WELCOME: EPA PUBLIC MEETING EPA HSWA PERMIT CLEAN HARBORS OF BRAINTREE

Hazardous Waste Facility Information There are 27 facilities in New England that are permitted hazardous waste facilities, like Clean Harbors, that treat and store hazardous waste. There are a total of 11 permitted hazardous waste facilities in Massachusetts. The EPA HSWA permit for Clean Harbors is the first one to be issued in New England. The other 10 hazardous waste facilities in MA will be assessed for applicability.

EPA HSWA Regulations The organic air emission regulations were promulgated under the Hazardous and Solid Waste Amendments (HSWA) of 1984. These Amendments allow EPA to implement hazardous waste requirements in a State that is not authorized for them. The air emission standards are self implementing at the federal level, that is, the facility must meet the standards until a permit is issued.

Why Organic Air Emission Standards Were Established Volatile organics can have adverse effects on human health and the environment. Volatile organic compounds (VOCs) can produce ozone. Dry cleaners are an example of a facility that has the potential to emit VOCs.

The EPA Permit for Clean Harbors (CH) The organic air emission standards are self-implementing and have been applicable to the facility since the late 1990’s. The purpose of these standards is to reduce organic air emissions from the handling of hazardous wastes containing volatile organic compounds. The EPA permit takes over 70 pages of regulations (requirements that are already applicable to the facility) and puts them in a clear and enforceable document (the permit).

The EPA Permit for CH (cont.) In general, to meet the air emission requirements for the management of volatile organic waste the permit requires that the containers (i.e. 55 gallon drums) at the facility: Be DOT approved, and Remain covered, except when adding or removing waste.

Container Storage at Clean Harbors

Container Storage at Clean Harbors

The EPA Permit for CH (cont.) The permit also requires that the tanks at the facility handling volatile organic wastes (the steel tanks, identified as the “A” tanks in the permit) are: Covered with a fixed roof, and Operated in conjunction with the carbon adsorption system (an air emission control device).

Steel Tanks at Clean Harbors

Close-up: Top of the Tanks

Carbon Adsorption Units at CH

The EPA Permit for CH (cont.) The EPA permit was drafted based upon: the requirements found in the state license which became effective on September 21, 2012; the response by Clean Harbors to EPA’s request for information letter submitted on December 8, 2010; and a site visit by EPA and MassDEP on March 13, 2012.

State License Requirements The state license is the primary document regulating the hazardous waste management activities at the facility. It includes tank and container management requirements, the contingency plan, the inspection plan, the waste analysis plan, and many of the other significant requirements applicable to the facility.

Federal and State Requirements The EPA permit covers those requirements for which the MassDEP is not authorized to implement under their hazardous waste program. These requirements include the organic air emission standards and some waste codes.

Waste Codes The waste codes in the HSWA permit include those for which MassDEP is not currently authorized. These particular waste codes are included in revised regulations that MassDEP will be adopting soon. The additional waste codes must be managed in the same manner as all other wastes handled at Clean Harbors under the state license.

Connection between the State License and the EPA Permit The EPA permit can be considered an attachment to the state license. There is nothing in the EPA permit that changes or overrides the requirements in the state license.

Public Participation EPA issued the public notice for the draft permit on January 23, 2014 in the Braintree Forum newspaper. EPA also notified by radio on February 20, 2014. The 45-day comment period ends on March 10, 2014.

Permit Information The public notice, permit & fact sheet can be found on EPA’s website at:    http://www.epa.gov/region1/topics/cleanup/rcra.html Copies of the EPA permit are also available at the Thayer Public Library and the EPA Library in our Boston Office.

RCRA Waste Management Section THANK YOU Sharon Leitch RCRA Waste Management Section USEPA Region 1 617-918-1647