| Requirement & Regulatory Citation | Compliance Status | Compliance Comments |
| *AIR EMISSIONS - SUBPART BB CHECKLIST. | | |
| Background: If a facility (TSD or LQG) has equipment (any valve, pump,compressor, pressure relief device, sampling connection system, flange, open-ended valve or line) that contacts hazardous wastes greater than 10 percent organics, that facility is subject to the inspection and monitoring requirements of Subpart BB. If the equipment used to transport hazardous waste with greater than 10 percent organics is used for less than 300 hours per year, then the facility is excluded from the requirements of 264/265.1052 through 264/265.1060 of this subpart if the equipment is identified as required in 264/265.1064(g)(6). | | |
| Objective: The Inspector should try to determine if Subpart BB applies at a particular facility and, if applicable, evaluate the facility?s Leak Detection and Repair (LDAR) program. Does it cover all the effected equipment, what is its frequency (monthly, quarterly) and are there records of timely (<15 days) equipment repair when leaks are detected. The importance of compliance with Subpart BB is a function of the amount and volatility of a facility?s waste. | | |
| 1. Does the facility have any valves or pumps that contain or contact hazardous wastes greater than 10 percent organics?. | | |
| 2. Does the facility have any compressors, pressure relief devices, sampling connection systems, flanged pipe open-ended valve or line that contain or contact hazardous wastes greater than 10 percent organics?. | | |
| 3. Is the facility claiming the < 300 hours exemption?. | | |
| 4. If the answer to Questions 1 or 2 is yes, and the facility is not claiming the <300 hour exemption, then does the facility have a list of each piece of equipment that is subject to Subpart BB?. | | |
| 5. Has this equipment been marked as required by the Subpart BB Regulations?. | | |
| 6. Has the facility implemented a LDAR program?. | | |
| Describe the program: . | | |
| *FOR PUMPS AND VALVES IN LIGHT LIQUID OR GAS/VAPOR SERVICE. | | |
| LIGHT LIQUID SERVICE: For a hazardous waste to be in light liquid service, the vapor pressure of one or more of the organic constituents in the material must be greater than 0.3 Kilopascals at 20 degrees C and the total concentration of pure organic constituents having a vapor pressure greater than 0.3 kilopascals at 20 degrees Centigrade is equal to or greater than 20 percent by weight. | | |
| 7. Is each pump in light liquid monitored monthly to detect leaks?. | | |
| 8. Is each pump in light liquid service checked by visual inspection each calendar week for indications of liquids dripping from the pump seal?. | | |
| 9. Is each valve in light liquid service or gas/vapor service monitored monthly for leaks?. | | |
| *EQUIPMENT IN HEAVY LIQUID SERVICE. | | |
| 10. Are pumps, valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service and flanges and other connectors in light or heavy liquid service monitored for leaks by visual, olfactory, or any other detection method?. | | |
