RCRA Subpart AA/BB/CC – Hazardous Waste Tank Emissions Management

Tanner Houston & Wendy Tredway

Solvents are used throughout semiconductor fabrication facilities and as a result generate hazardous waste streams with substantial organic concentrations that must be managed appropriately. These waste streams are of specific concern to the EPA because of their potential to volatilize and emit to the atmosphere. To curtail these air emissions, the EPA enacted the Resource Conservation and Recovery Act (RCRA) Organic Air Emissions Standards, commonly referred to as “Subpart AA/BB/CC”, which detail specific requirements facilities must meet when managing these solvent-containing waste streams. Typical equipment found in semiconductor facilities that may have to be managed in accordance with Subpart AA/BB/CC are valves, pumps, compressors, process vents, pressure relief devices, tanks, connectors, closed vent systems and various control devices. Compliant Subpart AA/BB/CC programs generally involve periodic visual inspections, emissions monitoring, detailed recordkeeping, employee training, leak detection and repair (LDAR) programs, and reporting. Reducing hazardous air emissions is part of EPA’s recent National Compliance Initiatives and inspectors are back out in the field to enforce Subpart AA/BB/CC regulations. Now is a great time to make sure you understand the regulatory burden for your facility and how to meet those requirements. Hazardous waste organics air emissions management is a complex topic, and the Subpart AA/BB/CC regulations include many exemptions that could apply to your facility.

This presentation will provide a general overview of Subpart AA/BB/CC applicability and requirements, recent experiences with EPA audits, common citations that are currently being issued, and strategies to achieve compliance.

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