Do you have a hazardous waste tank at your facility? Do you comply with the applicable RCRA requirements? Hazardous waste tanks must meet four subparts of the RCRA rule: J, AA, BB, and CC. It is important to understand that the requirements of these subparts are separate from the leak detection rules under the USEPA NESHAP air program, and both must be assessed.
Baron recently participated at a joint DEP/EPA Region 2 New Jersey site inspection that focused on these RCRA Subparts. Below is a brief review of the requirements.
Subpart J – 40 CFR 264.190-200
Subpart J requires lined or sealed secondary containment systems since standard concrete or asphalt are considered porous. Tank testing is required prior to placing a tank into service. A tank’s design must be assessed by a licensed Professional Engineer (P.E.) and this assessment must be kept on file for the life of the tank.
A daily inspection of the tank system must be completed and recorded at least once per operating day. The inspection must include all monitoring and leak detection equipment that are part of the tank system to ensure operation is according to its design. Any tank system that contains ignitable or reactive wastes must be located more than fifty (50) feet from any property line of the facility. Additionally, Subpart J includes air emission standards and requires compliance with Subparts AA, BB and CC of the RCRA standard.
Subpart AA – 40 CFR 265.1030-1035
Subpart AA covers air emissions from process vents associated with a hazardous waste tank system if the system is being used in distillation, fractionation, thin-film evaporation, solvent extraction or air or steam stripping operations. Process vents must meet specific emission limits on a per hour and per year basis or operate a control device that reduces total organic emissions by 95%. These vents will also require regular monitoring using EPA’s Reference Method 21. Specific recordkeeping is also required for the process vents covered by this subpart.
Subpart BB – 40 CFR 265.1050-1064
Subpart BB regulates air emissions from pumps, compressors, pressure relief devices, sampling connections, open-ended valves and lines, valves and flanges. These items are frequently referred to as ancillary equipment. All covered equipment must be identified so it can easily be distinguished from any other facility equipment. All pumps and valves must be monitored on a monthly basis using Reference Method 21 unless they have been certified for no detectable emissions. Pressure relief devices must be certified for no detectable emissions and must return to this condition within five (5) days of any pressure release. Certain equipment can be exempted from the monitoring requirements of the standard if it can be shown that the equipment is exposed to hazardous waste for less than 300 hours per year. This exemption requires purging of equipment with an inert gas or liquid each time waste is moved through the equipment.
Subpart BB requires equipment and inspection logs to be entered into the facility operating record and maintained for three to five years. A record must be created for each piece of equipment covered by the standard. Compliance documentation must include detailed design or performance test results. Leak logs are required for any leak(s) that is discovered as a result of either weekly visual or monthly quantitative monitoring. Inspection logs are also required.
Subpart CC – 40 CFR 265.1080-1090
Subpart CC covers air emissions from hazardous waste in tanks, surface impoundments or containers. For the waste determination, facilities must determine the average volatile organic content at the point of generation. The subpart divides all regulated equipment into Level 1 and Level 2 controls based upon size, construction and vapor pressure of the stored materials. Level 1 controls can be satisfied by a fixed roof tank with a continuous barrier over the entire surface of the hazardous waste within the tank. Level 2 requires the addition of a control device. Most generators should find that their waste will fall within the Level 1 control requirements for typical
hazardous waste operations.
An inspection and monitoring plan must be established for each piece of covered equipment. Recordkeeping for information related to equipment, inspections, monitoring and vapor pressure of the tank contents is required and must be maintained for three to five years at a minimum.
Many regulated sites are aware of the requirements of Subpart J of the RCRA standard, however Subparts AA, BB and CC are less well known. If your facility has a hazardous waste tank, click on any of the email links on our "Meet Our Teams" page, to email us for an assessment of the system, to ensure compliance with all four Subparts, or to seek alternate methods of managing your waste program.