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Table 9
CERCLA/SARA (Superfund)
• Site-specific risk analysis required for removal and remediation actions
• Removal and remediation actions must comply with federal and state laws that applicable
or relevant and appropriate (ARARS)
•Toxic release inventory required by SARA Title 313
Source: US EPA.

to establish a more stringent standard, if a risk assessment at later time indicates that
technology-based standards are not adequately protective.
Recently completed was the NESHAP for benzene waste operations. This was the
last NESHAP set under the “old” Section 112. In March 1990, it was promulgated and
codified in 40 CFR 61, Subpart FF. It applies to the following emission sources: chem-
ical plants, petroleum refineries, coke byproduct recovery facilities, and TSDFs. The
rule establishes a compliance deadline of March 7, 1992 for which existing facilities
must install the required control.
The Comprehensive Environment Response, Compensation, and Liability Act
mandates the cleanup of inactive contaminated sites. Table 9 indicates that CERCLA
has several aspects that provide control of organic emissions. The process required for
a Superfund site cleanup is a site-specific risk analysis conducted prior to a removal and
remediation action. Under this analysis, consideration of air emissions resulting from
the cleanup must be incorporated in the cleanup. This is illustrated by a cleanup of
groundwater contaminated with organics. This cleanup could use a groundwater strip-

Fig. 20. Overlap of statutory coverage for air emission sources. (From US EPA)