Proposed Amendments to NESHAP for Off-Site Waste and Recovery Operations



On August 7, 2017, EPA proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Off-Site Waste and Recovery Operations (OSWRO), NESHAP Subpart DD. The proposal addresses the 2015 amendment additional monitoring requirements for pressure relief devices (PRDs) on containers required by the OSWRO NESHAP. EPA is proposing to remove the additional container PRD monitoring requirements from the 2015 amendments since releases from container PRDs are rare, the emission potential is low, and the continuous monitoring requirements would be difficult and costly.

EPA requested specific comments on the following questions for this update:

  • Should EPA impose more frequent inspections for filled or partially-filled OSWRO containers that remain onsite longer than 60 days?
  • Is there a need to have additional inspection requirements for all containers or only for larger containers?
  • Should EPA incorporate the Resource Conservation and Recovery Act (RCRA) Subpart BB and Subpart CC inspection requirements for RCRA permitted and interim status facilities?

EPA's public comment period ended September 21.