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 requirement to control organic air emissions from certain RCRA hazardous waste management units (HWMUs), EPA promulgated a series of regulations known as the RCRA Organic Air Emission Standards (found in Title 40 of the Code of the Federal Regulations (CFR), parts 264 and 265, subparts AA, BB and CC). 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 and surface impoundments. 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, which were estimated to exceed two million tons per year at the time the standards were issued. These air emissions included toxic organic compounds and ozone precursors. Cancer, other adverse health effects and environmental effects such as crop damage may result from exposure to these organic emissions.
Definitions
Average volatile organic concentration or average VO concentration –the mass-weighted average volatile organic concentration of a hazardous waste as determined in accordance with the requirements of section 265.1084 of this subpart (40 CFR section 265.1081).
Closed-vent system – a system that is not open to the atmosphere and that is composed of piping, connections, and, if necessary, flow-inducing devices that transport gas or vapor from a piece or pieces of equipment to a control device (40 CFR section 264.1031).
Control device – an enclosed combustion device, vapor recovery system, or flare. Any device the primary function of which is the recovery or capture of solvents or other organics for use, reuse, or sale (e.g., a primary condenser on a solvent recovery unit) is not a control device (40 CFR section 264.1031)).
Enclosure – a structure that surrounds a tank or container, captures organic vapors emitted from the tank or container, and vents the captured vapors through a closed-vent system to a control device (40 CFR section 265.1081).
In light material service – means the container is used to manage a material for which both of the following conditions apply: the vapor pressure of one or more of the organic constituents in the material is greater than 0.3 kilopascals (kPa) at 20 °C; and the total concentration of the pure organic constituents having a vapor pressure greater than 0.3 kPa at 20 °C is equal to or greater than 20 percent by weight (40 CFR section 265.1081).
Maximum organic vapor pressure – the sum of the individual organic constituent partial pressures exerted by the material contained in a tank, at the maximum vapor pressure-causing conditions (i.e., temperature, agitation, pH effects of combining wastes, etc.) reasonably expected to occur in the tank. For the purpose of this subpart, maximum organic vapor pressure is determined using the procedures specified in 40 CFR part 264 / section 265.1084(c) (40 CFR section 265.1081).
No detectable organic emissions – means no escape of organics to the atmosphere as determined using procedures described in 40 CFR section 265.1084(d) (40 CFR section 265.1081).
Point of waste origination – means as follows: (1) when the facility owner or operator is the generator of the hazardous waste, the point of waste origination means the point where a solid waste produced by a system, process, or waste management unit is determined to be a hazardous waste as defined in 40 CFR part 261; (2) when the facility owner or operator is not the generator of the hazardous waste, point of waste origination means the point where the owner or operator accepts delivery or takes possession of the hazardous waste (40 CFR section 265.1081).
Point of waste treatment – means the point where a hazardous waste that is treated in accordance with 40 CFR section 265.1083(c)(2) exits the treatment process. Any waste determination shall be made before the waste is conveyed, handled, or otherwise managed in a manner that allows the waste to volatilize to the atmosphere (40 CFR section 265.1081).
Volatile organic concentration or VO concentration – the fraction by weight of the volatile organic compounds contained in a hazardous waste expressed in terms of parts per million (ppmw) as determined by direct measurement or by knowledge of the waste in accordance with the requirements of 40 CFR section 265.1084. For the purpose of determining the VO concentration of a hazardous waste, organic compounds with a Henry’s law constant value of at least 0.1 mole-fraction-in-the-gas-phase/mole-fraction-in the liquid phase (0.1 Y/X) (which can also be expressed as 1.8x10-6 atmospheres/gram-mole/m3) at 25 degrees Celsius must be included. Appendix VI of this subpart presents a list of compounds known to have a Henry’s law constant value less than the cutoff level (40 CFR section 265.1081).
Waste determination – means performing all applicable procedures in accordance with the requirements of 40 CFR section 265.1084 to determine whether a hazardous waste meets standards specified in this subpart. Examples of a waste determination include performing the procedures in accordance with the requirements of 40 CFR section 265.1084 to determine: the average VO concentration of a hazardous waste at the point of waste origination; the average VO concentration of a hazardous waste at the point of waste treatment and comparing the results to the exit concentration limit specified for the process used to treat the hazardous waste; the organic reduction efficiency and the organic biodegradation efficiency for a biological process used to treat a hazardous waste and comparing the results to the applicable standards; or the maximum volatile organic vapor pressure for a hazardous waste in a tank and comparing the results to the applicable standards. (40 CFR section 265.1081).
Waste stabilization process – means any physical or chemical process used to either reduce the mobility of hazardous constituents in a hazardous waste or eliminate free liquids as determined by Test Method 9095B (Paint Filter Liquids Test) in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication No. SW-846, as incorporated by reference in 40 CFR section 260.11. A waste stabilization process involves mixing the hazardous waste with binders or other materials and curing the resulting hazardous waste and binder mixture. Other synonymous terms used to refer to this process are “waste fixation” or “waste solidification.” This does not include the adding of absorbent materials to the surface of a waste, without mixing, agitation, or subsequent curing, to absorb free liquid. (40 CFR section 265.1081).
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 |
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(To view the document, click on the above link, type "EPA530-K-02-003I" into the "Search Publications" box and click on "Search"). |
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. |
| Reduction of Hazardous Waste Air Emissions Advisory | 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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Section 3 of this 2000 document describes the interrelationship of the OSWRO NESHAP with RCRA air standards. |
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Technical Guidance Document for RCRA Air Emission Standards for Process Vents and Equipment Leaks (To view the document, click on the above link, type "450389021" into the "Search Publications" box and click on "Search"). |
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. |
| 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. |
| This document describes the requirements of the Resource Conservation and Recovery Act (RCRA) organic air emission standards contained in 40 CFR parts 264/265, subpart CC for hazardous waste treatment, storage, and disposal facilities (TSDFs) and generators of hazardous waste. |