United States Solid Waste and
Environmental Protection Emergency Response
Agency (5305W)
Region 3
Waste and Chemicals
Management Division
EPA530-F-98-011
July 1998
http://www.epa.gov/osw
RCRA Organic Air Emission
Standards for TSDFs and Generators
The organic air
emission standards
for tanks, surface
impoundments, and
containers became
effective on December 6,
1996.
Prior to publication in
the Code of Federal
Regulations, subpart
CC regulations can be
found in the Federal
Register (FR) at 59
FR 62896, December 6,
1994, as amended at 60
FR 50426, September
29,1995; 61 FR 4903,
February 9,1996; 61
FR 59932, November
25,1996; 62 FR
64636, December 8,
1997.
Purpose
The purpose of this docu-
ment is to inform you of
the requirements of the
Resource Conservation and
Recovery Act (RCRA)
organic air emission
standards contained in
40 CFR Parts 264/265, subpart CC.The Environmental Protection Agency (EPA) is
responsible for the enforcement of the subpart CC standards until states become
authorized to implement the regulations.
The information contained in this summary document is solely for the
convenience of the reader. It is the responsibility of the facility to comply with
all regulatory requirements as promulgated. For a complete understanding of all
applicable requirements, the facility should refer to the regulations contained
in the Code of Federal Regulations (CFR).
Section 3004 (n) of RCRA requires the development of standards to control air
emissions from hazardous waste treatment, storage, and disposal facilities (TSDFs)
as necessary to protect human health and the environment. EPA has promulgated a
series of regulations to implement this requirement. These regulations control air
emissions from certain process vents and equipment leaks (parts 264 and 265,
subparts AA and BB), as well as air emissions from certain tanks, containers, and
surface impoundments (subpart CC).The subpart AA and BB standards became
effective on December 21, 1990. See page 6 for a detailed discussion of the subpart
AA and BB standards. The subpart CC organic emission control standards became
effective on December 6, 1996.
When the rules were issued, EPA estimated that organic air emissions from
hazardous waste TSDFs exceeded 2 million tons/year. These air emissions can
contain toxic organic compounds as well as ozone precursors. Cancer and other
adverse health effects may result from exposure to these organic emissions.
Subpart CC standards are designed to reduce the level of organic air emissions
to approximately 150,000 tons/year.
Recycled/Recyclable
Paper contains at least 20 percent postconsumer fiber.
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All samples used for
waste characterization
must be collected and
handled in accordance
with procedures
contained in a written
sampling plan
maintained onsite.
Applicability
Method 25D in 40 CFR
part 60, appendix A,
other approved analytical
methods, or owner/
operator knowledge may
be used to determine the
average VO concentration
of the waste.
The subpart CC standards of 40 CFR part
264 (Permitted Facilities) and part 265
(Interim Status Facilities) apply to owners
and operators of all facilities that treat,
store, or dispose of hazardous waste in
tanks, surface impoundments, or containers
if the waste management units are subject
to 40 CFR parts 264/265, subparts I, J, or
K, after December 6, 1996. This includes
large-quantity hazardous waste generators
(> 1,000 kg/month) storing hazardous
waste in tanks or containers for less than
90 days.
See 40 CFR 264.1080 or 265.1080 to
determine if your waste management units
are subject to the subpart CC regulations.
See 40 CFR 264.1082 and 265.1083 for a
description of hazardous wastes and waste
management units that are exempt from
the subpart CC standards. Generally, if a
hazardous waste has an average volatile
organic (VO) concentration less than 500
parts per million by weight (ppmw) at the
point of waste origination or if the
hazardous waste organic content has been
reduced by a treatment process to the
extent described in 40 CFR 264.1082 or
265.1083 prior to placement in the waste
management unit, the unit is exempt from
the air emission controls required under
the standards. The procedures to be used
for determining average VO concentration
and other waste characteristics are specified
in 40 CFR 264.1083 and 265.1084.
An owner or operator of an exempt waste
management unit is required to maintain
records that document the rationale for
the exemption.
Effective Dates
The subpart CC standards became effective
on December 6, 1996. If the required air
emission control equipment was not
operational by December 6, 1996, the
owner or operator was required to develop
an implementation schedule for the
equipment installation and startup. The
schedule must have been placed in the
facility records by December 6, 1996. For
most facilities, the final date by which all
required air emission equipment must have
been installed and operating was December
8, 1997. Waste stabilization tank controls
must be installed by June 8, 1998.
Tanks
Subpart CC standards applicable to
tanks containing hazardous wastes are
specified in 40 CFR 264.1084 and
265.1085.There are two levels of air
emission controls for tanks based on the
size of the tank, maximum organic vapor
pressure of the waste, and whether the tank
is used in a waste stabilization process.
The owner or operator is responsible for
determining whether Tank Level 1 or Tank
Level 2 controls are applicable.
Tank Controls
1. If a tank's waste is greater than or
equal to 500 ppmwVO, then air
emission controls must be used.
2. Level of control is determined based
on tank capacity, vapor pressure at
storage conditions, and waste stabili-
zation. Table 1 provides a matrix for
determining the applicable control
level for a tank.
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3. If a tank qualifies for Level 1 controls,
a tight-fitting cover (i.e., fixed roof)
can be used and the owner or operator
using Level 1 must determine the
maximum organic vapor pressure
for each hazardous waste placed in
the tank as specified by 40 CFR
265.1084 (c). Records of the
maximum organic vapor pressure
determination are required. These
records must include the date and time
the samples were collected, the
analytical method used, and the results.
4. If a tank qualifies for Level 2 controls,
the following control options are
available to the owner/operator:
• External floating roof (EFR)
• Internal floating roof (IFR)
• Vent to control device
• Pressure tank
• Vent to an enclosed combustion
device.
All tanks regulated by the subpart CC
standards must be regularly inspected.
Inspection procedures and requirements
vary by type of tank control used. Records
of all inspections, regardless of the control
level, must be kept at the facility for a
minimum of 3 years after the date of the
inspection.
Owners or operators of tanks with internal
or external floating roofs using Tank Level 2
controls are required to notify the Regional
Administrator before conducting
inspections. More detailed recordkeeping
and inspection requirements are also
required for floating roof tanks and tanks
or enclosures that vent to a control device.
Table 1 . Determination of Applicable Level of Control for Tanks Containing
Hazardous Waste Subject to the Subpart CC Regulations
Tank Design
Capacity
<75m3
(20,000 gal)
>75 m3
(20,000 gal)
and
<151 m3
(40,000 gal)
>151 m3
(40,000 gal)
Maximum Organic
Vapor Pressure of
Hazardous Waste
in Tank
<76.6 kPa
(11.1 psi)
>76.6 kPa
<27.6 kPa
(4.0 psi)
>27.6 kPa
<5.2 kPa
(0.75 psi)
>5.2 kPa
Does Waste
Stabilization Process
Occur in Tank?
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Applicable
Level of
Control
Tank Level 2 Controls
Tank Level 1 Controls
Tank Level 2 Controls
Tank Level 2 Controls
Tank Level 2 Controls
Tank Level 1 Controls
Tank Level 2 Controls
Tank Level 2 Controls
Tank Level 2 Controls
Tank Level 1 Controls
Tank Level 2 Controls
Tank Level 2 Controls
Method 25E in 40 CFR
part 60, appendix A,
other approved analytical
methods, or owner/
operator knowledge may
be used to determine the
maximum organic vapor
pressure of the hazardous
If Tank Level 1 controls
are used, documentation
of the maximum
organic vapor pressure
determination must be
kept in the facility
records.
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Surface impoundments
subject to subpart CC
control requirements
must have a floating
membrane cover or a
cover vented to a control
device.
Surface Impoundments Containers
Transport vehicles, such
as tank trucks and tank
rail cars, are considered
to be containers under
RCRA.
Container Level 1 or 2
controls can be satisfied
by properly using a DOT
container approved for
hazardous material
transport.
Subpart CC standards applicable to surface
impoundments containing hazardous
wastes are found in 40 CFR 264.1085 and
265.1086.To control air emissions from
a surface impoundment managing a
hazardous waste with aVO concentration
>500 ppmw, an owner or operator must
install and operate either a floating
membrane cover or a cover that is vented
through a closed-vent system to a control
device. The floating membrane cover must
meet certain design requirements specified
in the rule including a requirement that the
cover be made of high-density polyethyl-
ene with a thickness no less than 2.5 mm
or of an equivalent material. The surface
impoundment covers and closure devices
are to be visually inspected for defects on
or before the date that the unit is subject to
the subpart CC standards and at least once a
year thereafter. First efforts at repair of any
defects detected on the cover or closure
devices must be made within 5 days of
detection, and repairs must be completed
within 45 days of detection. A repair may
be delayed more than 45 days only if it
requires emptying the surface impound-
ment or removing it from service and no
alternative capacity is available at the facility
to accept the hazardous waste normally
managed in the unit. Records of all
inspections must be kept at the facility for a
minimum of 3 years from the date of the
inspection.
Subpart CC standards applicable to contain-
ers of hazardous wastes are specified in
40 CFR 264.1086 and 265.1087.There are
three levels of air emission controls for
containers based on container size, organic
contents, and whether the container is used
in a waste stabilization process. Table 2
provides a matrix for determining the
applicable control level for a container.
Containers with a capacity less than 0.1 m3
(26 gallons) are exempted from the rule.
Container Level 1 controls require that the
hazardous waste be stored in an approved
Department of Transportation (DOT)
container, a container equipped with a
cover and closure devices for each opening,
or an open-top container with an organic-
vapor-suppressing barrier. Container Level
2 controls require that the hazardous waste
be stored in an approved DOT container, a
container that operates with no detectable
organic emissions, or a demonstrated
vapor-tight container. Container Level 3
controls require that the hazardous waste
be stored in a container that is either
vented directly to a control device or is
located inside an enclosure that is vented
through a closed-vent system to a control
device. Design and operating criteria are
specified in the rule for the enclosure,
closed-vent system, and control device.
If a container is not emptied within 24
hours after it is accepted at the facility, a
visual inspection is required on or before
the date the container is accepted and at
least once a year thereafter. Repairs of
defects must be completed within 5 days
or the contents of the container must
be transferred to a container that is in
compliance with the subpart CC standards.
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If a non-DOT container larger than 0.46
m3 (119 gallons) is used with Container
Level 1 controls, records of the procedure
used to determine that the container is not
managing hazardous waste "in light
material service" must be maintained.The
subpart CC standards contain special
recordkeeping and inspection requirements
for Level 3 containers and their associated
closed-vent systems, enclosures, and
control devices.
Miscellaneous Units
Certain miscellaneous (subpart X) units
may also be subject to subparts AA, BB, and
CC if those units managing the hazardous
waste are similar to tanks, containers, and
surface impoundments. The appropriate air
emission controls would be implemented
through the issuance or modification of a
permit.
Inspection
and Monitoring
Requirements
Owners or operators are required to
inspect and monitor air emission control
equipment used to comply with subpart
CC in accordance with the applicable
requirements specified in §265.1085
through §265.1088. Requirements vary
by type of waste management unit and
control device used.
Differences Between
Permitted and Interim
Status Facilities
The only difference between the air
emission standards for permitted facilities
The owner or operator
must develop and
implement a written
plan and schedule to
perform the required
inspection and
monitoring.
Inspection records must
be maintained in the
facility records for at
least 3 years from the
date of inspection.
Table 2. Determination of Applicable Level of Control for Containers
of Hazardous Waste Subject to the Subpart CC Regulations
Container
Design
Capacity
<0.1 m3
(26 gal)
>0.1 m3
(26 gal)
and
<0.46 m3
(11 9 gal)
>0.46 m3
(11 9 gal)
Is the
Container in
Light Material
Service?
NA
Yes
No
No
Yes
Yes
No
No
Yes
Does Waste
Stabilization Process
Occur in Container?
NA
Yes
No
Yes
No
Yes
No
Yes
No
Applicable
Level of
Control
Container is Exempt from
Air Emission Standards
Container Level 3 Controls
Container Level 1 Controls
Container Level 3 Controls
Container Level 1 Controls
Container Level 3 Controls
Container Level 1 Controls
Container Level 3 Controls
Container Level 2 Controls
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Facilities that became
subject to subpart AA
and BB regulations as
a result of the TSDF
organic air emission
standards must install
the regulated control
devices by June 6,1999.
(This does not apply to
leak detection and repair
(LDAR) program
requirements under
subpart BB. Facilities
must comply with LDAR
requirements by
December 6,1996.)
Subpart AA establishes
standards for process
vents as well as closed-
vent systems and control
devices.
and interim-status facilities or large-quantity
generators (<90-day storage) is the report-
ing requirement. There are no specific
reporting requirements for interim-status
facilities or generators. For permitted
facilities, the following situations should be
reported to the Regional Administrator:
1. A waste management unit reported to be
exempt from the subpart CC regulations
that is no longer complying with the
standard that exempted the unit.
2. A tank using Tank Level 1 air emission
controls that is no longer complying with
Level 1 control requirements.
3. A control device that has continuously
operated in noncompliance with the
applicable standards for a period of 24
hours or longer in any 6-month period.
Subpart AA
and BB Standards
The TSDF organic air emission standards
have made all permitted TSDFs and large-
quantity generators subject to the subpart
AA and BB regulations as of December 6,
1996. The subpart AA and BB standards of
40 CFR parts 264 and 265 became effective
on December 21, 1990, for interim-status
TSDFs. Under the subpart CC rule,
permitted TSDFs are now required to
comply with the subpart AA and BB air
emission standards for interim-status
facilities until the facility's permit is
reviewed or reissued by EPA or the state
(when authorized to implement these
programs).
If the required controls (i.e., control devices
or process changes) were not installed
before December 6, 1996, an implementa-
tion schedule and an explanation describing
why the controls were not installed must be
placed in the facility records.
Subpart AA establishes air emission controls
for process vents associated with distillation,
fractionation, thin-film evaporation, solvent
extraction, or air or steam stripping opera-
tions that manage hazardous wastes with
organic concentrations of at least 10 ppmw
Subpart AA also establishes standards for
closed-vent systems and control devices.
See 40 CFR 264.1030 through 264.1036 or
265.1030 through 265.1035 for all of the
air emission standards for process vents,
closed-vent systems, and control devices.
Subpart BB establishes air emission controls
for equipment leaks. Subpart BB applies to
equipment that contains or contacts hazard-
ous wastes with organic concentrations of
at least 10% by weight. If the equipment
contacts hazardous waste or hazardous
waste residues less than 300 hours per year
or if the equipment is in vacuum service, it
is excluded from the subpart BB standards.
Types of equipment regulated by subpart BB
include pumps, compressors, pressure-relief
devices, sampling connection systems,
valves, open-ended valves or lines, and
flanges. (The allowance for an implement-
ation schedule does not apply to the leak
detection and repair [LDAR] program for
pumps and valves. LDAR must be in place
by December 6, 1996.)
Each piece of equipment that is subject to
the subpart BB standards must be marked in
such a manner that it can be readily distin-
guished from other pieces of equipment.
The equipment must be monitored and
inspected regularly. Specific inspection
requirements are contained in 40 CFR
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264.1052 through 264.1060 or 40 CFR
265.1052 through 265.1060. Most
equipment leaks must be repaired within
15 calendar days, although a leaking
pressure-relief device must be repaired
within 5 calendar days.
Recordkeeping requirements include
equipment identification, equipment
description and location, methods of
compliance monitoring, and equipment
LDAR records. See the Code of Federal
Regulations for more specific recordkeeping
requirements.
Waste Minimization
The hazardous waste generated by a
company can cut into that company's profit
margin. Not only are there costs to manage,
transport, and dispose of waste, valuable
resources could be discarded inadvertently
and potential liabilities incurred. More
and more companies are taking steps to
minimize hazardous waste generation
in their facilities to reduce the financial
burden of the RCRA regulations. EPA may
be able to help.
For more information on minimizing
hazardous waste, contact the RCRA Hotline
at 800-424-9346 orTDD-800-
553-7672 or visit the web site at:
http://www.epa.gov/osw/minimize
Definitions
Average volatile organic concentration -
The mass-weighted average volatile organic
concentration of a hazardous waste as
determined in accordance with the require-
ments of §265.1084 (a).
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.
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 is not
a control device.
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.
In light material service - A container that
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% by weight.
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 (e.g.,
temperature, agitation, pH effects of
combining wastes) reasonably expected to
occur in the tank. Maximum organic vapor
pressure is determined using the
procedures specified in §265.1084(c).
No detectable organic emissions - No
escape of organics to the atmosphere as
determined using procedures described in
§265.1084 (d).
Subpart BB establishes
air emission controls for
equipment leaks.
Equipment that is
leaking and subject to
subpart BB must be
identified with a tag that
contains the equipment
ID No. and the date of
leak detection.
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Point of waste origination - (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.
Point of waste treatment -The point where a
hazardous waste to be treated in accordance with
§265.1083 (c) (2) exits the treatment process. Any waste
determination must be made before the waste is
conveyed, handled, or otherwise managed in a manner
that allows the waste to volatilize to the atmosphere.
Volatile organic concentration - The fraction by weight
of the volatile organic compounds with a Henry's law
constant value of at least 0.1 y/x contained in a
hazardous waste expressed in terms of ppmw as
determined by direct measurement or by knowledge
of the waste in accordance with the requirements of
§265.1084.
Waste determination - Performing all applicable
procedures in accordance with the requirements of
§265.1084 to determine whether a hazardous waste
meets standards specified in subpart CC. For example,
determining the volatile organic concentration of a
hazardous waste stream.
Waste stabilization process - 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 9095 (Paint Filter
Liquids Test) in Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, EPA Publication No. SW-846,
Third Edition, September 1986, as amended by Update
I, November 15, 1992. 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.
Please contact the RCRA Hotline at (800) 424-9346
or TDD (800) 553-7672 (in the Washington, DC,
area call (703) 412-9810) to find out your EPA
Regional Permitting and Enforcement contacts.
SEPA
U.S. Environmental Protection Agency
401 M Street (5305W)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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