UnX«d StatM           SoM Wa»t« and         §P* 51 0-F-9GHJ09
                   Environmental Protection    Emergency Rttpon**     February 1993
                   Agency               Washington, DC 20460
                                      OS-42
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Action Taken
Rationale For
Proposing This
Rule
Discussion
On February 12,1993, EPA proposed this rule that will exempt contaminated
media and debris generated from petroleum UST corrective actions that are
subject to Subtitle I of RCRA from certain portions of the RCRA Toxicity
Characteristics rule. This exemption is limited to the 25 newly listed organic
chemicals. This action maintains the language contained in the current tempo-
rary deferral for UST petroleum-contaminated media and debris, found at 40
CFR 261.4 (b) (10). If this proposed rule becomes a final rule, the current
language of the deferral would remain unchanged The period of time for the
public to comment on this proposed rule is 60 days, until April 13,1993.

The findings of EPA's studies and public meetings indicate that removing the
TC deferral would significantly affect UST cleanup procedures, delay remedial
actions, and increase soil remediation costs. Further, delays in site remediation
caused by compliance with Subtitle C requirements could increase health and
environmental risks prior to cleanup. In addition, EPA believes that states are
in the best position to oversee management of contaminated media and debris
from the approximately 30,000 new UST releases identified each year.

The Agency is soliciting public comment on four major issues in this proposed
rule.

1. Should the rule be expanded to exempt all TC contaminants? EPA
   believes that it may be unnecessary to require a hazardous waste
   determination for the 14 original EP (Extraction Procedure) contami-
   nants, because it is highly unlikely that UST petroleum-contaminated
   media and debris would contain them at concentrations above the TC
   regulatory levels.

2. Should the final rule be consistent with a similar, but separate,
   rulemaking that addresses contaminated media and debris from non-
   Subtitle I regulated sources (e.g., above ground tanks, farm and
   residential motor fuel USTs of less than 1,100-gallon capacity)?

3. Should the final rule establish Subtitle I management standards for
   contaminated media and debris? While this approach could provide
   more certainty in disposing of these materials while avoiding the
   burdens associated with regulating them as hazardous waste, it could
   reduce the states' flexibility in establishing technology requirements,
   cleanup standards, and oversight processes. Also, it may inhibit the
   development of innovative technologies.

4. Should the final rule establish streamlined Subtitle C regulatory
   approaches for UST petroleum-contaminated media and debris? The
   Agency is concerned that this approach either could present legal
   concerns or could fail to provide sufficient flexibility to remedy the
   environmental problems caused by regulating petroleum-contaminated
   media and debris as hazardous wastes.
Contact
For additional information or for a copy of the Federal Register notice, contact
EPA's RCRA/Superfund Hotline, Monday through Friday, 8:30 a.m. to ^ <0
p.m. EST. The national toll-free number is 800 424-9346; for the hearing
impaired, the number is TDD 800 553-7672.

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                                                         tw-
                                      Friday
                                      February 12, 1993
                                      Part VIH



                                      Environmental

                                      Protection Agency

                                      40 CFR Part 261
                                      Exemption or Petroleum-Contaminated
                                      Media and Debris From Underground
                                      Storage Tanks From RCRA Hazardous
                                      Waste Requirements; Proposed Rule
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                                                             Printed on Recycled Paper

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Federal Register / Vol. 58, No.  28 / Friday, February  12,  1993 / Proposed Rules
     ENVIRONMENTAL PROTECTION
     AGENCY

     40 CFR Part 261

     [FRL-4595-9]

     RIN 2050-AD69

     Exemption of Petroleum-Contaminated
     Media and Debris From Underground
     Storage Tanks From RCRA Hazardous
     Waste Requirements: Proposed Rule

     AGENCY: Environmental Protection
     Agency.
     ACTION: Proposed rule.

     SUMMARY: The Environmental Protection
     Agency (EPA) is proposing to take final
     action on an issue deferred in the 1990
     hazardous waste Toxicity
     Characteristics  (TC) rule under the
     Resource Conservation and Recovery
     Act (RCRA). The Agency proposes to
     exempt, from certain portions of EPA "s
     hazardous waste regulations, petroleum-
     contaminated media and debris, such  as
     soils and groundwater, that are
     generated from underground storage
     tank (UST) corrective actions that are
     subject to subtitle I of RCRA. The
     exemption would be limited to the 25
     newly listed organic chemicals under
     the TC (i.e., Hazardous Waste Codes
     D018 through D043 only). After
     consideration of comments received in
     response to this proposed rule, EPA will
     publish a rule containing the Agency's
     final determination regarding the
     permanent regulatory status of UST
     petroleum-contaminated media and
     debris under RCRA.
     DATES: Written  comments on this
     proposed rule must be submitted on or
     before April 13,1993.
     ADDRESSES: Written comments on
     today's proposal should be addressed  to
     the docket clerk at the following
     address: U.S. Environmental Protection
     Agency, RCRA  Docket (OS-305), 401 M
     Street, SW., Washington, DC 20460. One
     original and two copies of comments
     should be sent and identified by
     regulatory docket reference number F-
     93-DPUP-FFFFF. The docket is open
     from 9 a.m. to 4 p.m., Monday through
     Friday, excluding Federal holidays.
     Docket materials may be reviewed by
     appointment by calling (202) 260-9327.
     Copies of docket materials may be made
     at a cost of $0.15 per page.
     FOR FURTHER INFORMATION CONTACT:  For
     general information about this proposal,
     contact the RCRA/Superfund Hotline,
     Office of Solid Waste, U.S.
     Environmental Protection Agency
     Washington, DC 20460, (800) 424-9346
     (toll-free) or (703) 412-9810 (local). For
                       the hearing impaired, the number is
                       (800) 553-7672 (toll-free), or (703) 412-
                       3323 (local). For technical information
                       on this proposal, contact John
                       Heffelfinger in the EPA Office of
                       Underground Storage Tanks at (703)
                       308-6881. To obtain copies of the
                       reports or other materials referred to in
                       this proposal, contact the RCRA Docket
                       at the phone number or address listed
                       above.
                       SUPPLEMENTARY INFORMATION:
                       I. Background

                       A. Toxicity Characteristics Rule
                         The Toxicity Characteristics (TC) rule
                       for identifying hazardous wastes was
                       promulgated by the Agency on March
                       29,1990 (55 FR11798), was amended
                       on June 29,1990 (55 FR 26986), and
                       became effective on September 25,1990.
                       The rule replaced the Extraction
                       Procedure (EP) leach test with the
                       Toxicity Characteristic Leaching
                       Procedure (TCLP), added 25 organic
                       chemicals to the list of toxic
                       constituents of concern, and established
                       regulatory levels for these organic
                       chemicals.
                         The overall effect of the TC rule was
                       to subject additional solid wastes to
                       regulatory control under the hazardous
                       waste provisions of subtitle C of RCRA.
                       Under this rule, a waste may be  a
                       hazardous waste if any chemicals listed
                       in the rule, such as benzene, are present
                       in leachate from the waste (generated
                       from use of the TCLP) at or above the
                       specified regulatory levels. Management
                       of such hazardous waste is subject to
                       stringent RCRA subtitle C controls.
                       B. The UST Deferral
                         Among the wastes that could be TC
                       wastes are petroleum contaminated
                       media and debris. At the time of
                       promulgation of the final TC rule, the
                       Agency made a determination to
                       temporarily defer applicability of the TC
                       rule to media and debris (e.g., soils and
                       groundwater) contaminated with
                       petroleum from underground storage
                       tanks (USTs) that are subject to the
                       corrective action requirements of
                       subtitle I of RCRA. 55 FR 11862  (March
                       29,1990), as amended 55 FR 26986
                       (June 29,1990). The deferral was
                       limited to the 25 newly listed organic
                       chemicals under the TC (i.e., Hazardous
                       Waste Codes D018 through D043 only).
                       See40CFR261.4(b)(10).
                         The deferral was the result of  several
                       factors. See 55 FR 11836 (March 29,
                       1990). Because the potential impact of
                       the TC on materials generated from UST
                       cleanups did not become apparent until
                       very late in the rulemaking process, at
                       the time of promulgation of the final TC
rule, the Agency had little information
regarding the full impact of the TC rule
on UST cleanups, particularly regarding
the amount of contaminated media that
would become hazardous waste and the
type of management feasible and
appropriate for such waste. However,
available information suggested that the
impact of applying subtitle C to UST
cleanups might be severe in terms of the
administrative feasibility of both the
subtitle C and subtitle I programs. A
preliminary assessment indicated that
the number of UST cleanup sites and
the amount of media and debris at each
site that would exhibit the toxicity
characteristic could be extremely high,
with EPA expecting hundreds of
thousands of UST releases to be
identified in the next few years. The
Agency believed that subjecting all, or
even a portion, of these sites to subtitle
C requirements could overwhelm the
hazardous waste permitting program
and the capacity of existing hazardous
waste treatment, storage,  and disposal
facilities.
  In addition, EPA believed that
imposition of the requirements could
delay UST cleanups significantly,
require an enormous new commitment
of Federal and  State resources, and
undermine the State and  local focus of
the UST program. All of these factors
suggested that EPA needed additional
time to determine with more certainty
what the impacts of the TC would be on
UST cleanups before subjecting such
materials to hazardous waste
requirements. In addition, EPA needed
time to investigate whether regulatory
changes could be made to RCRA subtitle
C regulations to allow appropriate
integration of the two programs. EPA
also believed that the UST regulations
governing cleanup at these sites would
be adequate to  protect human health
and the environment in the interim,
until a final determination was made
regarding the regulation of UST wastes.
  in the preamble explaining the need
for the deferral, EPA committed to
undertaking several studies and
meetings in order to make a final
determination concerning the regulation
of these UST wastes under the subtitle
C program. Since the temporary deferral
was published  on March  29,1990, EPA
has conducted several studies and held
meetings with interested  members of the
public regarding the temporary deferral
and the anticipated effects of regulating
UST petroleum-contaminated media
and debris as hazardous wastes under
subtitle C of RCRA. EPA  recently
published a Notice of Data Availability
summarizing the findings of these
studies and the results of the public
meetings. 55 FR 36866 (August 14,
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      1992). Comments received in response
      to the Notice of Data Availability will
      also be used by the Agency in making
      its final determination regarding the
      permanent regulatory status of UST
      petroleum-contaminated media and
      debris as hazardous waste under RCRA
      subtitle C.

      II. Explanation of Today's Proposal
        Today's action proposes to exempt
      contaminated media and debris, that are
      generated from petroleum UST
      corrective actions that are subject to
      subtitle I of RCRA, from certain portions
      of the RCRA Toxicity Characteristics
      rule. The exemption would be limited to
      the 25 newly listed organic chemicals
      under the TC rule (i.e., Hazardous Waste
      Codes D018 through D043 only).
     -  The proposed action would oe
      accomplished by maintaining the
      language contained in the current
      temporary deferral for UST petroleum-
      contaminated media and debris, found
      at 40 CFR 261.4(b)(10). This deferral
      currently reads as follows:
      Section 261.4 Exclusions
      *****
       (b) Solid wastes which are not hazardous
      wastes. The following solid wastes are not
      hazardous wastes:
      *****
       (10) Petroleum-contaminated media and
      debris that fail the test for the Toxicity
     Characteristic of section 261.24 (Hazardous
     Waste Codes D018 through D043 only) and
     are subject to the corrective action
     regulations under part 280 of this chapter.
       If EPA issues the final determination
     as it is being proposed today, the
     current language of the deferral would
     remain unchanged. Each of the
     individual elements of the proposal is
     discussed in more detail below.

     A. Contaminated Media and Debris
       The term contaminated media
     includes naturally-occurring materials
     such as soil, groundwater, surface water,
     and air that have become contaminated
     with substances released from
     petroleum underground storage tanks.
       The term debris means solid material
     exceeding  60 mm (2.5 inch) particle size
     that is: (1) A manufactured object; or (2)
     plant or animal matter; or (3) natural
     geologic material. This term is defined
     by EPA at 40 CFR 268.2(g). See 57 FR
     37270 (Aug. 18, 1992). The definition of
     debris includes material that is plant or
     animal matter such as grass, trees, and
     stumps; or is natural geologic material
     such as rocks and boulders; or is a solid,
     man-made material such as concrete,
     buried tires, buried empty drums, as
     well as empty  petroleum USTs and
     empty piping that are present at the site.
     Included in this term are the UST and
 piping from which the petroleum
 substance was released, provided they
 are empty in accordance with EPA's
 closure regulations for underground
 storage tanks. 40 CFR 280.70(a) of these
 regulations defines an UST system to be
 empty when "no more than 2.5
 centimeters (one inch) of residue, or 0.3
 percent by weight of the total capacity
 of the UST system, remain in the
 system."

 B. Petroleum UST Corrective Actions
   Under today's proposal, contaminated
 media and debris are exempted if
 "subject to the corrective action
 regulations" under 40 CFR part 280.
 EPA interprets this to include all media
 and debris generated in response to
 known or suspected releases from a
 petroleum UST system. The term
 "petroleum UST system" is defined in
 EPA's UST regulations at 40 CFR
 280.12. Responses to releases from
 petroleum UST systems are covered by
 EPA's UST regulations at 40 CFR part
 280 under subpart E—Release
 Reporting, Investigation, and
 Confirmation, and subpart F—Release
 Response and Corrective Action for UST
 Systems Containing Petroleum and
 Hazardous Substances.
   The proposed exemption also
 includes contaminated media and
 debris discovered as a result of routine
 petroleum UST closures, UST site
 assessments, and UST replacements.
 The rationale for this approach is that
 the discovery of contamination when
 performing these routine activities
 requires reporting under EPA's UST
 regulations, as the contamination
 represents a known or suspected release
 from an UST. See 40 CFR 280.50. Such
 releases are subject to subparts E and F
 of EPA's UST regulations, referenced
 above.

 C. Subtitle I of RCRA
   Today's proposal applies only to
 contaminated media and debris from
 petroleum USTs that are subject to the
 corrective action regulations under
 subtitle I of RCRA (40 CFR part 280.60-
 280.67). Contaminated media and debris
 from non-subtitle I regulated sources
 (e.g., above ground tanks; farm and
 residential motor fuel USTs of 1100 or
 less gallons capacity) are not included
 in the proposed exemption. These
 materials, however, are the subject of a
 separate proposed rulemaking by the
 Agency. This separate rulemaking is
 discussed elsewhere in today's
preamble.
  USTs storing heating oil for
consumptive use on the premises where
stored are not regulated under subtitle I
and,  thus, are not covered by the
 proposed exemption. However,
 contaminated media and debris
 generated from residential heating oil
 tanks are "household wastes" under 40
 CFR 261.4(b)(l). Under EPA's subtitle C
 regulations, household wastes are solid
 wastes but are excluded from
 consideration as hazardous wastes.
 Thus, contaminated media and debris
 from residential heating oil tanks are not
 hazardous wastes under subtitle C of
 RCRA.

 D. Request for Comments
   EPA requests commenters to indicate
 their support or opposition, with
 supporting rationale, to the proposed
 exemption for UST petroleum-
 contaminated media and debris as
 described in the preceding paragraphs.
 hi particular, EPA is interested in
 comments addressing whether the scope
 of the proposed exemption is
 appropriate, or whether it should be
 broadened or narrowed. EPA is also
 interested in any analytical test data that
 indicate the concentration of the TCLP
 constituents in petroleum UST-
 contaminated media and debris. EPA
 also requests comments on alternatives
 to the exemption proposed today, which
 are discussed below.

 E. Other Options Considered

 1. Expansion of the Exemption to all TC
 Contaminants
   When the temporary deferral was
 clarified in June, 1990, it was limited to
 the 25 newly listed organic
 contaminants under the 1990 TC rule.
 The deferral does not apply to the
 original 14 contaminants identified
 under EPA's 1980 Extraction Procedure
 (EP) toxicity characteristic rule. The
 contaminants regulated under the EPTC
 are arsenic, barium, cadmium,
 chromium, lead, mercury, selenium,
 and silver, as well as endrin, lindane,
 methoxychlor, toxaphene,  2,4-D, and
 2,4,5-TP silvex. The deferral was limited
 only to the new contaminants because
 the issue of the relationship between
 hazardous waste rules and UST
 cleanups came to the Agency's attention
 during the development of the TC
 rulemaking, and was a result of the
 regulation of new constituents under
 that rule.
   Since the original 14 contaminants
 were not part of the temporary deferral,
 generators are currently obligated to
 make a determination of whether the
 petroleum-contaminated media and
 debris would be hazardous for the
 original 14 constituents. Generators are
allowed to make the determination
either by subjecting the materials to the
TCLP, or "applying knowledge of the
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Federal  Register  /  Vol.  58,  No. 28  /  Friday, February 12, 1993 / Proposed Rules
     hazard characteristic of the waste in
     light of the materials or the processes
     used" (40 CFR 262.11(c)).
       EPA believes it may also be
     unnecessary to require a hazardous
     waste determination for the 14 EP
     contaminants. As discussed in the
     preamble to EPA's underground storage
     tank regulations on September 23,1988
     (53 FR 37189), information the Agency
     had at that time from several States
     indicated it was highly unlikely that
     UST petroleum-contaminated soils
     would exhibit the characteristic of EP
     toxicity, even for lead that may have
     resulted from releases of leaded
     gasoline. Further, with the phase-out of
     leaded gasoline, it would seem even less
     likely for contaminated media and
     debris resulting from more recent
     releases  of gasoline to exhibit the
     Toxicity Characteristic for lead. Thus,
     inclusion of these contaminants in the
     exemption would appear to have no
     impact on  protection of human health or
     the environment, and testing for these
     contaminants appears unnecessary.
       In addition, including these
     contaminants in the exemption will
     result in cost savings in the form of
     avoided TCLP sampling and analysis
     costs because owners and operators
     would no longer be required to
     determine whether petroleum
     contaminated media and debris exhibits
     the Toxicity Characteristic. If UST
     owners make this determination
     through  TCLP testing of the materials,
     rather than applying some form of
     "knowledge" about them, laboratory
     analytical  costs can range from a few
     hundred to more than a thousand
     dollars per sample. Since several
     samples of the contaminated media and
     debris would likely be necessary in
     order to  adequately characterize the
     contamination at a particular site, the
     savings in  sampling and analysis costs
     could amount to several thousand
     dollars per facility. These cost savings
     could be used to pay for proper
     management of the contaminated media
     and debris, rather than for unnecessary
     sampling and laboratory analyses.
       Therefore, the Agency is interested in
     obtaining comments from the public
     regarding whether the final rule for the
     exemption should include these
     contaminants. EPA is particularly
     interested  in commenters' rationale for
     including  these contaminants within the
     exemption, and in any supporting data
     that indicate the concentration of these
     contaminants in petroleum UST-
     contaminated media and debris.
                        2. Expansion of the Exemption to Other
                        Hazardous Waste Characteristics
                          EPA considered, but has tentatively
                        rejected, proposing to expand the
                        exemption for UST petroleum-
                        contaminated media and debris to the
                        other three characteristics of hazardous
                        waste, in addition to the Toxicity
                        Characteristic. These three
                        characteristics are Ignitability,
                        Corrosivity, and Reactivity. See 40 CFR
                        260.20-260.23. EPA generally believes
                        that UST petroleum-contaminated
                        media and debris are unlikely to exhibit
                        these characteristics and, thus, would be
                        unlikely to be regulated as hazardous
                        waste because of these characteristics.
                        However, in the event that UST
                        petroleum-contaminated media and
                        debris were to exhibit one of these
                        characteristics, improper management
                        of the media or debris could pose severe
                        acute human health or environmental
                        impacts. The Agency believes that the
                        potential for such acute impacts
                        warrants management of contaminated
                        media and debris as hazardous waste, in
                        the unlikely event that these materials
                        exhibit one of these three
                        characteristics. EPA is interested in
                        public comments on this aspect of
                        today's proposal.

                        3. Subtitle I Management Standards for
                        Contaminated Media and Debris
                          Another option considered by EPA in
                        lieu of regulation under subtitle C was
                        to develop Federal management
                        standards under subtitle I for the
                        treatment and disposal of UST
                        petroleum-contaminated media and
                        debris. Such management standards
                        may provide a greater degree of
                        certainty regarding the ultimate
                        disposition of these materials than the
                        current subtitle I regulatory structure,
                        while avoiding the problems associated
                        with regulating these materials under
                        subtitle C. This approach, however,
                        would reduce the flexibility that the
                        States currently have in terms of
                        establishing technology requirements,
                        cleanup  standards, and oversight
                        processes that they consider adequate
                        and appropriate for management of
                        these materials.
                          This approach would also tend to
                        inhibit the development of innovative
                        technologies for remediation of these
                        materials. The Agency is currently
                        promoting the use of innovative
                        technologies for cleanups and the
                        streamlining of State corrective action
                        procedures, in an effort to improve the
                        effectiveness and efficiency of corrective
                        actions. Establishing Federal
                        management standards for UST
                        petroleum-contaminated media and
debris could limit the effectiveness of
these efforts.
  Establishing new regulations under
subtitle I would likely require States to
enact new legislation or regulations to
be "no less stringent" than the Federal
requirements in order to obtain approval
of their State UST program to operate in
lieu of the Federal program. This could
cause administrative problems for those
States that have already received
approval of their State UST program
from EPA, as well as delay those that are
far along in the approval process.
  EPA is interested in comments on this
issue, particularly regarding the scope
and content of potential Federal
management standards for UST
petroleum-contaminated media and
debris under subtitle I. EPA is interested
in comments regarding the usefulness
and desirability of such Federal
standards, in view of existing State UST
corrective action and solid waste
management programs.

III. Basis for Today's Proposal

A. Purpose and Legal Basis
  The primary purpose of today's action
is to allow corrective action, including
management of petroleum-contaminated
media and debris, to occur under the
authority of subtitle I of RCRA rather
than under overlapping requirements of
both subtitle C and subtitle I. Subtitle I
contains comprehensive requirements
for the reporting and cleanup of soil and
groundwater contamination from
petroleum USTs. Further, subtitle I
requires that treatment or  disposal of
soils be conducted in compliance with
applicable State and local requirements.
See 40 CFR 280.62.
  Subtitle I requirements are primarily
implemented by each of the individual
States and Territories, under provisions
of subtitle I State Program Approval
regulations, or under Memoranda of
Agreement with EPA in States whose
programs have not yet been approved by
EPA. In the case of an approved State,
EPA has deemed the State's UST
program to be "no less stringent" than
the Federal subtitle I program. In a State
operating under a Memorandum of
Agreement with EPA, the  State is
implementing the subtitle I regulations
on behalf of EPA. EPA retains the
authority to implement the
requirements, where necessary, ;n
unapproved States. In either case, the
UST program is protective of human
health and the environment, despite
differences in specific corrective action
procedures or approaches that may exist
between States.
  EPA believes that States are in the
best position to oversee management of
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                                                                      8507
      the approximately 50,000 new UST
      releases identified each year. As
      discussed below, EPA studies confirm
      that State agencies are currently
      managing UST petroleum-contaminated
      media and debris in a manner that
      protects human health and the
      environment. Thus, it is unnecessary to
      subject these materials to management
      as hazardous wastes under subtitle C of
      RCRA.
        Section 1004 of RCRA defines a
      "hazardous waste" as a solid waste
      which may pose a substantial threat
      "when  improperly * *  * managed." In
      addition, section 3001 of RCRA
      authorizes EPA to determine whether
      subtitle C regulation is appropriate in
      determining whether to designate a
      waste as "hazardous." EPA thus may
      determine that subtitle C regulation is
      not appropriate because such wastes are
      not "hazardous" when properly
      managed and, based on existing
      regulatory programs, would not be
      mismanaged. Under this approach,
      regulation of UST petroleum-
      contaminated media and debris under
      subtitle C is not necessary to protect
      human  health and the environment, due
      to the presence of the Federal subtitle I
      regulations for underground storage
      tanks and the UST programs that are
      active in each of the States.
        EPA is also concerned about the
      implementation and risk impacts
      associated with subjecting some or all
      aspects of petroleum UST cleanups to
      subtitle C. As discussed in more detail
      below, EPA believes that the findings of
      its studies and the information received
      during the course of meetings with
      interested members of the public
      support today's proposal for a final
      determination to make permanent the
      current temporary deferral for UST
      petroleum-contaminated media and
      debris.
      B EPA's Studies
       The findings of the Agency's studies
      corroborate the preliminary assessment
      that EPA made at the time of
      promulgation of the temporary deferral.
      Specifically, the findings of EPA's
      studies  indicate that removing the TC
      deferral would significantly affect UST
      cleanup procedures, delay remedial
      actions, and increase soil remediation
      costs. Further, delays in site
      remediation caused by compliance with
      subtitle  C requirements could increase
      health and environmental risks prior to
      cleanup.
       In addition to findings concerning the
      impacts of removing the deferral, these
      studies also indicate that many States
      have programs in place to adequately
      regulate the management of UST
 petroleum contaminated media and
 debris. The vast majority of these State
 programs address in some manner the
 entire cycle of UST petroleum
 contaminated soils and groundwater
 management, from initial
 characterization through storage and
 ultimate treatment or disposal,
 1. Technical Study
   The Agency has made available for
 public comment a draft report titled "TC
 Study of Petroleum UST Contaminated
 Media and Debris." This report is
 organized as follows:
   • Estimates of the amounts of UST
 petroleum contaminated soils that might
 be expected to exhibit the hazardous
 waste characteristic of toxicity if
 subjected to the TCLP test,
   • Impacts on hazardous waste
 capacity nationwide if these materials
 required management as a hazardous
 waste,
   • State management practices for
 petroleum contaminated soils from
 USTs,
   • Overview of technologies currently
 used  for management of petroleum
 contaminated soils and groundwater,
 and
   • Impacts on the RCRA subtitle I and
 C programs of removing the temporary
 deferral.

 2. Impacts Study
   The Agency has also made available
 for public comment a draft report titled
 "The Impacts of Removing the TCLP
 Deferral for Petroleum-Contaminated
 Media at Underground Storage Tank
 Sites." This report is organized as
 follows:
   • Procedural impacts of removing the
 deferral with regard to changes that
 would be required in cleanup
 procedures, technologies and the pace
 of UST corrective  actions,
   • Cost impacts of removing the
 deferral, both to the regulated
 community, as well as EPA and States,
 and
  • Preliminary assessment of health
 risk impacts associated with removing
 the temporary deferral.
 3. Study Findings
  As stated previously, EPA believes
that these study findings support a final
determination to make permanent the
current temporary deferral for UST
petroleum contaminated media and
debris. The primary study findings that
serve as a basis for making the deferral
permanent are summarized below.
  a. Procedural impacts.  Removal of
the deferral would result in substantial
delays in UST cleanups due to the
necessity of issuing a RCRA permit, by
 EPA or authorized States, for cleanups
 that involve treatment of TC-hazardous
 contaminated media on site (other than
 treatment that occurs on site in tanks in
 less than 90 days, or other units exempt
 from permitting). EPA's studies estimate
 that approximately 10% to 20% of the
 soil contaminated at a petroleum UST
 release may exhibit the Toxicity
 Characteristic. A significant
 consideration, however, is that this
 percentage contamination may exist at
 the majority of UST release sites, which
 currently average about 50,000 new
 release sites identified each year. EPA's
 studies indicate that on-site treatment of
 soils currently occurs at at least 20% of
 the UST soil remediation sites, with the
 trend increasing toward additional on-
 site treatment of soils. The situation
 with regard to groundwater
 contamination is also an important
 consideration. Virtually all treatment of
 petroleum-contaminated groundwater at
 UST release sites is performed on site.
 Although some of the groundwater
 treatment techniques may be exempt
 from RCRA permitting requirements,
 others would not be exempt.
  Delays in UST cleanups would occur,
 in part, due to the tremendous increase
 in the number of permit applications for
 UST cleanups that would likely have to
 be handled with current Federal or State
 RCRA subtitle C permitting staff
 resources. It takes approximately one to
 four years, at current workload levels, to
 issue a RCRA subtitle C permit. Further,
 in States not yet authorized under
 subtitle C for the TC portion of the
 regulatory program, EPA alone would be
 responsible for issuance of permits.  The
 substantial delays discussed above
 would allow subsurface contamination
 to continue and spread, increasing the
 costs of remediation, and increasing the
 potential for ground water
 contamination and for additional
 receptors to be affected.
  Removal of the deferral would result
 in significant changes in the UST
 corrective action process. The current
 subtitle I remedial decision-making
 process is relatively simple and
 straightforward, compared to the more
 complex process associated with
 managing contaminated media and
 debris as hazardous waste. One example
 of the increased complexity of
 implementing remedial measures for
 hazardous waste would be the need to
 evaluate on-site versus off-site options
 for the management of the material. This
would include identifying RCRA
 permitted treatment, storage, or disposal
 (TSD) facilities that would accept the
waste, balancing transportation and off-
site disposal costs with on-site
management costs, and formal
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Federal Register / Vol. 58, No.  28 / Friday, February 12, 1993 / Proposed Rules
     consideration of the risks and benefits of
     on-site versus off-site management.
       If the TC deferral were eliminated, the
     flexibility EPA currently allows States
     in the choice of cleanup technologies
     would be significantly reduced. For
     example, based on the current subtitle C
     regulations, UST owners and operators
     would likely be limited, in practice, to
     a choice of three cleanup options: (1)
     Excavate and send contaminated soil
     off-site to RCRA subtitle C permitted
     hazardous waste treatment, storage, or
     disposal facilities, (2) treat soils on-site
     in less than 90 days in a tank, in
     accordance with subtitle C tank
     generator and accumulation regulations,
     or (3) become a permitted TSD facility,
     thereby allowing on-site treatment of the
     petroleum contaminated media and
     debris.
       With regard to the above management
     scenarios under subtitle C, the Agency
     is not aware of any currently used
     cleanup technologies that would
     involve the treatment of large volumes
     of petroleum-contaminated soils on site
     in tanks for less than 90 days. Thus, this
     appears to be an unlikely management
     alternative. As for obtaining a RCRA
     TSD permit, two States have estimated
     owner/operator administrative costs to
     obtain a TSD permit for petroleum
     release sites ranging from  $21,000 to
     $80,000. Because of the delays and
     relatively high cost of a subtitle C TSD
     permit, which would be required for
     many on-site remediations of hazardous
     waste, petroleum contaminated soil
     management and disposal is more likely
     to be conducted off-site if it were
     considered hazardous waste. Since
     disposal in a subtitle C landfill is
     generally less expensive than subtitle C
     incineration, the Agency believes that
     for the majority of sites, the practical
     result of regulating UST petroleum-
     contaminated media and debris as
     hazardous waste would be the
     excavation and disposal of these
     materials in subtitle C landfills. This
     option, however, may be limited in
     time. When the TC land disposal
     restrictions are promulgated,
     incineration or other forms of treatment
     would likely be required for these
     materials prior to disposal, if they were
     considered hazardous waste.
       On the contrary, the flexibility
     afforded under subtitle I for managing
     UST petroleum-contaminated media
     and debris as non-hazardous allows for
     the use of a much broader spectrum of
     management options for these materials,
     such as aeration, low temperature
     thermal treatment, soil vapor extraction,
     and bioremediation. While there is
     currently variation between states in the
     Subtitle I soil technologies commonly
                        used, the majority currently rely on
                        excavation and relatively simple
                        treatment and disposal methods. The
                        trend during the past several years,
                        however, and EPA's preferred approach
                        to management of these materials, is to
                        treat them on site, in situ, i.e., without
                        excavation or transportation off-site.
                          Since the Agency believes that, in
                        most cases, the practical result of
                        regulating UST petroleum-contaminated
                        media and debris as hazardous waste at
                        this time would be the excavation and
                        disposal of these materials in subtitle C
                        landfills, this would adversely affect the
                        Agency's current efforts to promote the
                        use of innovative technologies for
                        treatment of these materials, particularly
                        those that can be used in situ, such as
                        bioremediation and soil vapor
                        extraction. In addition, EPA estimates
                        that landfilling of these materials at
                        subtitle C facilities would increase the
                        amount of waste going to these facilities
                        by 8 to 20 percent annually. Since the
                        Agency's studies confirm that these
                        materials are currently being managed
                        under subtitle  I State programs that are
                        protective of human health and the
                        environment, the Agency believes that it
                        would be more prudent to reserve the
                        nation's limited hazardous waste
                        landfill capacity for those wastes that
                        might otherwise be mismanaged, or for
                        which no equivalent subtitle I-type
                        program exists.
                          Although it is difficult to estimate the
                        precise pace at which UST remediations
                        would proceed when the contaminated
                        media and debris  is considered
                        hazardous waste, EPA's studies indicate
                        that they would take substantially
                        longer than cleanups currently managed
                        solely under subtitle I. Several factors
                        may contribute to the increased
                        duration of cleanups, such as more
                        extensive sampling and analysis
                        requirements, and increased complexity
                        of corrective action procedural
                        requirements, as described previously.
                          More important, however, than the
                        increased length of time needed to
                        perform the actual cleanup, are the
                        delays that would occur prior to the
                        beginning of corrective action,
                        particularly if the site requires
                        permitting. For example, permit
                        standards and  conditions are
                        established on a site-specific basis
                        under subtitle  C. In-situ soil vapor
                        extraction or bioremediation are
                        treatment approaches with which the
                        RCRA program has little permitting
                        experience to date, so  uncertainties exist
                        as to the most  appropriate permit
                        conditions for such cleanups. This
                        uncertainty is  likely to result in further
                        delays in issuing of permits for such
                        sites, as well as the imposition of
additional permit conditions that are
beyond the conditions typically
imposed by States under subtitle I.
  w addition to the permitting
requirements for the "regulated unit,"
i.e., the remediation unit where TC-
hazardous waste is treated, stored, or
disposed at the UST site, any existing
"solid waste management units," or
SWMUs, at the facility would have to be
cleaned up in accordance with RCRA
section 3004(u) corrective action
authorities and EPA's corrective action
guidance for permitted hazardous waste
TSD facilities. SWMUs at a typical UST
facility might include a used oil tank, a
trash disposal area, or an old drum
storage area, but include virtually any
portion of the property at which solid
waste has ever been managed. Cleanup
for these units under a RCRA TSD
permit would generally be to risk-based
levels, as determined on a site-specific
basis. See 55 FR 30798 (July 27,1990).
As part of the permit conditions, UST
owners or operators would be required
to undertake a RCRA Facility
Assessment, a RCRA Facility
Investigation, a Corrective Measures
Study and, finally, Corrective Measures
Implementation for any SWMUs at the
site. In addition, public participation
requirements apply prior to issuance of
each RCRA permit. This includes local
notice of the proposed permit action
and providing the public an opportunity
for public hearings on the permit. These
additional requirements add to delays in
the subtitle C permitting process and are
likely to severely discourage UST
owners from undertaking on-site, in-situ
cleanups. This result has also been
corroborated by an Agency study on
Corrective Action Management Units
(CAMUs). See 57 FR 48195 (October 22,
1992). The study indicates that applying
the hazardous waste land disposal
restrictions to remediation wastes
increases risks by causing less
treatment, and less on-site treatment in
particular, thereby increasing risks from
transport of hazardous waste and
leaving wastes in place without
treatment.
   An important consideration for UST
cleanups that would require  subtitle C
permitting is that cleanup cannot begin
until the permit is issued. The delays
associated with permit issuance will
allow contamination to continue
unabated, increasing the costs of
remediation and increasing the potential
for groundwater contamination and for
additional receptors to be affected.
   b. Risk impacts. EPA's studies
considered human health risk impacts
that potentially would result if the UST
petroleum-contaminated media deferral
were removed. The studies evaluated
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                    Federal  Register  /  Vol.  58,  No. 28 / Friday, February 12, 1993 / Proposed Rules         8509
      three components of health risk. The
      first component is interim risk, which is
      the health risk present at an UST site
      prior to remediation, including drinking
      water risks, and risks such as fire and
      explosions, and inhalation of vapors.
      Interim risk would be expected to rise
      significantly without the exemption,
      since permitting delays prior to
      remediation would allow increased
      migration of petroleum contaminants,
      thereby increasing exposure potentials
      forpopulations near the site.
        EPA also evaluated a second
      component of risk, known as residual
      risk. Residual risk is the health risk
      remaining at the site following soil and
      groundwater remediation. EPA's studies
      indicate that residual risk would likely
      remained unchanged, i.e., neither
      increased nor decreased, by removal of
      the deferral and regulation of UST
      petroleum-contaminated media and
      debris as hazardous waste. This is due
      to the fact that the Toxicity
      Characteristic is not relevant to residual
      risk, because it is not a cleanup
      standard. Rather, the TC and associated
      subtitle C regulations impose
      requirements on how the waste
      generated from a cleanup can be
      managed. The soil and groundwater
      cleanup standards for the UST portion
      of the remediation is likely to be
      identical either with or without the
      exemption being proposed today.
       The remaining component of risk, the
      treatment/disposal risk, relates to the
      exposure potential associated with
      treatment or disposal of contaminated
      soil and groundwater. The effect of
      removing the deferral on this element of
      risk is ambiguous. Different subtitle I
      and subtitle C technologies imply
      increased exposure potential, while
      others imply decreased potential. For
      example, in general, leak protection and
      subsurface monitoring at subtitle C
      landfills is generally superior to that at
      subtitle D landfills, where UST
      petroleum-contaminated soils may be
      disposed of in certain States. Thus,
      health risk potential is likely reduced by
      disposal in a subtitle C landfill versus
      subtitle D. In other cases, however,
      thermal treatment of subtitle I soils
      would provide more rapid contaminant
      destruction than subtitle C landfilling.
      Under this scenario, this type of
      treatment would likely pose less risk
      than subtitle C disposal.
       A further risk consideration involves
      the transport of contaminated soils.
      When soils are hauled over long
      distances, as would more likely be the
      case if they required management as
      hazardous waste and were excavated for
      off-site landfilling or incineration, the
      potential for accidental releases of
 contaminants is increased. Many States
 lack commercial subtitle C capacity to
 manage these materials, so transport
 over long distances is likely. In contrast,
. subtitle I treatment often occurs on site,
 as indicated in EPA's studies. Off-site
 treatment and disposal under subtitle I
 is typically accomplished within the
 State, resulting in far less hauling
 distances for the contaminated soils
 and, thus, less risk due to
 transportation.
   c. Cost Impacts. EPA's study findings
 indicate that per-site remediation costs
 under subtitle C would be substantially
 higher than those currently incurred
 under subtitle I. As discussed
 previously, as a practical matter, the
 techniques that would likely be used in
 managing UST petroleum-contaminated
 media and debris as hazardous waste
 would be more limited than those
 currently used under subtitle I. For the
 majority of cases, it is likely that
 excavation  followed by subtitle C
 landfilling or incineration would occur.
 For sites involving soil management
 only, the studies indicate that typical
 subtitle C costs may range from two to
 15 times or more higher than the costs
 of cleanup under subtitle I. The primary
 source of this increase is the relative
 expense of the likely subtitle C soil
 management approaches compared to
 those currently used under subtitle I.
 The broad range of the increase is
 dependent upon the subtitle C approach
 selected by the UST owner or
 necessitated by site conditions.
   For example, unit costs for subtitle I
 thermal treatment of soils in one State
 average  $55 per cubic yard, compared to
 $1060 for subtitle C incineration and
 $510 for subtitle C landfills. Assuming
 management of 150 cubic yards of soil,
 subtitle  I costs would be $8250,
 compared to $76,500 for subtitle C
 landfilling and $159,000 for subtitle C
 incineration.
   As a direct result of this increase in
 per-site cleanup costs, the removal of
 the deferral would result in significant
 nationwide increases in annual UST
 remediation costs. The range of possible
 subtitle C management approaches and
 soil and groundwater remediation
 technologies makes it difficult to predict
 the size of the increases. However,
 based on reasonable assumptions about
 the likely mix of technologies selected,
 EPA's studies indicate national cost
 increases may range from $1.9 billion to
 $4.0 billion in each of the first five years
 following removal of the deferral. These
 estimates represent an 81 percent to 108
 percent increase over current subtitle I
 projected cleanup costs.
   Based on the discussion of risk
 impacts previously, such cost increases
 are unnecessary in achieving adequate
 protection of human health and the
 environment. Further, if hazardous
 waste permitting of UST cleanups
 occurred, there would likely be a
 decrease in the protection currently
 provided under subtitle I UST programs,
 but at an increased cost.
 C. Public meetings
  In the preamble to the 1990 TC rule,
 EPA also stated its intention to convene
 a public forum to discuss the issues
 associated with regulating UST
 petroleum-contaminated soils and
 debris under subtitle C of RCRA. To
 fulfill this commitment, in September
 and December, 1991, EPA convened
 several  meetings with various interested
 parties  (including representatives from
 the States, Congressional  staff,
 environmental groups and the waste
 treatment and waste generating
 industries] to discuss issues related to
 the cleanup of petroleum  contamination
 from UST as well as non-UST sources,
 and the potential impacts of the TC rule
 on these cleanups.
  The thirteen States attending these
 meetings expressed significant  concern
 about the adverse environmental
 impacts resulting from the application
 of the TC rule  to petroleum UST
 releases. The State representatives
 indicated that regulation of petroleum
 contaminated media and debris as '
 hazardous waste would significantly
 increase the cost of cleanup of these
 releases, substantially delay cleanup,
 and in some cases (by delaying cleanup)
 negatively impact human health and the
 environment.
  A number of States have funds that
 provide a significant portion of the
 cleanup costs for petroleum UST
 releases. According to these States, if
 petroleum contaminated media and
 debris are regulated as hazardous
 wastes,  the resulting dramatic increases
 in costs of waste management would
 significantly impair the ability of the
 State to  pay for future cleanups. Further,
 if there is no guarantee that payment
 will be forthcoming, several States
 believe that many responsible parties
 and their cleanup contractors will be
 much less willing to report and respond
 promptly to releases. The  net result,
 according to these States, will be that
 fewer sites will be remediated and
 remediations will be delayed, thus
 increasing the migration of
 contamination off-site, and in turn
 negatively impacting human health and
the environment.
  In the view of many States, the delays
associated with RCRA subtitle C
management would allow for
volatilization and migration of certain
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     TC constituents, such as benzene, prior
     to cleanup. These States point to RCRA
     testing and permitting as significant
     sources of delay. In addition, States
     cautioned EPA to recognize that,
     because of the high costs associated
     with subtitle C management, there
     would be a significant disincentive to
     promptly report and undertake
     corrective action for petroleum releases.
     They explained that UST owners may
     instead purposely allow the waste to
     volatilize until it no longer exhibits the
     toxicity characteristic, thus rendering it
     non-hazardous.
       Groups representing the waste
     generating industries (e.g., petroleum
     and petrochemical industries) at the
     meetings generally agreed with the
     views being expressed by the States,
     although several stated that the
     problems associated with applying
     subtitle C standards to remediations
     were not unique to petroleum
     contaminated media.
       Environmental group representatives
     acknowledged the importance of these
     problems, but saw the issue as similar
     to other claims that regulations deter
     effective corrective actions. The
     environmental group representatives
     agreed on the merits of streamlining the
     subtitle C administrative processes and
     procedures (e.g., RCRA subtitle C
     permitting, as discussed later in this
     notice), but felt that regulatory control
     was necessary to ensure environmental
     safety. The environmental group
     representatives also argued that the
     important benefits of a RCRA permit,
     particularly public involvement and
     facility-wide corrective action, would be
     lost if EPA adopted the approach
     suggested by the States, i.e., making the
     UST deferral permanent.
       Certain representatives of the
     hazardous waste treatment industry
     expressed strong concerns with
     exemption from the TC rule as the
     mechanism for solving the
     implementation problems posed by
     subtitle C regulation of petroleum
     contaminated media and debris.
     According to these representatives, EPA
     should consider streamlining the RCRA
     permitting process for the cleanup and
     disposal of petroleum contaminated
     media and debris. They specifically
     suggested that EPA consider issuing
     permits-by-rule for petroleum
     contaminated media and debris, as well
     as for other cleanup wastes. They also
     expressed concern that the UST deferral
     effectively exempts petroleum
     contaminated media and debris from the
     RCRA technical standards, in particular
     the land disposal restrictions. Other
     representatives of the waste treatment
     industry however, supported the
deferral and favored expanding it to
other cleanup wastes.
  A complete summary of these
meetings is in the docket for this
rulemaking. The various viewpoints
expressed in these meetings will be
considered as part of EPA's final
decisionmaking concerning the deferral.
IV. Regulatory Alternatives Under
Subtitle C
  The studies indicate that subjecting
petroleum UST cleanups to the full
range of subtitle C regulations would
have significant adverse impacts.
However, in the context of other
previous rulemakings, EPA has explored
the concept of alternative, ostensibly
more streamlined, types of RCRA
regulatory approaches that could be
used to expedite cleanups. Some of
these alternatives  are discussed below.
EPA is interested in comments from the
public on the efficacy of using these
approaches in dealing with UST
petroleum-contaminated media and
debris under subtitle C of RCRA as an
alternative to the exemption being
proposed today.
  One alternative  is reflected in the
proposed rulemaking for mobile
treatment units (52 FR 20914, June 3,
1987). Thermal treatment of UST
petroleum contaminated soils, often in
mobile thermal treatment units, is an
innovative soil treatment technology
that is increasing in use. The  primary
legal impediments to obtaining  this type
of "streamlined" permit for UST
corrective actions  under subtitle C are
the need to provide for site specific
public participation (as required under
RCRA 7004), and the requirement to
address  facility-wide corrective action
(under RCRA 3004(u)). Given that any
treatment permit would have to address
these statutory requirements,  and that
doing so would require a considerable
time and resource commitment  on the
part of the issuing government
agency(s), as well  as the permittee, it
may be that creating this type of permit
for UST petroleum cleanup situations
would actually have little
"streamlining" effect.
  Another approach is the use of
emergency permits under Subtitle C of
RCRA as an alternative to full subtitle C
permitting. Emergency permits under 40
CFR 270.61 could  be used in  some
situations involving petroleum UST
releases. The problem is that  these
permits  are of such short duration (90
days) that they would not be useful for
extended cleanup  operations, or for sites
where cleanup is not being conducted
in response to an actual "emergency"
situation. Of the 112,000 UST cleanups
initiated that have been reported to EPA
by the States, only 5900 were
categorized as emergency responses.
  The concept of permits-by-rule has
been considered as a mechanism that
could alleviate the administrative
impacts of individually permitting
petroleum UST cleanups under subtitle
C, while maintaining the substantive
controls and standards (including the
land disposal restrictions) provided
under Subtitle C. However, as noted
above, Section 7004(b)(2) of RCRA
specifies that permits issued under
RCRA for hazardous waste facilities
must undergo a local hearing process.
Thus, the utility of "permits-by-rule"
may be limited under RCRA. See NRDC
v. EPA, 907 F.2d 1146 (DC Cir. 1990)
(remanding a hazardous waste permit-
by-rule).
  Even if the administrative problems
associated with issuing permits for
petroleum UST cleanups activities
could be resolved, additional problems
of regulating these cleanups under
subtitle C remain. For example, UST
owners or operators would have to
register as a hazardous waste generator
and obtain a generator identification
number if they are generating soils or
groundwater that exhibit the toxicity
characteristic. The thousands of
facilities each year that may be involved
in such transactions would impose
additional burdens on the issuing
agency, and likely add to delays in the
cleanup process. In addition, generators
of hazardous waste are required to
prepare and submit to EPA a biennial
report of their hazardous waste
generation activities, resulting in an
increased paperwork burden to the
regulated community, and additional
administrative costs to EPA to process
such reports.
  EPA requests comment on the legal
and technical defensibility of the above
regulatory alternatives for regulation of
these materials under RCRA subtitle C.
EPA is concerned that  some of the
alternatives either may present legal
concerns or fail to provide sufficient
flexibility to remedy the environmental
problems caused by regulating these
materials as hazardous waste. EPA also
requests suggestions concerning other
changes to the subtitle C regulations that
will allow EPA to regulate these
materials under subtitle C while at the
same time providing the flexibility to
avoid the counterproductive impacts of
subtitle C regulation of UST petroleum-
contaminated media and debris
discussed previously. EPA is also asking
for comment on these and other
regulatory alternatives in a related
rulemaking concerning non-UST
petroleum contaminated media and
debris.
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                                                                      8511
      V. Process for the Final Determination
        EPA will review and evaluate the
      public comments on the studies, public
      meetings, and this proposed rule as part
      of its decisionmaking concerning the
      regulatory status of UST petroleum-
      contaminated media and debris.
      Following review of all the public
      comments submitted on these notices,
      EPA will publish in the Federal
      Register its final determination
      regarding the regulatory status of UST
      petroleum-contaminated media and
      debris.

      VI. Relationship to Non-UST
      Petroleum-Contaminated Media and
      Debris
        In a separate action (57 FR 61542,
      December 24,1992) the Agency has
      proposed suspension of the TC rule for
      the 25 newly listed organic
      contaminants for three years for
      environmental media and debris
      contaminated by petroleum products
      released from sources other than RCRA
      subtitle I regulated USTs. This
      suspension has been requested by
      several States. During the suspension
      period, the Agency would collect
      additional data, perform additional
      analyses, and explore other
      administrative  and legal mechanisms to
      better tailor RCRA regulatory
      requirements to unique issues
      associated with remediation of non-UST
      petroleum releases.
        Persons who would like to submit
      comments to EPA regarding the separate
      action for media and debris
      contaminated by non-UST releases must
      do so by submitting comments
      specifically addressing that action, to
      the appropriate RCRA docket.
        The Agency believes it is appropriate
      to examine the application of the TC
      rule to petroleum contaminated media
      and debris from USTs and non-UST
      sources separately. Programs that
      regulate USTs and non-UST sources of
      petroleum contaminated media and
      debris can be distinct, with their own
      regulatory and administrative
      structures. Hence, the impacts of the TC
      rule on UST and non-UST cleanups can
      differ. For this reason, the ultimate
      determinations as to how to regulate
      UST and non-UST petroleum
      contaminated media and debris could
      be different.
        Different exemptions, however, for
      very similar or identical types of waste,
      may be confusing to the regulated
      community and may pose challenges for
      the enforcement program. EPA is
      interested in obtaining comment from
      the public regarding whether and to
      what extent these two distinct
 exemptions should be made consistent
 or identical. Commenters may want to
 focus their attention on four differences
 in the non-UST proposal and today's
 proposal, discussed below.
   First, the exemption in the non-UST
 proposal is limited to petroleum-
 contaminated media and debris
 generated at sites that are the subject of
 a site-specific enforcement order or
 other written approval from the State.
 The Agency believes a similar provision
 is unnecessary in today's proposal, due
 to the existence of the Federal corrective
 action regulations for USTs under
 subtitle I of RCRA, and the existence of
 active UST regulatory programs in each
 State that provide oversight of UST
 corrective action activities.
   Second, the non-UST proposal limits
 the exemption to media and debris that
 are contaminated solely with petroleum
 product. The Agency believes a similar
 provision is unnecessary in today's
 proposal. Subtitle I of RCRA contains a
 well-defined universe of "petroleum
 UST systems" to which the exemption
 would apply. These petroleum UST
 systems are subject to the Federal UST
 corrective action regulations and the
 State programs discussed above,
 whether they contain petroleum product
 only, or other petroleum substances,
 such as used oil, in certain
 circumstances.
   Third, although not a part of the
 preferred option, the non-UST proposal
 solicits comment on whether to limit
 that exemption to releases of less than
 a specified size, e.g., less than 10,000
 gallons of released product. Larger spills
 might be subject to full subtitle C
 controls. While this provision may be
 appropriate for above ground spills
 where the quantity of released product
 can be more easily estimated, the
 Agency believes such a provision is
 unsuitable for releases from
 underground storage tanks, because it
 would be difficult, if not impossible, to
 ascertain the amount of material that
 had been released into the subsurface
 environment prior to the initiation of
 cleanup.
   Fourth, both proposals limit the
 exemption to the 25 newly listed TC
 constituents. However, the non-UST
 proposal solicits comment on further
 limiting the scope of the non-UST
 suspension only to those TC
 constituents which are known to be
 indigenous to petroleum product. The
 Agency is considering three
 contaminants in this regard under the
non-UST rule—benzene, cresols, and
methyl ethyl ketone. The Agency
believes such a limitation is
unnecessary in today's proposal,
however, because contaminated media
 and debris is exempt only if it is
 generated from a subtitle I petroleum-
 UST system, which is well defined. See
 40 CFR part 280.12. For example, a
 petroleum UST to which hazardous
 waste had been added would no longer
 be a subtitle I petroleum UST system
 (rather, it would be subject to subtitle C
 regulations). Thus, media and debris
 contaminated by releases from such a
 tank would not be exempt under today's
 proposal.

 VII. Effect on Subtitle C State
 Authorization
   Since today's proposal will, when
 finalized, make permanent the existing
 temporary exemption already contained
 in EPA's hazardous waste regulations,
 there would be no impact on State
 subtitle C hazardous waste programs,
 whether authorized by EPA for the TC
 or not. EPA did not require States to
 adopt the UST temporary deferral, nor
 would they be required to adopt the
 exemption being proposed today, when
 final, since this provision is less
 stringent than subjecting UST
 petroleum-contaminated media and
 debris to the full requirements of the TC
 rule.

 VIII. Regulatory Requirements

 A. Regulatory Impact Analysis
   Executive Order 12291 (46 FR 13193)
 requires that regulatory agencies
 determine whether a new regulation
 constitutes a "major" rulemaking and, if
 so, that a Regulatory Impact Analysis
 (RIA) be conducted. An RIA consists of
 the quantification of the potential
 benefits, costs, and economic impacts of
 a major rule. A major rule is defined in
 Executive Order 12291 as a regulation
 likely to result in: (1) An annual effect
 on the economy of $100  million or
 more; (2) a major increase in costs or
 prices for consumers, individuals,
 industries, Federal, State, or local
 government agencies, or geographic
 regions; or (3) a significant adverse
 effect on competition, employment,
 investment, productivity, innovation, or
 on the ability of United States based
 enterprises to compete with foreign
based enterprises in domestic or export
 markets.
  As discussed  elsewhere in this
preamble, EPA has estimated that
today's proposed rule will result
indirectly in significant cost savings, by
avoiding the increased costs that would
otherwise be associated with regulating
UST petroleum-contaminated media
and debris as hazardous waste. See
EPA's draft reports titled "TC Study of
Petroleum UST Contaminated Media
and Debris" and "The Impacts of
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     8512          Federal Register  /  Vol.  58, No. 28 / Friday, February 12, 1993 / Proposed Rules
     Removing the TCLP Deferral for
     Petroleum-Contaminated Media at
     Underground Storage Tank Sites" for
     documentation of these cost savings.
       Also, EPA does not believe the rule
     will significantly affect consumers,
     individuals, industries, Federal, State,
     or local government agencies, or
     geographic regions, or have significant
     adverse effects on competition,
     employment, investment, innovation, or
     international trade. Therefore, EPA has
     determined that today's proposed rule is
     not a major rule and that a Regulatory
     Impact Analysis is not required.
     B. Regulatory Flexibility Act
       Under the Regulatory Flexibility Act
     (RFA) of 1980 (Pub. L. 96-345),
     whenever a Federal agency publishes a
     notice of rulemaking for a proposed or
     final rule, it must prepare and make
available for comment a Regulatory
Flexibility Analysis that describes the
impact of the rule on small entities,
including small businesses, small
organizations, and small governmental
jurisdictions, unless the Agency head
certifies that the proposed action will
not have a significant economic impact
on a substantial number of small
entities.
  This proposal will provide significant
regulatory relief to businesses, including
many small businesses, faced with
corrective action as a result of releases
from petroleum USTs. Therefore,
pursuant to section 605(b) of the
Regulatory Flexibility Act, 5 U.S.C.
605(b), the Administrator certifies that
this rule will not have a significant
economic impact on a substantial
number of small entities.
C. Paperwork Reduction Act

  This rule does not impose any
additional reporting, recordkeeping, or
information collection requirements on
any member of the regulated public.
Therefore, no estimate of public
reporting burden is required for this
rule.

List of Subjects in 40 CFR Part 261

  Hazardous waste, Recycling,
Reporting and recordkeeping
requirements.
  Dated: January 20, 1993.
William K. Reilly,
Administrator.
[PR Doc. 93-3475 Filed 2-11-93; 8:45 am]
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