Frequent Questions

What are the requirements under RCRA for air emissions for equipment on units that are used to manage hazardous waste?

The air emission standards (Subpart BB of Parts 264 and 265) require owners and operators to control equipment leaks at hazardous waste facilities by requiring them to adopt safe management practices.   Subpart BB applies to equipment that contains or contacts hazardous waste with organic concentrations of at least ten percent by weight (§264/265.1050(b)).  Equipment is defined as any valve, pump, compressor, pressure relief device, sampling connection system, open-ended valve or line, or flange or other connector, and any control devices or systems required by Part 264/265, Subpart AA (§264.1031).  The Subpart BB equipment leak standards apply to permitted or interim status units, recycling units located at permitted or interim status hazardous waste management facilities, and large quantity generator units (§264/265.1050(b)).  Although most recycling units are exempt from regulation, §261.6(d) subjects certain recycling units to Subpart BB standards.  Any unit exempt from the facility standards per §264.1/265.1 is not subject to the equipment leak standards in Subpart BB.  In addition, equipment that contains or contacts organic hazardous waste for less than 300 hours per year is only subject to the Subpart BB identification and recordkeeping requirements (§§264.1050(f) and 265.1050(e)).

Additional guidance on Subpart BB standards is available in the following documents:

Memo, Springer to Regions; March 17, 2004 (RO 14703)
Monthly Call Center Report Question; June 2000 (RO 14461) (PDF, 10K)
Memo, Cotsworth to Pavlou; May 26, 2000 (RO 14469)
Monthly Call Center Report Question; March 2000 (RO 14443)
Monthly Call Center Report Question; February 1996 (RO 13777)
Memo, Michael to Massimino; December 3, 1991 (RO 13517)


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