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Subpart BB Standards
Special Definitions
Inspection and Monitoring Requirements
Alternative Standards for Valves in Gas/Vapor or Light Liquid Service: 2% Allowed to Leak
Alternative Standards for Valves in Gas/Vapor or Light Liquid Service: Skip Period
Waste Determination
Recordkeeping Requirements
Reporting Requirements
Implementation Issues Associated with Subpart BB
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Subpart BB Standards
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RCRA Section 1006(b) requires that RCRA standards be
consistent but not duplicative of Clean Air Act standards.
Equipment operated with air emission controls in accordance
with Clean Air Act requirements under
40 CFR Parts 60,
61,
63, are exempt from Subpart BB requirements. Subpart BB standards apply to
equipment that contains or contacts hazardous waste with
organic concentrations of at least 10 percent by weight. There
are specific monitoring and reporting requirements based on the
type of equipment. However, applicable equipment that
contains or contacts hazardous waste for less than 300 hours
per calendar year is excluded from the inspection and
monitoring requirements of these standards. Closed-vent
systems and control devices subject to Subpart BB standards
must comply with all applicable Subpart AA standards. Any
closed-vent systems and control devices utilized must comply
with Subpart AA design, operating, monitoring, and reporting
requirements. |
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Special Definitions
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| Special Definitions |
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Description: Subpart BB standards consist primarily of leak detection and
repair of design specifications. |
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Inspection and Monitoring Requirements
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| Pumps in Light Liquid Service |
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Description: Each pump which is in light liquid service must be monitored
monthly in accordance with Method 21. An instrument reading
of 10,000 ppm or greater determines a leak. Each pump which
is in light liquid service must also be checked by visual
inspection each calendar week. Visible indications of liquids
dripping from a pump seal determines a leak. When a leak is
detected the owner or operator must repair it as soon as
practicable but no later than 15 calendar days from detection.
A first attempt at repair shall be made no later than five calendar
days after each leak is detected. |
| Compressors |
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Description: Each compressor subject to Subpart BB regulations must be
equipped with a seal system that includes a barrier fluid system
that prevents leakage of total organic emissions to the
atmosphere. |
| Pressure Relief Devices in Gas/Vapor Service |
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Description: Pressure relief devices in gas/vapor service must be operated
with no detectable emissions, as indicated by an instrument
reading of less than 500 ppm above background as determined
by using Method 21. |
| Sampling Connecting Systems |
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Description: Each sampling connection system must be equipped with a
closed-purge, closed-loop, or a closed-vent system. The
closed-purge, closed-loop, or closed-vent system must return
the purged hazardous waste stream directly to the hazardous
waste management process line with no detectable emissions,
collect and recycle the purged hazardous waste stream with no
detectable emissions to the atmosphere, or be designed and
operated to capture and transport all the purged hazardous
waste stream to a control device. Sampling connection systems
with in-situ sampling are not required to be equipped with a
closed-purge, closed-loop, or closed-vent system. |
| Open-Ended Valves or Lines |
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Description: All open-ended valves or lines must be equipped with a cap,
blind flange, plug or a second valve, to seal the open end at all
times except during operations requiring hazardous waste
stream flow through the open-ended valve or line. |
| Valves in Gas/Vapor Service or in Light Liquid Service |
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Description: Each valve in gas/vapor or light liquid service must be
monitored monthly to detect leaks.
The monthly monitoring requires the use of Method 21. Any
reading of 10,000 ppm or greater determines a leak. When a
leak is detected, it must be repaired as soon as possible, but no
later than 15 calendar days after leak detection. A first attempt
at repair must be made within five calendar days of leak
detection. |
| Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light Liquid or Heavy Liquid Service and Flanges and Other Connectors |
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Description: Pumps and valves in heavy liquid service, pressure relief devices
in light liquid or heavy liquid service and flanges and other
connectors must be monitored in accordance with Method 21
within five calendar days if a potential leak was identified by
visual, audible, olfactory or any other detection method. If the
instrument reading is 10,000 ppm or greater, a leak is detected.
The leak must be repaired within 15 calendar days, with a first
attempt within five calendar days. |
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Alternative Standards for Valves in Gas/Vapor or Light Liquid Service: 2% Allowed to Leak
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| Alternative Standards for Valves in Gas/Vapor or Light Liquid Service: 2% Allowed to Leak |
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Description: The owner or operator can elect to have all valves within a
hazardous waste management unit comply with an alternative
standard which allows no greater than two percent of the valves
to leak. The owner or operator must notify the Regional
Administrator that they have elected to comply with the
alternative standards. A performance test in accordance with
Method 21 must be conducted at the time of the notice and
annually thereafter. The valves must be monitored within one
week by Method 21. |
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Alternative Standards for Valves in Gas/Vapor or Light Liquid Service: Skip Period
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| Alternative Standards for Valves in Gas/Vapor or Light Liquid Service: Skip Period |
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Description: An owner or operator may choose an alternative standard by
which, for all valves in gas/vapor or light liquid service that have
had two consecutive quarterly leak detection period with
percentages of valves leaking equal to or less than two percent,
the owner or operator may skip one of the quarterly leak
detection periods. After five consecutive quarterly leak
detection periods with the percentage of valves leaking equal to
or less than two percent, the owner or operator may go to
annually leak detection checks. However, if the percentage of
valves leaking is greater than two percent, the owner or
operator must resume quarterly monitoring. |
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Waste Determination
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| Waste Determination |
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Description: Leak detection monitoring and no detectable emissions
determinations in compliance with Subpart BB standards must
take place in accordance with Method 21. Applicability
determinations for equipment that may be subject to Subpart
BB standards must be made in accordance with the facility
waste analysis plan required by 40 CFR 264.13(b) and
265.13(b). Once collected according to the waste analysis
plan, the samples must be analyzed using American Society for
Testing and Materials (ASTM) Methods D 2267-88, E 169-
87, E 168-88, E 260-85 or SW-846 Methods 9060 or 8260. |
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Recordkeeping Requirements
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| Recordkeeping Requirements |
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Description: For each piece of equipment subject to Subpart BB regulation,
the owner or operator must record the following information in
the facility operating record. |
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Reporting Requirements
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| Reporting Requirements |
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Description: If a leak is detected in a valve, pump, or compressor and not
repaired, or if a control device operates outside of it’s design
specifications, a semiannual report which identifies the facility by
EPA identification number, facility name, and facility address
must be submitted to the Regional Administrator. The
identification number of the valve, pump, or compressor must
be reported and the duration, cause and corrective action
related to each control device malfunction must be recorded.
The dates of any hazardous waste management unit shutdowns
must also be included in the semiannual report. |
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Implementation Issues Associated with Subpart BB
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| Implementation Issues Associated with Subpart BB |
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Description: Over the past several years, a specially trained team of
inspectors from the Indiana Department of Environmental
Management has conducted over 50 inspections to evaluate
facility compliance with Subparts AA, BB and CC. As a result
of the IDEM inspection program, a number of common
misconceptions and violations have been identified. In general,
IDEM found that most LQGs were not aware of or complying
with Subpart BB equipment monitoring requirements. |
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