Overview of Subpart AA, BB, CC Standards
Statutory Authority
Regulatory History
Purpose of Subpart AA, BB, CC Standards
Other EPA Air Rules
RCRA Air Rules General Requirements
Applicability Considerations
Waste Determiniation Considerations
Compliance Options Overview
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Overview of Subparts AA, BB, CC Standards
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Section 3004(n) of RCRA requires the U.S. Environmental
Protection Agency (EPA) to develop standards to control air
emissions from hazardous waste treatment, storage and disposal
facilities (TSDF) as may be necessary to protect human health
and the environment. This requirement reiterates the general
requirement in RCRA section 3004(a) and section 3002(a)(3)
to develop standards to control hazardous waste management
activities as may be necessary to protect human health and the
environment. The Agency has issued a series of regulations to
implement the section 3004(n) mandate; these regulations
control air emissions from certain process vents and equipment
leaks (Part 264 and Part 265, Subpart AA and BB), and
emissions from certain tanks, containers, surface impoundments
and miscellaneous units(the Subpart CC standards). |
Statutory Authority
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Statutory Authority |
Description: Section 3004(n) of RCRA requires the U.S. Environmental
Protection Agency (EPA) to develop standards to control air
emissions from hazardous waste treatment, storage and disposal
facilities (TSDF) as may be necessary to protect human health
and the environment. |
Regulatory History
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Regulatory History |
Description: The EPA issued the Phase I air regulations on June 21, 1990
[55 25454]. Phase 1 air rules
regulated air emissions from certain process vents and
equipment leaks as described in 40 CFR Parts 264 and
265, Subparts AA and BB. |
Purpose of Subparts AA, BB, CC Standards
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Purpose of the Subparts AA, BB and CC Standards |
Description: The RCRA air rules have been developed to reduce organic air
emissions and their associated risk to human health and the
environment. Volatile organic compounds are involved in the
formation of ozone which has been shown to have harmful
effects on human health and adversely effect agricultural
production. Many volatile organic compounds may be
classified as air toxics which also are responsible for adverse
human health effects. Controlling releases of volatile organic
compounds to the environment will reduce these adverse
effects. |
Ozone |
Description: Ozone is just one of six major air pollutants that are regulated
by EPA but it is by far the most complex and the most difficult
to regulate. Ozone is different from stratospheric or high level
ozone in that it is detrimental to human health and welfare. |
Air Toxics |
Description: Air toxics are airborne pollutants that can cause cancer or
other human health effects. The total nationwide cancer incident
due to outdoor concentration of air toxics in the United States
has been estimated to range from approximately 1700 to 2700
excess cancer cases per year. The Clean Air Act amendments
of 1990 identified 189 compounds as air toxics. |
Other EPA Air Rules
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Other EPA Air Rules |
Description: Because the RCRA air emissions standards promulgated in
Subparts AA, BB and CC apply to some of the same emissions
sources that are subject to regulations established pursuant to
the Clean Air Act (CAA), the potential exists for some overlap
between the RCRA air rules and the CAA rules. |
RCRA Air Rules General Requirements
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RCRA Air Rules General Requirements |
Description: Examples of MACT standards that regulate sources that could
be subject to the air rules promulgated under RCRA include the
NESHAP for Organic Hazardous Air Pollutants from the
Synthetic Organic Chemical Manufacturing Industry (40 CFR
Part 63, Subpart F), the NESHAP for Organic Hazardous Air
Pollutants from the SOCMI for Process Vents, Storage
Vessels, Transfer Operations, and Wastewater (40 CFR Part
63, Subpart G), the NESHAP for Organic Hazardous Air
Pollutants from Equipment Leaks (40 CFR Part 63, Subpart H)
and the NESHAP for Organic Hazardous Air Pollutants for
Certain Processes subject to the Negotiated Regulation for
Equipment Leaks (40 CFR Part 63, Subpart I). |
Applicability Considerations
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Applicability Considerations |
Description: Subparts AA, BB, and CC standards apply to owners and
operators of hazardous waste treatment, storage and disposal
facilities (TSDFs) that are subject to the permitting requirements
of 40 CFR 270 regardless of their permit status. |
Waste Determination Considerations
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Waste Determination Considerations |
Description: Appropriate knowledge of the concentration of organic
constituents in the hazardous waste that is managed at a facility
is essential to making Subparts AA, BB, and CC compliance
determinations. |
Compliance Options Overview
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Compliance Options Overview |
Description: Compliance with the RCRA air standards may be achieved by
three basic methods. |
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