EPA530-F-94-041

                       November 16, 1994

                            FACT  SHEET

Final Air  Emission  Standards  under the  Resource  Conservation and
 Recovery Act (RCRA) for Hazardous Waste Treatment, Storage, and
 Disposal Facilities: Tanks, Surface Impoundments and Containers

TODAYS ACTION. . . .

+    The Environmental Protection Agency (EPA) is issuing a final
     rule under the authority of section 3004(n)  of the Resource
     Conservation and Recovery Act  (RCRA) to reduce organic air
     emissions from hazardous waste treatment, storage, and
     disposal facilities (TSDF).

*    Hazardous waste TSDF store waste in units such as tanks and
     containers, treat waste by processes such as recycling, and
     dispose of waste by techniques such as deep-well injection
     or incineration.

WHAT ARE THE HEALTH AND ENVIRONMENTAL BENEFITS?

+    The final rule will reduce emissions of cancer-causing air
     toxics  (such as benzene and carbon tetrachloride) and
     volatile organics, which include volatile organic compounds
     (VOC)  and hazardous air pollutants by an estimated 1 million
     tons annually.

*    Hazardous waste TSDF are one of the largest industrial
     sources of VOC in the country.  The VOC emissions contribute
     significantly to ground-level ozone or smog.  Ground-level
     ozone has been shown to cause adverse effects on human
     health and can damage forests and crops.

+    The EPA estimates that the incidence of cancer resulting
     from exposure to TSDF organic air emissions will decrease
     from 48 cases per year to 2 cases per year.

BACKGROUND

+    Promulgation of this standard marks the completion of the
     second phase of a three-phased regulatory program under
     section 3004(n) of RCRA to control air emissions from
     hazardous waste TSDF.  Phase I was completed when the EPA
     issued final standards for TSDF process vents and equipment
     leaks in June 1990.

4    Phase III will address any remaining risks posed by
     hazardous waste TSDF to assess the need for additional
     regulations.

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WHO IS AFFECTED BY THE FINAL RULE?

     Owners and operators of TSDF that are subject to the
permitting requirements for hazardous waste management units
under Subtitle C of RCRA may be subject to this regulation.
Subtitle C defines the hazardous waste universe regulated under
RCRA.  The facilities covered by this rule include:

*    Approximately 2,300 TSDF, most of which are located at
     production facilities such as chemical plants, petroleum
     refineries, and pharmaceutical manufacturers across the
     nation.

+    An additional 20,000 generators have 90-day tanks and
     containers that are now subject to the regulation. (Under
     the conditions specified in 40 CFR 262.34, these units are
     exempt from the Subtitle C permitting requirements provided
     the waste is accumulated in the unit for no more than 90
     days and complies with the control requirements specified in
     40 CFR 265 Subpart I or J).

+    These requirements will be applicable to all affected
     facilities on the effective date of the standards,
     regardless of a facility's permit status.  The rules are
     intended to be self-implementing, and do not require a
     modification to be made to existing RCRA final permits.

WHAT DO THE FINAL STANDARDS REQUIRE?

Introduction

+    A "surface impoundment" is an excavation or natural
     depression in the ground, such as a pond or lagoon, that
     holds an accumulation of waste.  A "tank" is a stationary
     device designed to contain waste, such as a storage tank or
     a treatment tank.  A "container," such as a 55-gallon drum
     or a dumpster, is a portable device in which waste is
     accumulated or stored.

+    This rule is not applicable to other hazardous waste
     management units that may be present at a TSDF,  such as
     landfills or waste piles.  Where appropriate,  the standards
     do apply to miscellaneous units that are like tanks or
     containers.

Required Controls

+    Organic emission control equipment must be installed,
     operated, and maintained on all tanks,  surface impoundments,
     and containers that manage hazardous waste with an average
     volatile organic content equal to 100 parts per million by
     weight (ppmw)  or more.

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+    Tanks and surface impoundments must use covers  (e.g., a roof
     on a tank, an enclosure over a surface impoundment) and vent
     the collected organic vapors to a control device that
     reduces the organics in the vapor stream by 95 percent.  Use
     of a cover without additional controls is allowed for a tank
     that meets certain capacity and waste vapor pressure
     conditions and for all surface impoundments provided: (1) no
     waste-fixating, heating, or heat-generating process is
     conducted in the unit; and (2) the waste managed in the unit
     is not mixed, stirred, agitated, or circulated within the
     unit using a process that results in splashing, frothing, or
     visible turbulent flow on the waste surface.

+    Containers used for handling, preparing, or storing
     hazardous waste are required to be covered except during
     necessary operations that require the cover to be removed
     (such as waste transfer, inspecting, or sampling).  For
     containers with a design capacity greater than or equal to
     0.46 m  (approximately 119  gallons),  waste  loading
     operations performed by pumping shall use submerged fill.
     Containers used for waste fixation are required to be
     located under a cover with a closed vent system that routes
     all organic vapors vented from the container to a control
     device.

WHAT ARE THE MAJOR CHANGES IN THE REGULATION SINCE PROPOSAL?

+    A TSDF tank, surface impoundment, or container is exempted
     from the required air emission controls provided that the
     waste managed in the unit has an average volatile organic
     concentration less than 100 ppmw.  This concentration cutoff
     for the proposed rule was 500 ppmw,  but it was a never-to-
     be-exceeded value.

+    A container having a design capacity less than O.lm3
     (approximately 26 gallons)  is exempted from all container
     control requirements.

4    A container required to use emission controls under the
     final standards and having a design capacity less than
     0.46 m  (approximately 119  gallons)  is  exempted from  certain
     container loading and monitoring requirements.

*    Alternative control requirements for containers have been
     added to the final standards allowing TSDF owners and
     operators to use certain containers that meet the existing
     U.S. Department of Transportation specifications and testing
     requirements for containers used to transport hazardous
     waste.

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*    The final standards include a deferral for radioactive mixed
     waste and waste associated with cleanup activities.
     Therefore, these waste types are not required to be managed
     in units that are equipped with the specified controls.

HOW MUCH WILL THE FINAL RULE COST?

+    Total capital investment cost to TSDF owners and operators
     to implement the final standards is estimated to be
     approximately $290 million.  Total annualized costs are
     estimated to be $110 million per year.  The major portion of
     these costs is associated with the design, installation, and
     operation of emission control equipment.

FOR MORE INFORMATION...

     For specific questions about the rule, contact Michele Aston
at (919) 541-2363.  To order a copy of the Federal Register
notice or the fact sheet, please call the RCRA Hotline Monday
through Friday, 8:30 a.m. to 7:30 p.m.,  EST and ask for the rule
Final Air Emission Standards under the Resource Conservation and
Recovery Act (RCRA) for Hazardous Waste Treatment, Storage, and
Disposal Facilities; Tanks, Surface Impoundments and Containers.
The RCRA Hotline's national toll-free number is (800) 424-9346;
for the hearing impaired, it is (TDD) (800) 553-7672.  You may
also write to the RCRA Information Center (5305),  US EPA, 401 M
Street, SW, Washington, DC 20460.

     The Federal Register notice and the BID are also available
on the EPA's Clean-Up Information Bulletin Board (CLU-IN).   To
access CLU-IN with a modem of up to 28,800 baud, dial (301) 589-
8366.  First time users will be asked to input some initial
registration information.  Next, select "D" (download)  from the
main menu.   Input the file name "RCRAAIR1.ZIP" to download this
notice.  Input the file name "RCRAAIR2.ZIP" to download the BID.
Follow the on-line instructions to complete the download.  More
information about the download procedure is located in Bulletin
104;  to read this, type "B 104" from the main menu.   In the
interim before the Federal Register notice is available,  the
final signature version of the promulgation notice will be
available under the file name "RCRAAIRD.ZIP" from the CLU-IN
bulletin board.  For additional help with these instructions,
telephone the CLU-IN help line at (301)  589-8368.

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