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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

 

Overview of Subparts AA, BB, CC Standards
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
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
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
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
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
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
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
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
Compliance Options Overview
Description: Compliance with the RCRA air standards may be achieved by three basic methods.