| Requirement & Regulatory Citation | Compliance Status | Compliance Comments |
| *AIR EMISSIONS - SUBPART AA CHECKLIST. | | |
| Background: If a facility (TSD or LQG) manages hazardous wastes greater than 10 ppmw of organics in a process vent used in distillation, fractionation, solvent extraction, thin-film evaporation, air or steam stripping, Subpart AA may apply. Subpart AA would not apply in a bona-fide closed loop scenario at LQGs and TSDs. To comply, the facility would need to determine if the process vent(s) releases greater than 3.0 lbs/hr and 3.1 tons/year of organic air emissions to the atmosphere. If it does not release that much then the facility is in compliance with Subpart AA. If its emissions are greater, then a control device is necessary to bring the facility into compliance. The control device may be a condenser, flare, carbon absorber, etc... that brings the equipment?s emission rate below the 3.0 lbs/hr and 3.1 tons/year, or reduces the organic emissions by 95%. | | |
| Objective: The Inspector should try to determine if Subpart AA applies at a particular facility and, if applicable, evaluate the facility?s efforts to achieve compliance. Has the facility calculated or measured the organic emissions from all vents and compared that with the emissions limit?. | | |
| 1. (a) Is this facility a Large Quantity Generator; Interim Status TSD; or Permitted TSD? If NO, do not continue with the RCRA Air Emissions checklists. | | |
| 2. (a) Does the facility have any hazardous waste management unit using the following processes: distillation, fractionation, thin-film evaporation, solvent extraction, air stripping and steam stripping? If NO, then proceed to the Subpart BB checklist. | | |
| If YES, list each process vent that is associated to one of the processes. | | |
| (b) Does the hazardous waste contain greater than 10 ppmw organics?. | | |
| (c) Are any of these processes exempt under the closed loop recycle exemption?. | | |
| If YES, please describe system. | | |
| (d) For those process vents with a yes answer to 2(b) describe the waste(s), unit(s) and processes. | | |
| (e) Identify those process vents with a no answer to 2 (c), and describe the information/ documentation used to make the determination (collect this information and submit to EPA). | | |
| 3(a) Is the total hourly emission rate of the affected process vents greater than 3 lb/hr?; and . | | |
| (b) Is the facility-wide yearly emission rate greater than 3.1 tons/yr?. | | |
| (c) If the answer to 3(a) or 3(b) is no, describe the calculations done by the company to support this determination (Provide copies of the calculations and associated information and submit it to EPA). | | |
| 4.(a) If the answer to 3.(a) or (b) is Yes, did the facility install control devices to reduce the emissions? (ALL TSDS MUST HAVE THE CONTROL DEVICES IN PLACE). | | |
| (b) Do the calculations/analysis seem reasonable? (Are they current? Are facility operating hours (e.g., 8 or 24 hours/day) correct? Have worst case scenarios been considered?). | | |
| (c) If the control devices are not in place, is there an implementation schedule in the facility?s operating record? (APPLICABLE TO LQGS UNTIL JUNE 1999). | | |
| If NO, explain: . | | |
| 5.(a) Are control devices inspected and/or monitored at least once each operating day to ensure proper operation?. | | |
| (b) Is there any indication of a problem with the operation of the control devices?. | | |
| (c) In case of problems, were corrective measures implemented immediately?. | | |
| If NO, explain: . | | |
| IF THE FACILITY IS SUBJECT TO THE SUBPART AA RULE AND IS USING A CONTROL DEVICE AND YOU ARE UNSURE OF THE COMPLIANCE STATUS, COLLECT THE DESIGN AND MONITORING DATA AND FORWARD TO THE EPA OFFICE FOR REVIEW. | | |
