April 16, 2018
A Guide to Determining Subpart CC Control Level
Subpart CC, found in Parts 264 and 265, is known for being one of three sets of air emission standards with which TSD facilities and large quantity generators must comply. If a hazardous waste management unit is using air emission controls in accordance with applicable CAA requirements, then the RCRA air emission standards do not apply. But what do you do if you have a hazardous waste tank or container that does need to comply with the RCRA air emission standards? We have created two easy-to-use tables to help explain what Subpart CC control level is applicable to your waste management unit.
Simplified Matrix for Determining Subpart CC Level 1 or 2 Hazardous Waste Tank Controls
| Maximum organic vapor pressure of hazardous waste in tank | Subpart CC |
|---|---|---|
If stabilization is occurring in the tank, Level 2 controls apply. Otherwise use the matrix below. | Level 2 |
|
<20,000 gallons (75 m3) | ≤11.1 psi (76.6 kPa) >11.1 psi (76.6 kPa) | Level 1 Level 2 |
≥20,000 gallons (75 m3) and <40,000 gallons (151 m3) | ≤4.00 psi (27.6 kPa) >4.00 psi (27.6 kPa) | Level 1 Level 2 |
≥40,000 gallons (151 m3) | ≤0.75 psi (5.2 kPa) >0.75 psi (5.2 kPa) | Level 1 Level 2 |
1Capacities specified as gallons are approximate; the Subpart CC regulations specify capacities in m3. Basis is design capacity, not fill level, of the tank.
Source: Adapted from EPA/530/F-98/011, July 1998, available at http://www.epa.gov/sites/production/files/2015-08/documents/subcc.pdf.
Compliance with Subpart CC tank controls
Compliance with tank controls is relatively straightforward:
- Level 1 tank controls can be summarized as a fixed roof with no gaps, closure devices that can be open for normal operation but have no gaps when closed, pressure-relief devices if necessary to maintain safe internal pressure, and annual inspections of the roof and closure devices. [§§264.1084(c)/265.1085(c)]
- There are five different options for complying with Level 2 tank controls, although the most common option is to equip the tank with a closed-vent system routed to a volatile organic control device.[§§264.1084(d)/265.1085(d)]
Simplified Matrix for Determining Subpart CC Level 1, 2, or 3 Hazardous Waste Container Controls
Container design capacity1 | Container in light material service?2 | Subpart CC level of control |
|---|---|---|
≤26.4 gallons (0.1 m3) |
Exempt from Subpart CC |
|
>26.4 gallons (0.1 m3) If stabilization is occurring in the container, Level 3 controls apply. Otherwise use the matrix below. |
Level 3 |
|
>26.4 gallons (0.1 m3) and ≤121 gallons (0.46 m3) |
Level 1 |
|
>121 gallons (0.46 m3) | No Yes | Level 1 Level 2 |
1Capacities specified as gallons are approximate; the Subpart CC regulations specify capacities in m3. Basis is design capacity, not fill level, of the container.
2“In light material service means the container 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 percent by weight.” [§265.1081]
Source: Adapted from EPA/530/F-98/011, July 1998, available at http://www.epa.gov/sites/production/files/2015-08/documents/subcc.pdf.
Compliance with Subpart CC container controls
Containers are also relatively simple to operate in compliance with Subpart CC if you select them properly:
- Level 1 container controls can be easily met by using a closed container that meets applicable DOT standards. Containers with tight fitting covers with no visible gaps or openings are also acceptable. [§§264.1086(c)/265.1087(c)]
- Level 2 container controls also include the option of using a closed container that meets applicable DOT standards. The requirements can also be met by using a closed container that has no detectable organic emissions per Method 21 of 40 CFR Part 60, Appendix A or by using a closed container that is shown to be vapor tight per Method 27 of 40 CFR Part 60, Appendix A on an annual basis.[§§264.1086(d)/265.1087(d)]
- Level 3 container controls are the most stringent and require the container to be 1) vented directly to a control device; or 2) located in an enclosure that meets Procedure T—Criteria for and Verification of a Permanent or Temporary Total Enclosure under 40 CFR 52.741, Appendix B, such enclosure being connected via a closed-vent system to a control device. [§§264.1086(e)/265.1087(e)]
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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.
This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
