RCRA Air: What Air Regulations are in the Hazardous Waste Standards?
In our blog article about EPA's compliance initiatives, EPA said a number of facilities were not complying with RCRA air requirements and as a result, i...
RCRA air regulations are invisible to many facilities managing hazardous waste—until an EPA inspection finds non-compliance and penalties follow. EPA has explicitly directed inspectors to prioritize RCRA air deficiencies because non-compliance is widespread.
⚡ TL;DR: RCRA air regulations (40 CFR Part 264/265, Subparts AA, BB, CC) control organic air emissions from hazardous waste equipment. The applicable Subpart depends on your equipment type (tanks, containers, surface impoundments, etc.). If you manage hazardous waste and haven’t evaluated your RCRA air obligations, EPA inspectors will find the gap during their next facility visit.
In our blog article about EPA’s compliance initiatives, EPA said a number of facilities were not complying with RCRA air requirements and as a result, inspectors were being directed to look at these items in inspections.
⚠️ Why Inspectors Are Targeting This: RCRA air compliance requires equipment-specific emission controls—often overlooked because waste management facilities focus on handler training and waste containment but miss the air components. EPA’s compliance initiatives identified this gap as systemic. Expect targeted questions about emission controls, closure procedures, and equipment decommissioning on any upcoming inspection.
So, what are the RCRA air requirements, and who is affected by them? RCRA air regulations pertain to organic air emissions from equipment used for hazardous waste. There are 3 different standards Subparts AA, BB and CC and each are specific to the type of equipment being used. Does This Apply to You? iSi can help you determine if you’re subject to RCRA Air regulations, and which Subpart you’re required to follow. Contact us today for a price quote!
Frequently Asked Questions
Q: What are RCRA air regulations and which facilities must comply?
A: RCRA air regulations control organic air emissions from equipment used to manage hazardous waste under the Resource Conservation and Recovery Act (RCRA). EPA has identified that many facilities are not complying with these requirements, and EPA inspectors are now prioritizing RCRA air compliance in their inspection activities.
Q: What are RCRA Subparts AA, BB, and CC?
A: RCRA air requirements are divided into three subparts (AA, BB, and CC), each specific to different types of equipment used for hazardous waste management. The appropriate subpart depends on the particular equipment and equipment type at your facility, and EPA inspectors evaluate whether facilities are following the correct regulatory standard.
Q: How do I determine which RCRA air subpart applies to my facility?
A: The applicable subpart depends on the specific equipment types used for hazardous waste storage, treatment, and disposal at your facility. iSi Environmental can conduct a compliance review to determine your RCRA air obligations and identify any equipment or operations requiring control measures.
Q: What is EPA’s current enforcement focus regarding RCRA air compliance?
A: EPA has directed inspectors to specifically evaluate RCRA air compliance during facility inspections due to widespread non-compliance identified in previous compliance initiatives. Facilities with hazardous waste management operations should ensure they have properly evaluated their RCRA air obligations and implemented appropriate emission controls.
Q: What equipment is typically subject to RCRA air requirements?
A: RCRA air regulations apply to equipment used in hazardous waste management including tanks, containers, surface impoundments, land treatment units, waste piles, and closed or closing units. The specific Subpart (AA, BB, or CC) depends on the equipment configuration and emission control requirements for your facility’s waste streams.
💰 Penalty Exposure: RCRA air violations are typically classified as significant non-compliance and can result in civil penalties of $10,000+ per day per violation. Equipment deficiencies spanning multiple units can quickly escalate to $100,000+ in total penalties. Facilities that have never conducted RCRA air compliance reviews face substantial risk if an inspection occurs.
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