Enhancing Compliance with RCRA Air Emission Standards at Hazardous Waste Facilities

When not properly controlled, hazardous waste management at large quantity generators (LQGs) and treatment, storage, and disposal facilities (TSDFs) can release volatile organic compounds from process vents, equipment, tanks, containers, and/or surface impoundments. These emissions can contribute significantly to ambient ozone formation, and they can expose workers, and sometimes nearby communities, to harmful pollutants that can increase cancer, respiratory illness, and other health risks. These emissions have been regulated under Resource Conservation and Recovery Act (RCRA) since the 1990s. However, during the decades since then, the U.S. Environmental Protection Agency (EPA) has identified numerous violations and compliance issues at LQGs and TSDFs due to failure to fully or correctly implement the required controls. EPA tasked ERG with providing support for an initiative to identify and reduce compliance issues at hazardous waste management and disposal facilities.

For over eight years, ERG has supported EPA in conducting dozens of inspections at RCRA facilities for compliance with air emission requirements. These inspections have covered both TSDFs and LQGs managing millions of tons of organic hazardous waste. ERG has led and supported process-based inspections and waste sampling to determine which process vents, equipment, tanks, containers, or surface impoundments were subject to RCRA air regulations, and to ensure that all regulated equipment was properly included in each facility’s air program. ERG’s support has included real-time use of photoionization detectors and flame ionization detectors to perform Method 21 leak monitoring, as well as the use of forward-looking infrared (FLIR) cameras to visually identify releases. In addition, ERG has thoroughly reviewed facility records to verify compliance with equipment identification, tagging, leak detection monitoring, instrument calibration, leak repair timeframes, and other requirements. ERG’s work to identify specific areas of non-compliance has helped provide a foundation for actions to resolve non-compliance issues, leading to reduced harmful emissions and cleaner air in communities near RCRA facilities.