Implementing the RCRA/CAA Air Emission Controls Compliance Exemption/Election Provisions Through RCRA Permits

This document provides information and model permit language for Resource Conversation and Recovery Act (RCRA) permit writers implementing the regulatory compliance exemption/election provisions that are found in 40 CFR parts 264/265, subpart AA (applicable to certain process vents), subpart BB (applicable to equipment leaks), and subpart CC (applicable to certain tanks, containers, surface impoundments).

Although this document is mostly intended for regional and state permit writers, it also assists regulated entities in understanding the compliance exemption/election provisions and states what should be included in a permit application. EPA intends both sets of standards (RCRA and the Clean Air Act (CAA)) to work together to create a comprehensive air program for addressing organic air emissions from all waste and related material recovery operations.

For more information on RCRA Air Emissions Standards, view our pages on:

• RCRA Organic Air Emission Standards for TSDFs and Generators
• Applicability and Requirements of the RCRA Organic Air Emission Standards
• Implementing the RCRA/CAA Air Emission Controls Compliance Exemption/Election Provisions Through RCRA Permits (October 2019)