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46 Lawrence K. Wang et al.

Table 7
Standards Development Under Section 3004(n)
Phase I Total organics
Process vents and equipment leaks
Promulgated 6/21/90 (55 FR 25454)
Phase II Total organics
Tanks, surface impoundments, containers, and
miscellaneous units
Proposal package in OMB
Phase III Individual constituent standards, as needed to supplement
Phase I and Phase II standards
Early Work Group stage
Source: US EPA.

Waste Amendments and the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) as amended by SARA.
Most of the new air emission standards, discussed in this chapter, are being developed
under RCRA. As required under Section 3004(n), the US EPA Administrator is directed
to protect public health and welfare by establishing the standards for monitoring and
controlling the air emission from TSDFs. The implementation of these standards is
conducted under RCRA’s permitting systems for hazardous waste-management units.
The US EPA is developing the RCRA 3004(n) air standards under a three-phase
program, as shown in Table 7. Phase I develops the organic emissions standards from
process vents associated with specific noncombustion waste-treatment processes
(e.g., stream stripping and thin-film evaporation units). Additionally under this phase,
organic emissions standards are developed for equipment leaks from pumps, valves, and
pipe fittings. On June 21, 1990, the final standards for these sources were promulgated.
See Subparts AA and BB in the Code of Federal Regulations (CFR), Title 40, Parts
264 and 265 (40 CFR 264 and 265). Under Phase II, the organic emission from tanks,
surface impoundments, containers, and miscellaneous units are established. The pro-
posed standards for these sources were proposed in July 1991 and published in (new)
Subpart CC in 40 CFR, Parts 264 and 265. Even after the implementation of Phase I
and II organic standards, current analyses indicate a potential residual risk problem.
As a result, Phase III will develop individual constituent standards as necessary to
−4
bring the residual maximum individual risk to within acceptable range (10 −6 to 10 ).
Proposed Phase III standards are planned to be concurrent with promulgation of
Phase II standards.
Also established under RCRA is the Corrective Action Program, which requires
solid-waste-management units to go through a site-specific facility evaluation. Air
emissions must also be included in the site-specific evaluation and risk assessment.
Additionally, air emissions are affected by the land disposal restrictions (LDR), which
were promulgated under RCRA. Unless certain treatment requirements are met, LDR
prohibits the depositing of hazardous waste on or into land disposal sources such as
landfills, surface impoundments, and waste piles. When the hazardous waste is treated
to meet LDR requirements, air emission may result if the treatment process is not prop-