then the annual
average PSHAP and SHAP wastewater
concentrations need not be determined.
However, if the 0/0 chooses to determine
concentrations for assessing (i.e..
characterize), then it must be done in such a
way that concentration values represent the
annual average. The annual average is
defined as the total mass of HAP (PSHAP or
SHAP) occurring in the wastewater during a
calendar year divided by the total mass of
the wastewater. Determinations can be made
using either test methods, knowledge of the
wastewater stream, or bench-scale or pilot
scale test data. If the determination is
made:
1) downstream of the POD where
two or more streams have joined.
2) after the stream has been treated.
or
3) after losses to the atmosphere
have occurred.
then adjustments must be made to the data so
that it represents conditions at the POD.
Values derived from testing or from applying
knowledge of the wastewater must be
reported in the Notification of Compliance
Status report. Values derived from bench-
scale or pilot scale test data must be
documented in the Precompliance report.
Additionally, if a site conducts wastewater
sampling to characterize the wastewater,
then the site must develop and maintain, on-
site. a Sampling Plan to document measures
taken to ensure that volatization losses arc
minimized during sampling.
7-11
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VS: Wastewater Storage Tanks
The first of the vapor suppression standards
is for wastewater tanks, which are provided
in §63.1256(b). These requirements are
summarized in Table 7-2.
Wastewater Tank - a stationary waste
management unit that is designed to contain an
accumulation of wastewater or residuals and is
constructed primarily of nonearthen materials
(e.g., wood, concrete, steel, plastic) which
provide structural support. Flow equalization
tanks are included in the definition.
If the tank meets certain size and maximum
true vapor pressure criteria, the O/O must
comply with Tank Roof requirements
(Fixed, Floating, etc) and associated Closed
Vent System and APCD requirements (if
applicable). The definition of maximum
true vapor pressure provides guidance on
how to calculate it.
Note on using open or closed
biological treatment processes:
Waste management units
specifically used for biological
treatment are not subject to wastewater
storage tank or surface impoundment
vapor suppression requirements. The
processes must be designed to meet the
definition of either an open biological
treatment process or a closed biological
treatment process in order for the exemption
to apply.
Maximum True Vapor Pressure - the
equilibrium partial pressure exerted by the total
organic HAP in the stored or transferred liquid
at the temperature equal to the highest calendar-
month average of the liquid storage or transfer
temperature for liquids stored or transferred
above or below the ambient temperature or at
the local maximum monthly average temperature
as reported by the National Weather Service for
liquids stored or transferred at the ambient
temperature, as determined:
In accordance with methods described
in Chapter 19.2 of the American
Petroleum Institute's Manual of
Petroleum Measurement Standards,
Evaporative Loss From Floating-Roof
Tanks (incorporated by reference as
specified in §63.14); or
As obtained from standard reference
texts; or
As determined by the American Society
for Testing and Materials Method
D2879-97, Test Method for Vapor
Pressure-Temperature Relationship and
Initial Decomposition Temperature of
Liquids by Isoteniscope (incorporated
by reference as specified in §63.14);
or
Any other method approved by the
Administrator.
7-12
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Table 7-2. WASTEWATER STORAGE TANK VAPOR SUPPRESSION STANDARDS
Criteria
Vapor Suppression Standards
Tank Capacity, T
(m3)
Maximum
True
Vapor
Pressure
(kPa)
Required
Standard
Description &
Section No. {63.1256 )}
T < 75
63.1256(b)(1)
- (b)(1) = Control w/ Fixed Roof (If tank is used for
heating, exothermic treatment, or sparging, resulting
in an increase in HAP emissions of 5% over that
which would occur if no heating, exothermic
treatment, or sparging activities occurred, then
standard is (b)(2))
- (b)(2) = Comply w/ Inspection & Maintenance
procedures {(b)(3-9)}' and control emissions using
one of the following:
Fixed Roof/Closed Vent System to APCD,
Fixed Roof/Internal Floating Roof
External Floating Roof
Equivalent means of control
75 ^ T< 151
< 13.1
63.1256(b)(1)
> 13.1
63.1256(b) (2)
T ^151
<5.2
63.1256(b)(1)
> 5.2
63.1256(b) (2)
1 A complete list of I & M procedures is given in the Monitoring chapter.
VS: Wastewater Surface Impoundments
Wastewater Surface Impoundments
standards are listed in §63.1256(c) and
summarized in Table 7-3. The regulation
addresses any surface impoundment that
receives, manages or treats affected
wastewater. Vapors from surface
impoundments are suppressed using either
(1) a Cover (i.e, rigid) and Closed Vent
System routed to a control device or (2) a
Floating Membrane system.
7-13
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Table 7-3. WASTEWATER SURFACE IMPOUNDMENT VAPOR SUPPRESSION
STANDARDS (§63.1256(c)}
Vapor
Suppression
Method (Choice)
Standard
Cover/Closed
Vent System to a
Control Device, or
A. Unless system is maintained under vacuum, a Cover/Closed Vent System must be
maintained according to 63.1258(h) {Leak inspection provisions for Vapor
Suppression Equipment},
B. Openings maintained in closed position, and
C. Cover used at all times
Floating
Membranes
A. Designed to float and form continuous barrier
B. Constructed from synthetic that is either
1. HDPE >100 mils
2. A material or composite of materials having the equivalent organic
permeability and physical and chemical properties of 100 mils HDPE and
that maintains material integrity for service life of material.
C. No visible cracks, holes, gaps or open spaces between cover section seams or
between the interface of the cover edge and its foundation mountings
D. Each opening equipped w/ closure device that when closed shows no visible
cracks, holes, gaps, or other open spaces in the closure device or between the
perimeter of the cover opening and the closure device.
E. Equipped w/ one or more emergency storm water drains (optional)
F. Closure devices shall be made of suitable material
G. When wastewater is present, openings shall be closed and cover on except during
inspection, maintenance, etc. Shall be maintained (inspected) according to
63.1258(h).
(49 CFR part 178) or maintaining w/o leaks
according to 63.1258(h).
Container - as used in the wastewater
provisions, means any portable waste
management unit that has a capacity greater
than or equal to 0.1 m ' in which a material is
stored, transported, treated, or otherwise
handled. Examples of containers are drums,
barrels, tank trucks, barges, dumpsters, tank
cars, dump trucks, and ships.
VS: Wastewater Containers
Wastewater Containers standards contained
in §63.1256(d) are summarized in Table 7-4.
The regulation addresses any container with
a capacity greater than or equal to 0.1 m3 (25
gallons) that receives, manages or treats
affected wastewater. For containers with
capacity greater than 0.42 m3 (110 gal), the
standards call for using a cover and openings
to be maintained according to §63.1258(h),
Leak Inspection Provisions for Vapor
Suppression
Equipment. For those less than 0.42 m3 (but
greater than 0.1 m3), the O/O can choose
between meeting existing DOT regulations
7-14
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Table 7-4. WASTEWATER CONTAINERS VAPOR SUPPRESSION STANDARDS
{§63.1256(d)}
Size
Standard Description (with Section Numbers)
> 0.42
m3 (110
gal)
1. Maintain cover as follows;
- Maintain cover and openings according to §63.1258(h),
- Keep cover and openings closed unless for filling, removal, inspection,
sampling, pressure relief or safety related reasons.
2. When filling;
- Either use submerged pipe when filling, with end of fill pipe no more
than 15 cm or 2 pipe diameters from the bottom of the container, OR
locate container within enclosure that has closed vent system that routes
organic HAP vapors vented from the container to a control device, OR use
a closed vent system to vent displaced vapors from the container either to a
control device or back to the equipment from which the wastewater is
transferred.
- Keep cover and openings closed unless needed for filling
3. When it is necessary for container to be open, locate it w/in an enclosure w/
Closed Vent System that routes vapors to APCD and:
- Maintain enclosure according to §63.1258(h) - see Monitoring chapter
for I and M requirements,
- Maintain APCD according to §63.1256(h),
- Inspect Closed Vent System according to §63.1258(h),
- If under vacuum, not required to maintain according to §63.1258(h).
< 0.42
m3 (110
gal)
1. Maintain cover as follows;
- Comply with either:
A. Meet DOT 49 CFR 178, or
B. Maintain without leaks according to §63.1258(h). See
Monitoring chapter for I and M requirements.
- Keep cover and openings closed unless for filling, removal, inspection,
sampling, pressure relief or safety related reasons.
2. When it is necessary for container to be open, locate it w/in an enclosure w/
Closed Vent System that routes vapors to APCD and:
- Maintain enclosure according to §63.1258(h). See Monitoring chapter
for I and M requirements.
- Maintain APCD according to §63.1256(h),
- Inspect Closed Vent System according to §63.1258(h),
- If under vacuum, not required to maintain according to §63.1258(h).
7-15
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VS: Individual Drain System
Wastewater Individual Drain Systems
standards contained in §63.1256(e) are
summarized in Table 7-5. The standard
addresses any individual drain system that
receives or manages affected wastewater or
residual removed from affected wastewater.
The standards present 2 options for
suppressing emissions from individual drain
systems (IDS). The first option is using a
closed IDS with a Closed Vent System that
is vented to an APCD. The second option is
to minimize emissions using water seals
and/or tightly fitting caps or plugs on all
entrances to the drain systems and for
junction boxes.
Junction boxes may be vented to the
atmosphere if they have minimal water
depth fluctuations, have vapor blocks at
either their entrance(s) or exit(s), and have a
vent pipe that meets specified design
criteria. Building sewers may be vented
through roof vents and outside sewers may
be vented at locations other than at junction
boxes, provided that the vent pipe height (at
least 90 cm) and diameter (no greater than
10.2 cm in inside diameter) are the same as
those for junction box vents AND the sewer
has a water seal at the first downstream
junction box.
7-16
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Table 7-5. WASTEWATER INDIVIDUAL DRAIN SYSTEM VAPOR SUPPRESSION
REQUIREMENTS (§63.1256(e)}
Standard
(choice of
either)
Description
1256(e) (1-3),
OR
1. Maintain cover on each opening. If vented route through Closed Vent System to APCD
and:
- For cover and openings:
A. Maintain according to 63.1258(h) - see Monitoring chapter for I and M
requirements
B. Keep in closed position when wastewater is in drain except for
sampling, removal, inspection, maintenance or repair.
- APCD designed/operated/inspected according to 63.1256(h)
- Closed Vent System inspected according to 63.1258(h),
- If under vacuum, not reauired to maintain bv 63.1258(h). and
- Design individual drain system to segregate vapors from drain systems that do
not manage affected wastewaters and prevent releases to atmosphere.
2 & 3. Inspection and Maintenance procedures - in Monitoring chapter
1256(e)(4-6)
4. Comply w/ following
- Equip drain system openings w/ water seal, tightly fitting caps or plugs and
- For water seal, maintain system to verify flow of water in trap, and
- If water seal on drain receiving wastewater, discharge pipe must be
submerged or flexible shield installed (except on water seals used on hubs
receiving wastewater not subject to this provision)
- Each junction box must have tightly fitting solid cover. If vented, comply w/
either
A. Vent to process or to Closed Vent System vented to APCD. Closed
Vent System maintained according to 63.1258(h) and APCD according to
63.1256(h), or
B. If box uses gravity flow or there is only slight variation in liquid level
then
1. Vent pipe > 90 cm length and < 10.2 cm inside diameter, and
2. Water seals installed to restrict ventilation on either the box
influent or effluent.
- Each sewer line carrying affected wastewater must not be vented to atmosphere
unless the sewer line entrance to the first downstream junction box is water sealed
and the sewer line vent pipe is > 90 cm long and < 10.2 cm inside diameter.
5 & 6. Inspection and Maintenance procedures - in Monitoring chapter
VS: Oil-Water Separators
Wastewater Oil-Water separators standards
contained in §63.1256(f) are summarized in
Table 7-6. The regulation addresses any oil-
water separator that receives, manages, or
treats affected wastewater or residuals
removed from wastewater. Vapors are to be
suppressed using either a Fixed Roof (with a
closed vent system and control device),
Floating Roof, or Equivalent Means. An
Equivalent Means of vapor suppression
must be demonstrated by performance
testing or engineering evaluation.
7-17
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Table 7-6. WASTEWATER OIL WATER SEPARATORS VAPOR SUPPRESSION
STANDARDS {§63.1256(f)}
Equip
with...
Description (with Section Numbers)
Fixed Roof
with CVS and
Control
Device,
OR
1. Maintain Roof and openings according to §63.1258(h) (see Monitoring chapter for I
and M requirements), and
2. Keep in closed position when wastewater is in oil/water separator except for
sampling, removal, inspection, maintenance or repair, and
3. Design, operate, inspect APCD according to §63.1256(h) (See Table 7-2), and
4. Inspect Closed Vent System according to §63.1258(h)
5. Negative pressure not required to comply with §63.1258(h)
Floating Roof
1. Design floating roof per §60.693-2(a)(l)(i) and (ii), (a)(2), (a)(3), and (a)(4).
- Primary seal - liquid-mounted or mechanical shoe
- Secondary seal above the primary seal; cover the annular space between the
floating roof and the wall of the separator
- Equip each opening in the roof with gasketed cover, seal, or lid. Keep closed
except during inspection and maintenance.
- Roof must float on liquid (i.e., off the roof supports) except during abnormal
conditions.
- Roof may be equipped with emergency roof drains for removal of stormwater;
use slotted membrane fabric cover that covers at least 90% of the
drain opening area or a flexible fabric sleeve seal.
2. Perform seal eat) measurements according to 40 CFR 60 Sub Dart OOO
60.696(d)(1) and scheduled as follows:
- Primary seals: w/in 60 days after installation/wastewater introduction and once
every 5 yrs thereafter, and
- Secondary Seals: w/in 60 days after installation/wastewater introduction and
annually thereafter.
QandA
Q. What are CEFs and IWPs ?
A. IJ sled with each vapor suppression standard are inspection procedures for
Control Equipment Failures (CFF) and or Improper Work Practices (IWP)
for each equipment type, lor example, one of the (*FFs listed for wastewater
tanks is when a "gasket, joint, lid or cover has a crack, gap or is broken. "
An example of an IWP for fixed roof tanks is leaving open any access doors
or any other opening when such door or opening is not in use.
7-18
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What are the Performance
Standards for Wastewater
Treatment?
7.4.2 Wastewater Treatment Standards
The wastewater treatment standards are
found in §63.1256(g). Basically, there are
six treatment standards in (g)(8 -13). A
summary of how they apply to the four
affected wastewater categories, A - D
(Figure 7-2), is discussed below and shown
in Table 7-7.
Wastewater from New and Existing
Sources
For new or existing sources, the owner must:
Treat an affected PSHAP wastewater
stream (category A)
to remove 99% PSHAP, or
to less than 50 ppmw
PSHAP,* or
remove 95% total HAP (from
all wastewaters whether
affected or unaffected) in a
biological treatment unit, or
use a RCRA-permitted (or
interim status) treatment
device, such as an
incinerator, boiler, or
underground injection.
Treat an affected Total HAP
wastewater (categories B & C)
to remove 99% PSHAP and
90% SHAP, or
to less than 50 ppmw PSHAP
and less than 520 ppmw
SHAP,* or
use enhanced biotreatment
(allowed only if PSHAP is
less than 50 ppmw or if the
wastewater has been treated
upstream in compliance with
(g)(8) (50 ppmw PSHAP or
99% reduction of PSHAP)
and the wastewater is not
designated), or
remove 99% PSHAP and
treat to 520 ppmw SHAP, or
treat to 50 ppmw PSHAP and
remove 90% SHAP, or
to remove 95% Total HAP
(from all wastewaters
whether affected or
unaffected) in a biological
treatment unit, or
use a RCRA-permitted (or
interim status) treatment
device, such as an
incinerator, boiler, or
underground injection.
JL, NOTE(*): Concentration
standards cannot be used (1) when
1V""' biological treatment is used or (2)
when the wastewater streams are
designated.
For an existing source that has been
designated as affected (per
§63.1256(a)(l)(ii)), the wastewater
treatment requirements are:
PSHAP reduced by 99% and SHAP
reduced by 90%, or
Total HAP reduced by 95% in a
biotreatment unit, or
Treatment in a RCRA-permitted
treatment device.
Wastewater from New Sources
For new sources, the owner/operator must:
Treat an affected SHAP wastewater
stream with greater than 110,000
ppmw SHAP (category D)
7-
19
-------
to remove 99% SHAP, or
use a RCRA-permitted (or
interim status) treatment
device, such as an
incinerator, boiler, or
underground injection.
Management of Residuals from
Wastewater Treatment
Wastewater residuals are defined as HAP-
containing liquids or solid materials
removed from a wastewater stream by a
waste management unit or treatment process
that does not destroy organics. Examples of
residuals include:
the organic layer and bottom residue
removed by a decanter or organic-
water separator, and
overheads from a steam stripper or
air stripper.
Materials not classified as residuals include:
silt, mud, or leaves,
bottoms from a steam stripper or air
stripper, and
sludges, ash, or other materials from
destructive treatment devices such as
biological treatment units and
incinerators.
There are several options for managing
residuals taken from the treatment of
affected wastewater:
recycle the residual back into the
production process or sell it to
another firm for recycling. Once the
residual is returned to a production
process, it is no longer subject to
regulation. OR
return the residual to the treatment
process. OR
treat the residual to reduce the total
combined mass flow rate of SHAP
and/or PSHAP by 99 percent or
more. (Use the performance tests in
63.1257(e)(2)(iii)(C) -
noncombustion, nonbiological
treatment process - or (D) -
combustion treatment process - to
demonstrate compliance.) OR
treat the residual in a RCRA-
regulated unit (hazardous waste
incinerator or underground injection
well.
In addition, tanks, surface impoundments,
containers, individual drain systems, and
oil/water separators used for the storage or
management of residuals must meet the
same design and operating requirements that
apply to these units when used for treatment
of affected wastewater (63.1256(b) - (f)).
What are the Standards for Air
Emissions Control?
7.4.3 Emissions Control Standards
Standards for control of air emissions vented
during the treatment process and from other
waste management units with covers and
closed vent systems are specified for air
pollution control devices (APCD) as either:
1) equipment specifications - for combustion
devices in terms of residence time and
temperature specifications.
or
2) APCD performance levels - in the form of
7-20
-------
Removal Efficiencies (RE) or APCD outlet
HAP concentrations.
A summary of the standards is shown in
Figure 7-4. Basically, there is a choice of 5
control standards as follows:
Combustion device achieving 95%
RE HAP, 20 ppmv outlet TOC @3%
02, or provide 0.5 sec residence time
at 760 deg C,
longer being used to treat affected
wastewater or residuals, OR
if additional time is necessary due to
the unavailability of parts, due to
circumstances beyond the control of
the owner/operator. Repair must be
done as soon as practical, In this
case, the reasons for delaying the
repair must be documented.
Vapor recovery system achieving
95% RE HAP or 20 ppmv outlet
TOC,
Flare meeting requirements of
§63.11(b),
Scrubber or other APCD achieving
95% RE HAP or 20 ppmv TOC.
NOTE: The APCD outlet
standard of 20 ppmv TOC is not
' available for APCDs controlling
vent streams from wastewater
surface impoundments or containers.
With regard to repairs to air pollution
control devices, if gaps, cracks, tears, or
holes are observed in the ductwork, piping,
or connection to covers and control devices
during an inspection, the owner/operator
must make an attempt within 5 calendar
days to fix the problem. Repair can be
delayed only if:
the repair cannot be done without a
shutdown or if the emissions
resulting from immediate repair
would be greater than those
anticipated to result from delaying
the repair. The equipment must be
repaired by the end of the next
shutdown, OR
the equipment is emptied or is no
7-21
-------
APCD shall be
designed and operated
according to one of the
technologies listed
befow
Vapor recovery system
(i.e., carbon adsorber,
condenser, etc) shall
reduce organic HAP
by 95% or TOO1 to
less than 20 ppmv
./!:!_»Illi.
Flare shall
meet 83.11(b)
requirements
Combustion device
shall comply with one
of the following
standards
A scrubber shall
reduce by chemical
destruction organic
HAP by 95% or TOC1
to 20 ppmv
MBMm
Any other APCD
shall reduce organic
HAP by 95% or TOC1
to 20 ppmv
Reduce
organic HAP
by 95%
Achieve outlet TOC
concentration of 20
ppmv @ 3% Og
Provide residence
time of 0.5 sec and
min. temp of 760°C
These non-combustion
TOC options cannot be
used for wastewater
surface impoundments
or containers.
Is the APCD
controlling a vent
stream with >20 ppmv
halogenated
compounds?
Yes
NO
125
Control hydrogen
halides or halogens to
95% or to 20 ppmv
before or after the
combustion device
Is APCD
a boiler
or process heater?
Yes
Introduce
vent gas into
flame zone
(U:
No
Demonstrate
compliance per
63.1257
Figure 7-4. Wastewater APCD Requirements in §63.1256(h)
7-22
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Table 7-7. WASTEWATER TREATMENT STANDARDS
Treatment
Options
Used
To
Treat
Source Type
Limitations
Citations
treat to < 50
ppmw
PSHAP
new and existing
(categories A, B,
and C)
- no biotreatment or dilution
- not available for designated streams
,1256(g)(8)(i)
.1256(a)(l)(ii)
99% total mass
removal/
destruction of
HAP
PSHAP
new and existing
(categories A, B,
and C)
,1256(g)(8)(ii)
SHAP
new (category
D)
- only required when SHAP
concentration is 110,000 ppmw and the
total PSHAP and SHAP load in
wastewater from the PMPU is >
lMg/yr
,1256(g)(12)
treat to <520
ppmw
SHAP
new and existing
(categories B
and C)
- no biotreatment or dilution
- not available for designated streams
,1256(g)(9)(i)
.1256(a)(l)(ii)
90% total mass
removal/
destruction of
HAP
SHAP
new and existing
(categories B
and C)
,1256(g)(9)(ii)
enhanced
biological
treatment
SHAP
new and existing
(categories A, B,
and C)
- system must meet the definition of
enhanced biological treatment
- may only be used for affected
wastewater with
< 50 ppmw PSHAP, or wastewater that
has been treated to less than 50 ppmw
PSHAP or to 99% reduction of
PSHAP
- not available for designated streams
,1256(g)(10)
.1256(a)(l)(ii)
95% mass
removal/
destruction of
total HAP with
biological
treatment unit
Total
PSHAP
and
SHAP
new and existing
(categories A, B,
and C)
- biological treatment is required
- all wastewater streams (as defined in
63.1252) entering the system must
achieve 95% HAP removal, except
wastewater already treated in
compliance with another treatment
option
- all wastewater streams (as defined in
63.1252) entering the system must be
managed in wastewater management
units (sewers, etc.) in compliance with
the MACT
1256(g)(ll)
7-23
-------
Treatment
Options
Used
To
Treat
Source Type
Limitations
Citations
RCRA pcrmillcd
or interim status
treatment, device
PSHAP
and/or
SHAP
new and existing
(categories A, B,
C,and D)
- systems include heaters, incinerators,
boilers, industrial furnaces, and
underground injection
,1256(g)(13)
Offsite Treatment or Onsite Treatment by
Someone Other Than Owner/Operator
The owner/operator may elect to transfer
affected wastewater (or a residual removed
from such wastewater) to an offsite
treatment operation or to an on-site
treatment operation being run by someone
else.
Owner/
Operator:
Responsibilities include...
of the
Affected
Source
ensuring that all waste management units on-site handling affected streams are in
compliance with wastewater management requirements (e.g., all drain systems and
tanks containing affected streams must comply with §63.1256(b)-(f)).
submitting a notice with each shipment stating that the wastewater or residual from the
wastewater contains PSHAP and/or SHAP that must be treated in compliance with the
regulations. If the transfer is continuous or ongoing, submit the notice with the first
shipment and whenever there is a change in the treatment required. Keep a record of
the notice in accordance with §63.1259(g).
7-24
-------
Owner/
Operator:
Responsibilities include...
of a
Treatment
System
Receiving
the
Wastewater
Submitting to EPA. prior to receiving any affected wastewater, a written certification
stating that any affected wastewater or affected wastewater residual will be treated in
compliance with:
S §63.1256(b)-(i) (requirements for tanks, surface impoundments, containers,
individual drain systems, oil water separators, plus other performance
standards for treatment), or
S Subpart D (if alternative emissions limitations have been approved), or
S §63.6(g) (use of an alternative nonopacity emission standard), or
S If the affected wastewater streams or residuals contain less than 50 ppmw
partially soluble HAP, then the person receiving them for treatment can:
i. comply with (g)(10) (enhanced biotreatment for SHAP) and cover
the waste management units up to the activated sludge unit, or
ii. comply with (g)(l l)(i) and (ii) (95 percent reduction in a biological
treatment unit), and (h) (emissions control device standards) and
cover the waste management units up to the activated sludge unit, or
iii. comply with (g)(10) (enhanced biotreatment for SHAP) provided
that the affected source owner/operator demonstrates that less than
5 percent of the total SHAP is emitted from waste management
units up to the activated sludge unit, or
iv. comply with (g)(l l)(i) and (ii), (95 percent reduction in a biological
treatment unit), and (h) (emissions control device standards),
provided that the affected source owner/operator demonstrates that
less than 5 percent of the total SHAP is emitted from waste
management units up to the activated sludge unit.
Securing the signature of the responsible official on the certification, and providing
the name and address of the certifying entity to the EPA Regional office.
NOTE ON REVOKING CERTIFICATION: A written statement must be sent to both EPA
and the owner/operator of the affected wastewater stating that the transferee is no longer
accepting responsibility for treatment of the affected wastewater. The transferee must give at
least 90 days notice. When the 90-day period is up, the owner/operator may not transfer
affected wastewater or residuals to the treatment operation.
What are the standards for wastewater treatment using multiple treatment
processes in series ?
The mass removal destruction efficiency requirements are the same.
However, efficiency calculation techniques differ for different treatment
configurations. If 11 aste 11 ater is conveyed by hard piping then mass re mo val
destruction efficiency is determined across the combination of treatment
processes. If 11'aste11 ater is not conveyed by hard piping then efficiency is
determined across each treatment process with total efficiency equal to the
sum of efficiencies from each component process.
Q and A
a
A.
7-25
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What is the Pollution Prevention
Option?
In lieu of the wastewater standards discussed
above, an owner or operator (O/O) can
choose to meet pollution prevention (P2)
standards. The P2 requirements are either:
reduce the production-indexed HAP
consumption factor (kg HAP
consumed/kg product produced) by
75% from a specified baseline
average established no earlier than
1987, or
reduce the production-indexed HAP
consumption factor by at least 50%
from a specified baseline average
established no earlier than 1987
(Monitoring Requirements). A complete
description of the required monitoring
procedures can be found in -4 Chapter 9 -
Monitoring. The following paragraph
presents a brief introduction to the initial
compliance demonstration requirements for
wastewater. A more complete description of
the requirements can be found in -4
Chapter 8 - Compliance Demonstration
and Testing Procedures.
AND reduce total PMPU HAP
emissions divided by the annual
production rate (kg HAP emitted per
year/kg produced per year) to a value
greater than 25%_of the average
production-indexed consumption
factor (i.e., achieve 50% reduction by
using pollution prevention and
achieve additional 25% by using
standard control devices). For more
information on the pollution
prevention option, see -4 Chapter
10- Pollution Prevention
Alternative.
7.5 Compliance Demonstration
Compliance demonstration procedures for
wastewater standards are listed in
§63.1257(e) - Test Methods and Compliance
Procedures - Compliance with Wastewater
Provisions. This section lists requirements
for demonstrating initial compliance.
Procedures for demonstrating on-going or
continual compliance are listed in §63.1258
7-26
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Q and A
Q. How do I demonstrate compliance for:
1) wastewater with multiple phases
2) treatment residuals ?
A. Wastes/reams with free phase HAP cannot be sent to individual drain systems,
stored in wastewater tanks or surface impoundments, or sent to treatment
units. The free phase HAP can only be discharged to a R( 7IA treatment unit,
per 63.1256(a)(3). Tor wastewater treatment residuals, the () () must either:
1. recycle the residua! back to the production process, or sell the material
for the purpose of recycling
2. return the residua! back to the treatment process,
3. destroy combined PSHAP/SHAP by at least 99%, or
4. treat the residual in a R( 'RA unit per §63.I256(g)(I3).
To demonstrate compliance with option I or 2, the ()/() must document
process configuration. To demonstrate compliance with option 3, the ()/()
should use compliance demonstration technique (" or 1) as discussed in
Appendix WWT.
The initial compliance demonstration
procedures as listed in §63.1257(e) are
basically separated into 3 parts:
Determination of wastewater HAP
concentration and load as it pertains
to wastewater applicability criteria
(i.e. annual concentration and annual
load),
Design Evaluation and Performance
Test procedures for demonstrating
compliance with air emissions
control (i.e., APCD) requirements,
and
Design Evaluation and Performance
Test procedures for demonstrating
compliance with wastewater
treatment standards.
Compliance with the vapor suppression
standards is done primarily through the
reporting provisions of the rule, which
require that the owner or operator document
the results of Inspection and Monitoring
procedures that are followed for wastewater
management units.
The reader is referred to Chapters 8 and 9
for more complete details on compliance
demonstrations and monitoring
requirements.
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Table 7-4. WASTEWATER CONTAINERS VAPOR SUPPRESSION STANDARDS
{§63.1256(d)}
Size
Standard Description (with Section Numbers)
> 0.42
m3 (110
gal)
1. Maintain cover as follows;
- Maintain cover and openings according to §63.1258(h),
- Keep cover and openings closed unless for filling, removal, inspection,
sampling, pressure relief or safety related reasons.
2. When filling;
- Either use submerged pipe when filling, with end of fill pipe no more
than 15 cm or 2 pipe diameters from the bottom of the container, OR
locate container within enclosure that has closed vent system that routes
organic HAP vapors vented from the container to a control device, OR use
a closed vent system to vent displaced vapors from the container either to a
control device or back to the equipment from which the wastewater is
transferred.
- Keep cover and openings closed unless needed for filling
3. When it is necessary for container to be open, locate it w/in an enclosure w/
Closed Vent System that routes vapors to APCD and:
- Maintain enclosure according to §63.1258(h) - see Monitoring chapter
for I and M requirements,
- Maintain APCD according to §63.1256(h),
- Inspect Closed Vent System according to §63.1258(h),
- If under vacuum, not required to maintain according to §63.1258(h).
< 0.42
m3 (110
gal)
1. Maintain cover as follows;
- Comply with either:
A. Meet DOT 49 CFR 178, or
B. Maintain without leaks according to §63.1258(h). See
Monitoring chapter for I and M requirements.
- Keep cover and openings closed unless for filling, removal, inspection,
sampling, pressure relief or safety related reasons.
2. When it is necessary for container to be open, locate it w/in an enclosure w/
Closed Vent System that routes vapors to APCD and:
- Maintain enclosure according to §63.1258(h). See Monitoring chapter
for I and M requirements.
- Maintain APCD according to §63.1256(h),
- Inspect Closed Vent System according to §63.1258(h),
- If under vacuum, not required to maintain according to §63.1258(h).
7-15
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VS: Individual Drain System
Wastewater Individual Drain Systems
standards contained in §63.1256(e) are
summarized in Table 7-5. The standard
addresses any individual drain system that
receives or manages affected wastewater or
residual removed from affected wastewater.
The standards present 2 options for
suppressing emissions from individual drain
systems (IDS). The first option is using a
closed IDS with a Closed Vent System that
is vented to an APCD. The second option is
to minimize emissions using water seals
and/or tightly fitting caps or plugs on all
entrances to the drain systems and for
junction boxes.
Junction boxes may be vented to the
atmosphere if they have minimal water
depth fluctuations, have vapor blocks at
either their entrance(s) or exit(s), and have a
vent pipe that meets specified design
criteria. Building sewers may be vented
through roof vents and outside sewers may
be vented at locations other than at junction
boxes, provided that the vent pipe height (at
least 90 cm) and diameter (no greater than
10.2 cm in inside diameter) are the same as
those for junction box vents AND the sewer
has a water seal at the first downstream
junction box.
7-16
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Table 7-5. WASTEWATER INDIVIDUAL DRAIN SYSTEM VAPOR SUPPRESSION
REQUIREMENTS (§63.1256(e)}
Standard
(choice of
either)
Description
1256(e) (1-3),
OR
1. Maintain cover on each opening. If vented route through Closed Vent System to APCD
and:
- For cover and openings:
A. Maintain according to 63.1258(h) - see Monitoring chapter for I and M
requirements
B. Keep in closed position when wastewater is in drain except for
sampling, removal, inspection, maintenance or repair.
- APCD designed/operated/inspected according to 63.1256(h)
- Closed Vent System inspected according to 63.1258(h),
- If under vacuum, not reauired to maintain bv 63.1258(h). and
- Design individual drain system to segregate vapors from drain systems that do
not manage affected wastewaters and prevent releases to atmosphere.
2 & 3. Inspection and Maintenance procedures - in Monitoring chapter
1256(e)(4-6)
4. Comply w/ following
- Equip drain system openings w/ water seal, tightly fitting caps or plugs and
- For water seal, maintain system to verify flow of water in trap, and
- If water seal on drain receiving wastewater, discharge pipe must be
submerged or flexible shield installed (except on water seals used on hubs
receiving wastewater not subject to this provision)
- Each junction box must have tightly fitting solid cover. If vented, comply w/
either
A. Vent to process or to Closed Vent System vented to APCD. Closed
Vent System maintained according to 63.1258(h) and APCD according to
63.1256(h), or
B. If box uses gravity flow or there is only slight variation in liquid level
then
1. Vent pipe > 90 cm length and < 10.2 cm inside diameter, and
2. Water seals installed to restrict ventilation on either the box
influent or effluent.
- Each sewer line carrying affected wastewater must not be vented to atmosphere
unless the sewer line entrance to the first downstream junction box is water sealed
and the sewer line vent pipe is > 90 cm long and < 10.2 cm inside diameter.
5 & 6. Inspection and Maintenance procedures - in Monitoring chapter
VS: Oil-Water Separators
Wastewater Oil-Water separators standards
contained in §63.1256(f) are summarized in
Table 7-6. The regulation addresses any oil-
water separator that receives, manages, or
treats affected wastewater or residuals
removed from wastewater. Vapors are to be
suppressed using either a Fixed Roof (with a
closed vent system and control device),
Floating Roof, or Equivalent Means. An
Equivalent Means of vapor suppression
must be demonstrated by performance
testing or engineering evaluation.
7-17
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Table 7-6. WASTEWATER OIL WATER SEPARATORS VAPOR SUPPRESSION
STANDARDS {§63.1256(f)}
Equip
with...
Description (with Section Numbers)
Fixed Roof
with CVS and
Control
Device,
OR
1. Maintain Roof and openings according to §63.1258(h) (see Monitoring chapter for I
and M requirements), and
2. Keep in closed position when wastewater is in oil/water separator except for
sampling, removal, inspection, maintenance or repair, and
3. Design, operate, inspect APCD according to §63.1256(h) (See Table 7-2), and
4. Inspect Closed Vent System according to §63.1258(h)
5. Negative pressure not required to comply with §63.1258(h)
Floating Roof
1. Design floating roof per §60.693-2(a)(l)(i) and (ii), (a)(2), (a)(3), and (a)(4).
- Primary seal - liquid-mounted or mechanical shoe
- Secondary seal above the primary seal; cover the annular space between the
floating roof and the wall of the separator
- Equip each opening in the roof with gasketed cover, seal, or lid. Keep closed
except during inspection and maintenance.
- Roof must float on liquid (i.e., off the roof supports) except during abnormal
conditions.
- Roof may be equipped with emergency roof drains for removal of stormwater;
use slotted membrane fabric cover that covers at least 90% of the
drain opening area or a flexible fabric sleeve seal.
2. Perform seal eat) measurements according to 40 CFR 60 Sub Dart OOO
60.696(d)(1) and scheduled as follows:
- Primary seals: w/in 60 days after installation/wastewater introduction and once
every 5 yrs thereafter, and
- Secondary Seals: w/in 60 days after installation/wastewater introduction and
annually thereafter.
QandA
Q. What are CEFs and IWPs ?
A. IJ sled with each vapor suppression standard are inspection procedures for
Control Equipment Failures (CFF) and or Improper Work Practices (IWP)
for each equipment type, lor example, one of the (*FFs listed for wastewater
tanks is when a "gasket, joint, lid or cover has a crack, gap or is broken. "
An example of an IWP for fixed roof tanks is leaving open any access doors
or any other opening when such door or opening is not in use.
7-18
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What are the Performance
Standards for Wastewater
Treatment?
7.4.2 Wastewater Treatment Standards
The wastewater treatment standards are
found in §63.1256(g). Basically, there are
six treatment standards in (g)(8 -13). A
summary of how they apply to the four
affected wastewater categories, A - D
(Figure 7-2), is discussed below and shown
in Table 7-7.
Wastewater from New and Existing
Sources
For new or existing sources, the owner must:
Treat an affected PSHAP wastewater
stream (category A)
to remove 99% PSHAP, or
to less than 50 ppmw
PSHAP,* or
remove 95% total HAP (from
all wastewaters whether
affected or unaffected) in a
biological treatment unit, or
use a RCRA-permitted (or
interim status) treatment
device, such as an
incinerator, boiler, or
underground injection.
Treat an affected Total HAP
wastewater (categories B & C)
to remove 99% PSHAP and
90% SHAP, or
to less than 50 ppmw PSHAP
and less than 520 ppmw
SHAP,* or
use enhanced biotreatment
(allowed only if PSHAP is
less than 50 ppmw or if the
wastewater has been treated
upstream in compliance with
(g)(8) (50 ppmw PSHAP or
99% reduction of PSHAP)
and the wastewater is not
designated), or
remove 99% PSHAP and
treat to 520 ppmw SHAP, or
treat to 50 ppmw PSHAP and
remove 90% SHAP, or
to remove 95% Total HAP
(from all wastewaters
whether affected or
unaffected) in a biological
treatment unit, or
use a RCRA-permitted (or
interim status) treatment
device, such as an
incinerator, boiler, or
underground injection.
JL, NOTE(*): Concentration
standards cannot be used (1) when
1V""' biological treatment is used or (2)
when the wastewater streams are
designated.
For an existing source that has been
designated as affected (per
§63.1256(a)(l)(ii)), the wastewater
treatment requirements are:
PSHAP reduced by 99% and SHAP
reduced by 90%, or
Total HAP reduced by 95% in a
biotreatment unit, or
Treatment in a RCRA-permitted
treatment device.
Wastewater from New Sources
For new sources, the owner/operator must:
Treat an affected SHAP wastewater
stream with greater than 110,000
ppmw SHAP (category D)
7-
19
-------
to remove 99% SHAP, or
use a RCRA-permitted (or
interim status) treatment
device, such as an
incinerator, boiler, or
underground injection.
Management of Residuals from
Wastewater Treatment
Wastewater residuals are defined as HAP-
containing liquids or solid materials
removed from a wastewater stream by a
waste management unit or treatment process
that does not destroy organics. Examples of
residuals include:
the organic layer and bottom residue
removed by a decanter or organic-
water separator, and
overheads from a steam stripper or
air stripper.
Materials not classified as residuals include:
silt, mud, or leaves,
bottoms from a steam stripper or air
stripper, and
sludges, ash, or other materials from
destructive treatment devices such as
biological treatment units and
incinerators.
There are several options for managing
residuals taken from the treatment of
affected wastewater:
recycle the residual back into the
production process or sell it to
another firm for recycling. Once the
residual is returned to a production
process, it is no longer subject to
regulation. OR
return the residual to the treatment
process. OR
treat the residual to reduce the total
combined mass flow rate of SHAP
and/or PSHAP by 99 percent or
more. (Use the performance tests in
63.1257(e)(2)(iii)(C) -
noncombustion, nonbiological
treatment process - or (D) -
combustion treatment process - to
demonstrate compliance.) OR
treat the residual in a RCRA-
regulated unit (hazardous waste
incinerator or underground injection
well.
In addition, tanks, surface impoundments,
containers, individual drain systems, and
oil/water separators used for the storage or
management of residuals must meet the
same design and operating requirements that
apply to these units when used for treatment
of affected wastewater (63.1256(b) - (f)).
What are the Standards for Air
Emissions Control?
7.4.3 Emissions Control Standards
Standards for control of air emissions vented
during the treatment process and from other
waste management units with covers and
closed vent systems are specified for air
pollution control devices (APCD) as either:
1) equipment specifications - for combustion
devices in terms of residence time and
temperature specifications.
or
2) APCD performance levels - in the form of
7-20
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Removal Efficiencies (RE) or APCD outlet
HAP concentrations.
A summary of the standards is shown in
Figure 7-4. Basically, there is a choice of 5
control standards as follows:
Combustion device achieving 95%
RE HAP, 20 ppmv outlet TOC @3%
02, or provide 0.5 sec residence time
at 760 deg C,
longer being used to treat affected
wastewater or residuals, OR
if additional time is necessary due to
the unavailability of parts, due to
circumstances beyond the control of
the owner/operator. Repair must be
done as soon as practical, In this
case, the reasons for delaying the
repair must be documented.
Vapor recovery system achieving
95% RE HAP or 20 ppmv outlet
TOC,
Flare meeting requirements of
§63.11(b),
Scrubber or other APCD achieving
95% RE HAP or 20 ppmv TOC.
NOTE: The APCD outlet
standard of 20 ppmv TOC is not
' available for APCDs controlling
vent streams from wastewater
surface impoundments or containers.
With regard to repairs to air pollution
control devices, if gaps, cracks, tears, or
holes are observed in the ductwork, piping,
or connection to covers and control devices
during an inspection, the owner/operator
must make an attempt within 5 calendar
days to fix the problem. Repair can be
delayed only if:
the repair cannot be done without a
shutdown or if the emissions
resulting from immediate repair
would be greater than those
anticipated to result from delaying
the repair. The equipment must be
repaired by the end of the next
shutdown, OR
the equipment is emptied or is no
7-21
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APCD shall be
designed and operated
according to one of the
technologies listed
befow
Vapor recovery system
(i.e., carbon adsorber,
condenser, etc) shall
reduce organic HAP
by 95% or TOO1 to
less than 20 ppmv
./!:!_»Illi.
Flare shall
meet 83.11(b)
requirements
Combustion device
shall comply with one
of the following
standards
A scrubber shall
reduce by chemical
destruction organic
HAP by 95% or TOC1
to 20 ppmv
MBMm
Any other APCD
shall reduce organic
HAP by 95% or TOC1
to 20 ppmv
Reduce
organic HAP
by 95%
Achieve outlet TOC
concentration of 20
ppmv @ 3% Og
Provide residence
time of 0.5 sec and
min. temp of 760°C
These non-combustion
TOC options cannot be
used for wastewater
surface impoundments
or containers.
Is the APCD
controlling a vent
stream with >20 ppmv
halogenated
compounds?
Yes
NO
125
Control hydrogen
halides or halogens to
95% or to 20 ppmv
before or after the
combustion device
Is APCD
a boiler
or process heater?
Yes
Introduce
vent gas into
flame zone
(U:
No
Demonstrate
compliance per
63.1257
Figure 7-4. Wastewater APCD Requirements in §63.1256(h)
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Table 7-7. WASTEWATER TREATMENT STANDARDS
Treatment
Options
Used
To
Treat
Source Type
Limitations
Citations
treat to < 50
ppmw
PSHAP
new and existing
(categories A, B,
and C)
- no biotreatment or dilution
- not available for designated streams
,1256(g)(8)(i)
.1256(a)(l)(ii)
99% total mass
removal/
destruction of
HAP
PSHAP
new and existing
(categories A, B,
and C)
,1256(g)(8)(ii)
SHAP
new (category
D)
- only required when SHAP
concentration is 110,000 ppmw and the
total PSHAP and SHAP load in
wastewater from the PMPU is >
lMg/yr
,1256(g)(12)
treat to <520
ppmw
SHAP
new and existing
(categories B
and C)
- no biotreatment or dilution
- not available for designated streams
,1256(g)(9)(i)
.1256(a)(l)(ii)
90% total mass
removal/
destruction of
HAP
SHAP
new and existing
(categories B
and C)
,1256(g)(9)(ii)
enhanced
biological
treatment
SHAP
new and existing
(categories A, B,
and C)
- system must meet the definition of
enhanced biological treatment
- may only be used for affected
wastewater with
< 50 ppmw PSHAP, or wastewater that
has been treated to less than 50 ppmw
PSHAP or to 99% reduction of
PSHAP
- not available for designated streams
,1256(g)(10)
.1256(a)(l)(ii)
95% mass
removal/
destruction of
total HAP with
biological
treatment unit
Total
PSHAP
and
SHAP
new and existing
(categories A, B,
and C)
- biological treatment is required
- all wastewater streams (as defined in
63.1252) entering the system must
achieve 95% HAP removal, except
wastewater already treated in
compliance with another treatment
option
- all wastewater streams (as defined in
63.1252) entering the system must be
managed in wastewater management
units (sewers, etc.) in compliance with
the MACT
1256(g)(ll)
7-23
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Treatment
Options
Used
To
Treat
Source Type
Limitations
Citations
RCRA pcrmillcd
or interim status
treatment, device
PSHAP
and/or
SHAP
new and existing
(categories A, B,
C,and D)
- systems include heaters, incinerators,
boilers, industrial furnaces, and
underground injection
,1256(g)(13)
Offsite Treatment or Onsite Treatment by
Someone Other Than Owner/Operator
The owner/operator may elect to transfer
affected wastewater (or a residual removed
from such wastewater) to an offsite
treatment operation or to an on-site
treatment operation being run by someone
else.
Owner/
Operator:
Responsibilities include...
of the
Affected
Source
ensuring that all waste management units on-site handling affected streams are in
compliance with wastewater management requirements (e.g., all drain systems and
tanks containing affected streams must comply with §63.1256(b)-(f)).
submitting a notice with each shipment stating that the wastewater or residual from the
wastewater contains PSHAP and/or SHAP that must be treated in compliance with the
regulations. If the transfer is continuous or ongoing, submit the notice with the first
shipment and whenever there is a change in the treatment required. Keep a record of
the notice in accordance with §63.1259(g).
7-24
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Owner/
Operator:
Responsibilities include...
of a
Treatment
System
Receiving
the
Wastewater
Submitting to EPA. prior to receiving any affected wastewater, a written certification
stating that any affected wastewater or affected wastewater residual will be treated in
compliance with:
S §63.1256(b)-(i) (requirements for tanks, surface impoundments, containers,
individual drain systems, oil water separators, plus other performance
standards for treatment), or
S Subpart D (if alternative emissions limitations have been approved), or
S §63.6(g) (use of an alternative nonopacity emission standard), or
S If the affected wastewater streams or residuals contain less than 50 ppmw
partially soluble HAP, then the person receiving them for treatment can:
i. comply with (g)(10) (enhanced biotreatment for SHAP) and cover
the waste management units up to the activated sludge unit, or
ii. comply with (g)(l l)(i) and (ii) (95 percent reduction in a biological
treatment unit), and (h) (emissions control device standards) and
cover the waste management units up to the activated sludge unit, or
iii. comply with (g)(10) (enhanced biotreatment for SHAP) provided
that the affected source owner/operator demonstrates that less than
5 percent of the total SHAP is emitted from waste management
units up to the activated sludge unit, or
iv. comply with (g)(l l)(i) and (ii), (95 percent reduction in a biological
treatment unit), and (h) (emissions control device standards),
provided that the affected source owner/operator demonstrates that
less than 5 percent of the total SHAP is emitted from waste
management units up to the activated sludge unit.
Securing the signature of the responsible official on the certification, and providing
the name and address of the certifying entity to the EPA Regional office.
NOTE ON REVOKING CERTIFICATION: A written statement must be sent to both EPA
and the owner/operator of the affected wastewater stating that the transferee is no longer
accepting responsibility for treatment of the affected wastewater. The transferee must give at
least 90 days notice. When the 90-day period is up, the owner/operator may not transfer
affected wastewater or residuals to the treatment operation.
What are the standards for wastewater treatment using multiple treatment
processes in series ?
The mass removal destruction efficiency requirements are the same.
However, efficiency calculation techniques differ for different treatment
configurations. If 11 aste 11 ater is conveyed by hard piping then mass re mo val
destruction efficiency is determined across the combination of treatment
processes. If 11'aste11 ater is not conveyed by hard piping then efficiency is
determined across each treatment process with total efficiency equal to the
sum of efficiencies from each component process.
Q and A
a
A.
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What is the Pollution Prevention
Option?
In lieu of the wastewater standards discussed
above, an owner or operator (O/O) can
choose to meet pollution prevention (P2)
standards. The P2 requirements are either:
reduce the production-indexed HAP
consumption factor (kg HAP
consumed/kg product produced) by
75% from a specified baseline
average established no earlier than
1987, or
reduce the production-indexed HAP
consumption factor by at least 50%
from a specified baseline average
established no earlier than 1987
(Monitoring Requirements). A complete
description of the required monitoring
procedures can be found in -4 Chapter 9 -
Monitoring. The following paragraph
presents a brief introduction to the initial
compliance demonstration requirements for
wastewater. A more complete description of
the requirements can be found in -4
Chapter 8 - Compliance Demonstration
and Testing Procedures.
AND reduce total PMPU HAP
emissions divided by the annual
production rate (kg HAP emitted per
year/kg produced per year) to a value
greater than 25%_of the average
production-indexed consumption
factor (i.e., achieve 50% reduction by
using pollution prevention and
achieve additional 25% by using
standard control devices). For more
information on the pollution
prevention option, see -4 Chapter
10- Pollution Prevention
Alternative.
7.5 Compliance Demonstration
Compliance demonstration procedures for
wastewater standards are listed in
§63.1257(e) - Test Methods and Compliance
Procedures - Compliance with Wastewater
Provisions. This section lists requirements
for demonstrating initial compliance.
Procedures for demonstrating on-going or
continual compliance are listed in §63.1258
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Q and A
Q. How do I demonstrate compliance for:
1) wastewater with multiple phases
2) treatment residuals ?
A. Wastes/reams with free phase HAP cannot be sent to individual drain systems,
stored in wastewater tanks or surface impoundments, or sent to treatment
units. The free phase HAP can only be discharged to a R( 7IA treatment unit,
per 63.1256(a)(3). Tor wastewater treatment residuals, the () () must either:
1. recycle the residua! back to the production process, or sell the material
for the purpose of recycling
2. return the residua! back to the treatment process,
3. destroy combined PSHAP/SHAP by at least 99%, or
4. treat the residual in a R( 'RA unit per §63.I256(g)(I3).
To demonstrate compliance with option I or 2, the ()/() must document
process configuration. To demonstrate compliance with option 3, the ()/()
should use compliance demonstration technique (" or 1) as discussed in
Appendix WWT.
The initial compliance demonstration
procedures as listed in §63.1257(e) are
basically separated into 3 parts:
Determination of wastewater HAP
concentration and load as it pertains
to wastewater applicability criteria
(i.e. annual concentration and annual
load),
Design Evaluation and Performance
Test procedures for demonstrating
compliance with air emissions
control (i.e., APCD) requirements,
and
Design Evaluation and Performance
Test procedures for demonstrating
compliance with wastewater
treatment standards.
Compliance with the vapor suppression
standards is done primarily through the
reporting provisions of the rule, which
require that the owner or operator document
the results of Inspection and Monitoring
procedures that are followed for wastewater
management units.
The reader is referred to Chapters 8 and 9
for more complete details on compliance
demonstrations and monitoring
requirements.
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