November 12, 2018

Subpart BB Compliance Begins with Equipment Identification

Subpart BB, along with Subparts AA and CC, of Parts 264 and 265, make up RCRA’s air emission standards. Subpart BB is a leak detection and repair (LDAR) program similar to what is found in the Clean Air Act (CAA). Focusing on the ancillary equipment associated with hazardous waste units, Subpart BB establishes an inspection and monitoring schedule based on the equipment in use. Therefore, the first step in a successful Subpart BB program is the identification of regulated equipment.

Most commonly, Subpart BB-regulated equipment is physically tagged or marked to distinguish it from other pieces of equipment not subject to LDAR requirements. Sections 264.1050(d)/265.1050(c) imply physical tagging is required, but conversations with industry professionals and regulators seem to suggest that this is not necessarily so. It may be sufficient to indicate the regulated equipment on a plant diagram; however, we recommend checking with your authorized state agency on this interpretation.

EPA has developed an extensive LDAR best-practices guidance document to help with Subpart BB and CAA LDAR compliance. In it, EPA recommends 1) physically tagging each regulated equipment component with a unique ID number; 2) writing the component ID number on piping and instrumentation diagrams; 3) instituting an electronic data management system for LDAR data and records, possibly using bar coding equipment; and 4) periodically conducting field audits to ensure lists and diagrams accurately represent equipment installed in the plant.

Keep in mind that Subparts AA, BB, and CC are one of eight EPA national compliance initiatives for FY 2017–2019. These are regulatory issues where EPA has found wide-spread noncompliance resulting in serious health and environmental impacts. To assist facilities that are affected by these air emissions regulations, EPA recently released a compliance advisory.


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA 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.