RCRA Organic Air Emission Standards for TSDFs and Generators
Section 3004(n) of the Resource Conservation and Recovery Act (RCRA) requires the development of standards to monitor and control air emissions from hazardous waste treatment, storage and disposal facilities (TSDFs), as necessary, to protect human health and the environment. To implement this, EPA established the RCRA Organic Air Emission Standards under three subparts found in Title 40 of the Code of the Federal Regulations (CFR), Part 264 (permitted facilities) and Part 265 (interim status facilities).
These standards are applicable to hazardous waste TSDFs and certain large quantity generators (LQGs). They establish performance, design, operation, monitoring, recordkeeping, and maintenance requirements for certain hazardous waste management units (HWMUs) and associated equipment and air emission control devices. Specifically, Subpart AA controls air emissions from certain process vents, Subpart BB controls air emissions from specified equipment leaks, and Subpart CC controls air emissions from certain tanks, containers, surface impoundments, and miscellaneous units as applicable. The Subpart AA and BB Standards became effective on December 21, 1990. The Subpart CC Standards became effective on December 6, 1996.
Check out our Applicability and Requirements page for more detail and information on Subparts AA, BB, and CC of the RCRA Organic Air Emission Standards for TSDFs and Generators.
On this page:
Why are the RCRA Organic Air Emission Standards Important?
The standards were issued to reduce organic air emissions from hazardous waste management units, which were estimated to exceed two million tons per year at the time the standards were issued. These air emissions include toxic organic compounds and ozone precursors. These can result in exposure to onsite workers and impact nearby communities. Adverse health effects such as cancer, and environmental effects such as crop damage, may result from exposure to these organic emissions. Organic air emissions can also increase the risk of fire or explosion.
Frequent Questions
Are listed hazardous wastes that meet applicable LDR treatment standards subject to Subpart CC regulations?
Listed hazardous wastes that meet LDR treatment standards for the organics in the waste are not subject to Subpart CC regulations. Listed hazardous wastes with treatment standards that address only inorganic constituents may not benefit from this exclusion. However, listed hazardous waste containing both organic and inorganic constituents may be exempt from Subpart CC if it meets the LDR treatment standards for the organic constituents in that waste (62 FR 64635, 64643-4; December 8, 1997).
Can hazardous waste be managed in units when the control device for organic air emissions is not operating?
Subpart CC standards allow up to 240 hours per year for periods of planned routine maintenance of a control device (40 CFR 264.1087(c)(2)/265.1088(c)(2)). During this time, the hazardous waste may still be managed in the unit, even though the control device is not required to meet the performance requirements for emission reduction (61 FR 59931, 59948; November 25, 1996).
If an LQG or TSDF is subject to one of the RCRA air emissions standards in 40 CFR Parts 264 and 265, Subparts AA, BB, and CC that apply to certain process vents, equipment, tanks, surface impoundments, and containers, do the other two subparts apply?
If one of the Subpart AA, BB, or CC requirements apply to a particular activity, this does not mean that the others automatically apply as well. The standards of each subpart apply only when the substantive applicability provisions of the specific subpart are met (61 FR 59932, 59934; November 25, 1996). Specifically, Subpart AA applies to process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, and air or steam stripping operations that manage hazardous wastes with organic concentrations of at least 10 parts per million by weight (Sections 264.1030(b) and 265.1030(b)). Subpart BB applies to equipment, as defined in Section 264.1031, that contains or contacts hazardous wastes with organic concentrations of at least 10 percent by weight (Sections 264.1050(b) and 265.1050(b)). Subpart CC applies to facilities that manage hazardous waste in containers, tanks, or surface impoundments subject to either Subparts I, J, or K, respectively, of Parts 264 or 265 (Sections 264.1080(a) and 265.1080(a)). Each subpart has its own specific applicability criteria that an owner and operator must evaluate to determine if it is applicable to a particular activity, as the three subparts operate independently of one another.
Can visual inspections alone meet the leak detection requirements in Section 265.193 for hazardous waste tanks?
Because all secondary containment systems must be designed and operated to enable the owner/operator to readily discern a release from the tank system, daily visual inspection is acceptable for completely aboveground tanks to meet leak detection requirements. 40 CFR Section 264.193/265.193(f) require secondary containment for ancillary equipment in tank systems. Certain aboveground components of such equipment are exempt from the secondary containment requirements if they are visually inspected on a daily basis. Check your individual state requirements to be sure there are not added regulations.
Related material:
Monthly Call Center Report Question: August 1986 (RCRA Online 12701)
Monthly Call Center Report Question: March 1987 (RCRA Online 12868)
Monthly Call Center Report Question: May 1988 (RCRA Online 13173)
Resources
| Title | Description |
|---|---|
|
RCRA Organic Air Emission Standards for TSDFs and Large Quantity Generators |
Updated in 2022, the RCRA Organic Air Emission Standards for TSDFs and LQGs factsheet provides a high-level overview of the RCRA Air Emission Standards, including applicability and requirements, for hazardous waste treatment, storage, and disposal facilities (TSDFs) and large quantity generator (LQG) sites. |
|
Memorandum: Applicability of RCRA Organic Air Emission Standards to Equipment and/or Closure Devices |
This 2021 memorandum provides guidance to EPA and state permit writers and inspectors for determining whether certain equipment and/or closure devices located on covers of hazardous waste tanks, containers, and surface impoundments are subject to Subpart BB or Subpart CC of the Organic Air Emission Standards under the RCRA. By clarifying the applicable regulations for certain pieces of equipment and/or closure devices, EPA aims to provide a consistent federal interpretation of the RCRA Organic Air Emission Standards at hazardous waste large quantity generator (LQG) sites and TSDFs. |
| Implementing the RCRA/CAA Air Emission Controls Compliance Exemption/Election Provisions in Subparts AA, BB, and CC of 40 CFR Parts 264 and 265 | This 2019 document provides information for implementing the regulatory compliance exemption/election provisions found in 40 CFR Subparts AA, BB, CC and includes example permit language and checklists. This information is primarily for permit writers but may be helpful for permit applicants as well. |
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This 2018 document is an advisory for facilities that are affected by the air emissions requirements under RCRA. It highlights their responsibilities and recently observed compliance concerns. |
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| This 2001 document provides a regulatory overview of the RCRA organic air emissions standards, as they apply to hazardous waste facilities. It presents the history of the RCRA air emission standards, summarizes the requirements of each of the standards in Part 264/265, Subparts AA, BB and CC, and identifies the types of units subject to these requirements, as well as specific exemptions. | |
| Implementation Guidance for Off-site Waste and Recovery Operations (OSWRO) National Emissions Standards for Hazardous Air Emissions (NESHAP): Interrelationships with Other Related Air Rules |
Section 3 of this 2000 document describes the interrelationship of the OSWRO NESHAP with RCRA air standards. |
| This 1990 document provides technical guidance for permit writers and reviewers to implement the process vent and equipment leak organic air emission standards for hazardous waste treatment, storage and disposal facilities. |