In June 2020, the U.S. EPA announced that they, and authorized states, will be focusing hazardous waste inspections on air emission standards. EPA's explanation for this enforcement initiative is that they continue to find significant noncompliance in this area - especially related to pressure relief valves, tanks closure devices, monitoring, and recordkeeping. The requirements only apply to large quantity generators and treatment, storage and disposal facilities (TSDFs) producing organic hazardous waste air emissions from certain activities.
In addition, since the agency recently reversed the “once in, always in” policy, air emission sources that were previously exempted from the hazardous waste air emission standards may now become subject to the requirements. Penalties associated with noncompliance can be significant (e.g., an automotive parts manufacturer).
There are steps to take to prepare for these planned inspections including:
- Implementing a customized facility-wide hazardous waste leak detection and repair program.
- Conducting a self-audit under EPA and state programs to assess compliance and avoid penalties.
Contact your local Trinity office for assistance with these and other compliance strategies for your environmental program.