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Emissions from Hazardous Waste Tanks, Surface Impoundments, and Containers
Background

Organic air emissions from hazardous waste management activities cause air quality problems, such as ambient ozone formation, and also contribute to the depletion of stratospheric ozone. Human health can also be impacted as a result of inhaling air toxics.

In order to reduce organic emissions from hazardous waste management activities and their associated harmful effects, air emission control requirements have been established under the Resource Conservation and Recovery Act (RCRA). These requirements apply to owners and operators of hazardous waste treatment, storage, and disposal facilities (TSDFs) and to certain hazardous waste generators accumulating waste on-site in tanks and containers.

The standards are designed to help prevent the significant deterioration of air quality in areas that have attained the national ambient air quality standards (NAAQS) for ozone (i.e., "attainment areas") and are expected to contribute to further progress in attaining the NAAQS for ozone in nonattainment areas. The standards are also expected to reduce cancer risks to the public by reducing overall exposure to toxic air emissions.

Does the Rule Apply to Your Community?

Yes, if you are an owner or operator of a hazardous waste TSDF or a hazardous waste generator, and you accumulate/store hazardous waste on-site in a tank, surface impoundment, or container on or after June 5, 1995. Both permitted TSDFs and interim-status TSDFs are subject to the air emissions control standards. (An interim-status facility is a facility qualified to operate without a RCRA permit until a permit has been issued or denied.)

Owners and operators are subject to the air emission control requirements if all of the hazardous waste being placed in a tank, surface impoundment, or container has an average volatile organic concentration more than 100 parts per million by weight (ppmw) at the point of origin of that waste. The point of origin is defined as the point where the owner or operator of a TSDF takes possession of a waste, or where, in the case of a hazardous waste generator, the point where the hazardous waste is produced.

Actions Your Community Should Be Taking

If you place hazardous waste in a tank, surface impoundment or container you must manage it in accordance with the requirements under RCRA. These requirements include installing and operating air emission controls. Controls are required on every affected tank, surface impoundment and container (affected units) - from the point of origin of the waste through the point where the organics in the waste are either removed or destroyed.

Monitoring of the control devices is required. Monitoring is used to determine whether the control devices are operating correctly or malfunctioning. Visual inspections are also required for certain emissions control equipment items, like tank covers. Inspections are required semiannually to ensure that the control equipment is properly maintained and operated. Tanks, surface impoundments, and containers that are permitted under RCRA are also subject to reporting requirements. Reporting to EPA is generally required twice a year. Reports must describe the operation of any control device that was out of compliance with the regulations for a continuous period of 24 hours or longer.

Records on waste determinations, inspections, monitoring, and any control device exceedances must also be maintained in a facility operating record. If a unit is exempted from the air emission control requirements, you also need to keep records to indicate why the exemption was granted.

Timetable

Compliance with the air emissions standards is required by June 6, 1995. If, however, the required air emissions control equipment cannot be operational by June 6, 1995, an implementation schedule for installing the equipment must be developed by June 5, 1995. In this case, air emission controls must be operational by December 8, 1997.

Additional Information

The air emission control standards can be found in the Code of Federal Regulations (CFR) at 40 CFR subpart CC in both parts 264 (applicable to permitted TSDFs) and 265 (applicable to interim-status TSDFs).

For additional information, contact EPA's RCRA Hotline.
Telephone: 800/424-9346.

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