MEMORANDUM

Date:	February 4, 2016

Subject:	National Impacts Associated with the Proposed Amendments to Remove the Exemption for Facilities Performing Site Remediations under CERCLA or RCRA in the NESHAP for Site Remediation 

From:	Lesley Stobert, EC/R Inc.
		
To:	Paula Hirtz, EPA/OAQPS/SPPD
______________________________________________________________________________

The purpose of this memorandum is to present information on the expected nationwide costs and emissions reductions associated with the proposed amendments to the Site Remediation National Emission Standards for Hazardous Air Pollutants (NESHAP), which remove rule exemptions for site remediation activities conducted under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and for site remediation activities conducted under a Resource Conservation and Recovery Act (RCRA) corrective action or other required RCRA order. 

1.0	Background

On October 8, 2003 the EPA finalized the National Emissions Standards for Hazardous Air Pollutants for the Site Remediation source category based on the requirements of section 112(d) of the Clean Air Act (CAA) to control hazardous air pollutant (HAP) emissions from both new and existing sources (68 FR 58172). In March 2015, in response to a petition for reconsideration of the October 2003 rulemaking (received by the EPA in December 2003), the EPA issued a letter to the petitioners granting reconsideration on the issues raised in the petition. The EPA is issuing a Federal Register notice regarding one of the issues raised by the petitioners, the exemptions in the rule for site remediations performed under the authority of CERCLA or performed under a RCRA corrective action or other required RCRA order. In this notice, the EPA is proposing to remove these exemptions from the Site Remediation NESHAP.

The effect of the removal of these exemptions is that site remediations at facilities that are major sources of HAP as defined by section 112 of the CAA and engage in a MACT activity (defined as a non-remediation activity covered in the MACT list of major source categories pursuant to CAA section 112(c)) and that perform the site remediation under the authority of CERCLA or under a RCRA corrective action or other required RCRA order will now be subject to the Site Remediation NESHAP and all applicable requirements.
 





2.0	National Impacts

      2.1 	Facility Identification

To determine the potential scope of this action's impacts, we worked with the EPA's Office of Land and Emergency Management (OLEM) to query the EPA's Corrective Action data and latest available version (2013) of the Biennial Report (BR) data in RCRAInfo to determine which facilities currently (as of 2013) are performing site remediation activities under a RCRA corrective action or other required RCRA order. RCRAInfo is the EPA's national database (https://rcrainfo.epa.gov/rcrainfoweb/action/main-menu/view) that compiles data on RCRA facilities including detailed hazardous waste data (ftp://ftp.epa.gov/rcrainfodata/rcra_flatfiles). The BR (ftp://ftp.epa.gov/rcrainfodata) includes data on the generation of hazardous waste from large quantity generators and data on waste management practices from treatment, storage, and disposal facilities every two years. RCRAInfo also holds the status of RCRA Corrective Action facilities. To determine which Corrective Action facilities are performing site remediation activities, we queried the BR data for facilities with waste source codes of G41 through G45 and also G49 (See description in the Appendix), which are codes that indicate  the hazardous waste generation process or activity (i.e., source) is related to remediation of past contamination. Through this activity, a number of facilities were identified that perform site remediation activities, but since the Site Remediation NESHAP only applies to major sources of HAP, not all of these facilities would potentially be subject to the rule. To determine which of these facilities were major sources of HAP, we cross-referenced this facility list with the EPA's Air Facility System (AFS) database, which contains compliance and permit data for stationary sources of air pollution regulated by EPA, state and local air pollution agencies, by facility identification number. The resulting list includes 122 facilities.

In addition, to determine which facilities are performing remediation activities under the authority of CERCLA that are also major sources of HAP, we worked with OLEM to obtain background information and data. As most CERCLA-regulated "Superfund" sites are located at facilities that have been abandoned or are no longer operating, and since remediation activities alone do not usually generate enough emissions to reach the major source thresholds for HAP, OLEM staff suggested the effort to identify facilities that might be affected by the removal of the RCRA/CERCLA exemptions be focused on federal facilities. Nationwide, there are several operating federal facilities, such as military bases and national laboratories, that have ongoing CERCLA-regulated remediation activities and that are major sources of HAP. However, many of these remediation activities involve only groundwater monitoring or in-situ treatments that do not have air emission releases. To focus on the facilities that might be required to control emissions to meet the requirements of the Site Remediation NESHAP, OLEM staff queried the Superfund Enterprise Management System (SEMS) database for information on federal facilities that have ongoing activities with the potential for emissions releases to the air, including extraction, soil vapor extraction, and multi-phase extraction activities. Cross-referencing these facilities with the AFS database, three facilities were found to meet the criteria of being a major source for HAP and have at least one CERCLA-required remediation activity with air emissions potential on site. 

The combined preliminary list of facilities performing remediation activities required either under RCRA or CERCLA includes 125 facilities. The list of facilities shown in Table 1 is provided to support assessment of the potential impacts of removing the exemptions in the existing rule but is not intended to serve as an exhaustive list of affected entities under the proposed rule. Potentially affected entities should examine the applicability criteria in 40 CFR 63.7881 to determine if they are subject to this action. 

Table 1. Preliminary List of Facilities Performing Remediation Activities under RCRA or CERCLA
                                 Generator ID 
                                Facility Name*
                                     State
                                     City
AKD000850701
FLINT HILLS RESOURCES ALASKA, LLC, NORTH POLE REFINERY
                                      AK
NORTH POLE
AKD048679682
TESORO ALASKA COMPANY, KENAI REFINERY
                                      AK
KENAI
AL7210020742
U.S. ARMY GARRISON - REDSTONE
                                      AL
REDSTONE ARSENAL
AR0213820707
PINE BLUFF ARSENAL
                                      AR
PINE BLUFF
CAD066676123
CARSON TERMINAL
                                      CA
CARSON
CAD093245645
DUCOMMUN AEROSTRUCTURES, INC.
                                      CA
EL MIRAGE
CA2170023152
NAWS, CHINA LAKE
                                      CA
CHINA LAKE
CAD077227049
TESORO LOS ANGELES REFINERY - CARSON OPERATIONS
                                      CA
CARSON
CAD076528678
THE DOW CHEMICAL COMPANY
                                      CA
PITTSBURG
COD076470525
CORDEN PHARMA COLORADO INC
                                      CO
BOULDER
COD007057961
EVRAZ ROCKY MOUNTAIN STEEL
                                      CO
PUEBLO
CTD001147842
ELECTRIC BOAT CORP
                                      CT
GROTON
CTD001145341
HAMILTON SUNDSTRAND CORP
                                      CT
WINDSOR LOCKS
CTD990672081
PRATT & WHITNEY
                                      CT
EAST HARTFORD
CTD000845131
PRATT & WHITNEY ANDREW WILLGOOS TURBINE LAB
                                      CT
EAST HARTFORD
CTD001449784
SIKORSKY AIRCRAFT CORP
                                      CT
STRATFORD
DED003913266
OCCIDENTAL CHEMICAL CORPORATION
                                      DE
NEW CASTLE
FL2800016121
CAPE CANAVERAL AFS
                                      FL
PATRICK AFB
FL6800014585
JOHN F. KENNEDY SPACE CENTER
                                      FL
KENNEDY SPACE CENTER
GAD980729974
BLUE BIRD CORPORATION
                                      GA
FORT VALLEY
GAD006924872
DELTA AIR LINES INC
                                      GA
ATLANTA
GAD004065520
PINOVA, INC. (FORMERLY HERCULES INCORPORATED)
                                      GA
BRUNSWICK
GAD078106846
TRIUMPH AEROSTRUCTURES - VOUGHT AIRCRAFT DIVISION
                                      GA
MILLEDGEVILLE
GA0210020368
U.S. ARMY GARRISON, FORT GORDON
                                      GA
FORT GORDON
IAD005289806
JOHN DEERE WATERLOO WORKS - DRIVETRAIN OPERATIONS 
                                      IA
WATERLOO
IAD005273594
MONSANTO COMPANY
                                      IA
MUSCATINE
ID3572124557
MOUNTAIN HOME AIR FORCE BASE*
                                      ID
MOUNTAIN HOME
ILD041550567
CITGO LEMONT REFINERY
                                      IL
LEMONT
ILD080012305
EQUILON DBA SHELL OIL PRODUCTS
                                      IL
ROXANA
ILD005476882
MARATHON PETROLEUM CO LP
                                      IL
ROBINSON
ILD041889023
PREMCOR REFINING GROUP INC
                                      IL
HARTFORD
ILD000802702
SOLUTIA INC WG KRUMMRICH PLANT
                                      IL
SAUGET
IND006413348
ALLISON TRANSMISSION INC SPEEDWAY MAIN
                                      IN
INDIANAPOLIS
KS0213820467
GREAT PLAINS DEVELOPMENT AUTHORITY/INDUSTRIAL PARK
                                      KS
PARSONS
KSD007482029
OCCIDENTAL CHEMICAL CORPORATION
                                      KS
WICHITA
KYD003924198
E. I. DU PONT DE NEMOURS & COMPANY
                                      KY
LOUISVILLE
LAD040776809
BASF GEISMAR SITE
                                      LA
GEISMAR
LAD008086506
EAGLE US 2 LLC
                                      LA
WESTLAKE
LAD008184137
EXIDE TECHNOLOGIES, BATON ROUGE RECYCLING CENTER
                                      LA
BATON ROUGE
LAR000018333
LYONDELL CHEMICAL COMPANY
                                      LA
WESTLAKE
LAD001700756
MONSANTO LULING FACILITY
                                      LA
LULING
LAD092681824
OCCIDENTAL CHEMICAL CORPORATION GEISMAR FACILITY
                                      LA
GEISMAR
LAD990683716
PHILLIPS 66, LAKE CHARLES REFINERY
                                      LA
WESTLAKE
LAD008213191
RUBICON LLC
                                      LA
GEISMAR
LAD053783445
SYNGENTA CROP PROTECTION, LLC
                                      LA
ST GABRIEL
LAD008187080
THE DOW CHEMICAL CO., LOUISIANA OPERATIONS
                                      LA
PLAQUEMINE
LAD041581422
UNION CARBIDE CORP. - ST. CHARLES OPERATIONS
                                      LA
TAFT
MAD001408517
GENERAL ELECTRIC AVIATION
                                      MA
LYNN
MD4170024687
NAVAL SUPPORT ACTIVITY BETHESDA
                                      MD
BETHESDA
MDD001710227
W.R. GRACE & CP- CONN
                                      MD
BALTIIMORE
MED001095041
RUMFORD PAPER COMPANY
                                      ME
RUMFORD
MID064197742
6BASF CORP
                                      MI
WYANDOTTE
MID009305665
FORD MOTOR COMPANY- SALINE PLANT
                                      MI
SALINE
MID005356894
GENERAL MOTORS LLC
                                      MI
LANSING
MID050615996
GENERAL MOTORS WARREN TECHNICAL CENTER
                                      MI
WARREN
MID087738431
SEVERSTAL DEARBORN LLC
                                      MI
DEARBORN
MID000724724
THE DOW CHEMICAL COMPANY, MICHIGAN OPERATIONS
                                      MI
MIDLAND
MID048090633
WAYNE DISPOSAL INC
                                      MI
BELLEVILLE
MOD059200089
BUICK RESOURCE RECYCLING FACILITY, LLC
                                      MO
BOSS
MO9890010524
U.S. DEPT. OF ENERGY - KANSAS CITY PLANT
                                      MO
KANSAS CITY
MSD096046792
E.I. DU PONT DE NEMOURS AND CO
                                      MS
PASS CHRISTIAN
NCD018652339
DAIMLER TRUCKS NORTH AMERICA, LLC
                                      NC
CLEVELAND
NC6170022580
MARINE CORPS BASE CAMP LEJEUNE
                                      NC
CAMP LEJEUNE
NC1170027261
MCAB EAST - MCAS CHERRY POINT
                                      NC
HAVELOCK
NDD000690594
DAKOTA GASIFICATION COMPANY - GREAT PLAINS SYNFUELS PLANT
                                      ND
BEULAH
NJD081982902
CHEVRON OIL CO AT PERTH AMBOY REFINERY
                                      NJ
PERTH AMBOY
NJD002385730
DUPONT CHAMBERS WORKS
                                      NJ
DEEPWATER
NJD062037031
EXXONMOBIL OIL CORP
                                      NJ
LINDEN
NJD001317601
MERCK SHARP & DOHME CORP - UNION NJ
                                      NJ
UNION
NM0890010515
LOS ALAMOS NATIONAL LABORATORY
                                      NM
LOS ALAMOS
NY7890008975
BROOKHAVEN NATIONAL LABORATORY (USDOE)*
                                      NY
UPTON
NYD980593636
CON EDISON - ASTORIA
                                      NY
LONG ISLAND CITY
NYD980592497
EASTMAN BUSINESS PARK - FORMERLY  KODAK PARK
                                      NY
ROCHESTER
NYD002084135
GENERAL ELECTRIC SCHENECTADY
                                      NY
SCHENECTADY
NYD000707901
IBM CORP-EAST FISHKILL FACILITY
                                      NY
HOPEWELL JUNCTION
NYD002080034
MPM SILICONES LLC
                                      NY
WATERFORD
NYD000824482
OCCIDENTAL CHEMICAL - NIAGARA PLANT
                                      NY
NIAGARA FALLS
NYD030485288
REVERE SMELTING & REFINING CORPORATION
                                      NY
MIDDLETOWN
NYD066832023
SABIC INOVATIVE PLASTICS US LLC
                                      NY
SELKIRK
NYD002081396
WYETH PHARMACEUTICALS
                                      NY
ROUSES POINT
NYD002211324
XEROX CORPORATION
                                      NY
WEBSTER
OHD004218673
ARCELORMITTAL CLEVELAND LLC
                                      OH
CLEVELAND
OHD068111327
EVERGREEN RECYCLING & DISPOSAL
                                      OH
NORTHWOOD
OHD980613541
HERITAGE THERMAL SERVICES INC
                                      OH
EAST LIVERPOOL
OHD032271975
NUCOR STEEL MARION INC
                                      OH
MARION
OHD004198917
PPG BARBERTON INC
                                      OH
BARBERTON
OHD981529688
SOLVAY SPECIALTY POLYMERS USA LLC
                                      OH
MARIETTA
OKD990750960
HOLLY REFINING & MARKETING - TULSA LLC
                                      OK
TULSA
PAD002312791
HONEYWELL RESINS & CHEMICALS LLC
                                      PA
PHILADELPHIA
PAD077883346
ROHM AND HAAS CHEMICALS LLC
                                      PA
PHILADELPHIA
PAD000000554
SPS TECHNOLOGIES LLC
                                      PA
JENKINTOWN
PAD004498010
US STEEL CORP MVW CLAIRTON PLT
                                      PA
CLAIRTON
PRD090021056
BRISTOL-MYERS SQUIBB MANUFACTURING CO.
                                      PR
HUMACAO
SCD069314045
MILLIKEN CHEMICAL DEWEY PLANT
                                      SC
INMAN
TN8570024044
ARNOLD ENGINEERING DEVELOPMENT COMPLEX / TSDCI
                                      TN
ARNOLD AFB
TXD990757486
AIR PRODUCTS PASADENA PLANT
                                      TX
PASADENA
TXD008013468
ALON USA REFINERY
                                      TX
BIG SPRING
TXD074185141
BAYPORT CHEMICAL PLANT
                                      TX
PASADENA
TXD051161990
CITGO REFINING AND CHEMICALS EAST PLANT
                                      TX
CORPUS CHRISTI
TXD008081101
E I DU PONT DE NEMOURS BEAUMONT WORKS
                                      TX
NEDERLAND
TXD007330202
EASTMAN CHEMICAL COMPANY
                                      TX
LONGVIEW
TXD006451090
EXIDE FRISCO BATTERY RECYCLING PLANT
                                      TX
FRISCO
TXT490011293
FORMOSA PLASTICS POINT COMFORT PLANT
                                      TX
POINT COMFORT
TXD000836486
GB BIOSCIENCES CORPORATION GREENS BAYOU PLANT
                                      TX
HOUSTON
TXD074195678
GULF CHEMICAL & METALLURGICAL FREEPORT
                                      TX
FREEPORT
TXD026481523
KM LIQUIDS TERMINALS
                                      TX
GALENA PARK
TXD007365984
L-3 COMMUNICATIONS INTEGRATED SYSTEMS MAJOR FIELD
                                      TX
GREENVILLE
TXD083472266
LYONDELL CHEMICAL CHANNELVIEW
                                      TX
CHANNELVIEW
TXD980626022
MOTIVA PORT NECHES TERMINAL PLANT
                                      TX
PORT NECHES
TX7170022787
NAVAL AIR STATION CORPUS CHRISTI
                                      TX
CORPUS CHRISTI
TX3213820738
RED RIVER ARMY DEPOT
                                      TX
TEXARKANA
TXD067285973
SHELL OIL DEER PARK
                                      TX
DEER PARK
TXD980626782
UNION CARBIDE
                                      TX
TEXAS CITY
TXD000461533
UNION CARBIDE TEXAS CITY
                                      TX
TEXAS CITY
TX6170022770
VOUGHT INTEGRATED PROGRAMS DIVISION JSF
                                      TX
DALLAS
UT5210090002
TOOELE ARMY DEPOT-SOUTH AREA
                                      UT
STOCKTON
VAD001307495
HUNTINGTON INGALLS INCORPORATED
                                      VA
NEWPORT NEWS
WAD041337130
BOEING COMPANY  AUBURN
                                      WA
AUBURN
WAD041585464
BOEING EVERETT
                                      WA
EVERETT
WAD009256819
BOEING PLANT 2
                                      WA
SEATTLE
WA1890090078
HANFORD 200-AREA (USDOE)*
                                      WA
RICHLAND
WID006125215
TYCO SAFETY PRODUCTS - ANSUL STANTON ST FAC
                                      WI
MARINETTE
WVD005012851
E.I. DU PONT DE NEMOURS AND COMPANY
                                      WV
BELLE
WVD005005483
UNION CARBIDE CORPORATION - SOUTH CHARLESTON PLANT
                                      WV
SOUTH CHARLESTON
WYD079959185
SINCLAIR WYOMING REFINING COMPANY
                                      WY
SINCLAIR
*The facilities resulting from the search for CERCLA-regulated facilities are indicated with a *, and the remaining facilities were a result of the search for facilities regulated by RCRA.

      2.2 	Facility Impacts Information
      
To determine the impacts of the removal of the RCRA/CERCLA exemptions on these facilities, information about the remediation activities was reviewed, along with available information on the amount of waste handled, the potential HAP content of the waste, the phase of the waste, the types of waste management equipment being used and any emissions control information. For the 122 RCRA Corrective Action facilities, the review began with data from the BR supplied by OLEM staff, and for the three CERCLA-regulated facilities, the data reviewed was the data from the SEMS database supplied by OLEM staff. From examination of these data, we determined that many facilities would not be impacted by the removal of the exemptions or would have minimal impacts due to the low levels of HAP content in their remediation waste. These facilities would only be required to perform administrative recordkeeping activities. More information is provided below to describe the projected applicable Site Remediation NESHAP requirements for these facilities, and the Appendix shows each facility reviewed and the projected requirements for each.

	2.2.1 	RCRA Corrective Action Facilities

In examining the BR data for the RCRA Corrective Action facilities, the Waste Source Code information for each facility was reviewed, which revealed that many facilities in the BR with remediation activities were not performing the activity as a requirement of RCRA, but under another authority, such as a State program or voluntarily. Since facilities performing remediation through such a program are not exempt and already subject to the Site Remediation NESHAP, we determined that the removal of the RCRA exemption would not impact these facilities. As shown in the table in the Appendix, 54 of the 122 facilities included in the BR were identified as having remediation activities that were not required by RCRA and would not be affected by the removal of the RCRA exemption. We then proceeded to analyze the remaining 68 RCRA-regulated facilities.




Facilities with Remediation Waste Below the NESHAP Threshold Level of HAP

For the remaining 68 RCRA-regulated facilities, we next examined the amount of waste generated annually, as reported in the BR. The Site Remediation NESHAP contains an exemption from the control requirements (aside from certain recordkeeping requirements) for facilities for which the annual total quantity of regulated HAP in the remediation material excavated, extracted, pumped, or otherwise removed (i.e., handled) from the entire facility is less than 1 megagram or 1.1 tons. In reviewing the BR data, we determined that 15 of the 68 facilities handled less than 1.1 tpy of remediation waste and the only applicable requirements for these 15 facilities would be minimal recordkeeping requirements. In addition, in a few instances, the waste description information in the BR allowed us to determine that the HAP content in the handled remediation waste would be less than 1.1 tons (e.g., Form Code W101 - very dilute aqueous waste containing more than 99% water). This resulted in the determination that an additional 5 facilities handled remediation waste containing less than 1.1 tons of HAP annually and that the only applicable requirements for these 5 facilities would also be the minimal recordkeeping requirements.  For these 20 facilities, we assume only the minimal recordkeeping requirements would apply, which involve the preparation and maintenance of documentation on-site at the facility to support the determination that the total quantity of HAP in the remediation waste handled annually is less than 1.1 tons. We then proceeded to analyze the remaining 48 RCRA-regulated facilities.

Facilities with Remediation Waste Meeting the NESHAP Threshold Level of HAP

For the remaining 48 RCRA-regulated facilities that appear to generate remediation waste containing 1.1 ton or more of HAP annually, examination of the BR data revealed that 23 facilities were conducting onsite treatment and 25 facilities were not performing any onsite treatment of their remediation waste, but were transferring it offsite for treatment or disposal. For the 25 facilities that transfer their remediation waste offsite, we made the assumption that the potential impacts would be less than the impacts for the 23 facilities conducting onsite treatment, since the emissions potential would be limited to gathering and storing the material before transferring it offsite. 

Facilities Meeting the NESHAP Threshold Level of HAP that Transfer Waste Offsite  

For the 25 facilities that appear from the BR data to generate remediation waste containing 1.1 ton or more of HAP annually that transfer their remediation waste offsite, we made several general observations. Based on the remediation waste description, we found that for several of the facilities, the Site Remediation NESHAP requirements would not apply because the pollutant of concern was a metal or other chemical that is not regulated by the NESHAP. In other instances, the data indicated that the remediation waste is a solid (e.g., contaminated soil), and was handled in such a way that the Site Remediation NESHAP does not specify control requirements. Specific review of these 25 facilities revealed that 3 facilities do not have remediation waste with HAP regulated by the NESHAP, 6 facilities have remediation waste for which no control requirements would apply, and for the remaining 16 of these 25 facilities, we determined that the NESHAP requirements for storage tanks or containers may apply. 

We then applied the NESHAP requirements to these facilities and determined the potential impacts for these 25 facilities to be activities associated with recordkeeping and reporting as follows. For the 3 facilities with remediation waste that does not contain regulated HAP, we assume the only applicable requirements would be the minimal recordkeeping requirements to document the amount of HAP in the handled waste. For the 6 facilities handling remediation waste containing 1.1 tons or more annually of regulated HAP but for which no control requirements are specified in the NESHAP, we assume recordkeeping and reporting requirements would apply. These recordkeeping and reporting requirements would be more involved than those requirements for facilities handling remediation waste containing less than 1.1 tons of HAP, and would include the initial determination that the remediation waste contains 1.1 tons or more of regulated HAP, the recordkeeping for transfer of remediation materials off-site to another facility, and the initial and on-going compliance reporting and recordkeeping, as required by the NESHAP. 

For the 16 facilities with some remediation waste stored in tanks or containers before the waste is transferred offsite, we assumed that both the tanks and containers would already comply with the NESHAP. For containers, we assumed they would already meet the U.S. Department of Transportation requirements for transport of hazardous materials, and these requirements satisfy the container requirements of the Site Remediation NESHAP. For tanks, from the BR data on the waste amounts and description of the waste types, we assumed that the tank sizes and tank content vapor pressures would require Level 1 controls for compliance with the Site Remediation NESHAP. We further assumed that these tanks would already have fixed roofs, which is common for these tank sizes, and having a fixed roof would meet the requirements of the Site Remediation NESHAP for Level 1 control. Therefore, the only new requirements that would apply to these 16 facilities would be recordkeeping and reporting requirements and would include the initial determination that the waste handled contains 1.1 tons or more of regulated HAP, the recordkeeping for transfer of remediation materials off-site to another facility, and the initial and on-going compliance reporting and recordkeeping.

Facilities Meeting the NESHAP Threshold Level of HAP that Treat Waste Onsite
  
For the 23 facilities that reported onsite treatment of remediation waste and the waste appeared to have 1.1 tons or more of regulated HAP according to the BR, we attempted to gather more information about the site remediation activities. We contacted EPA Regional RCRA staff, RCRA state or local permitting agencies, and/or facility representatives, including staff at EPA Regions 1, 5, 6, and 8; state and local permitting agencies for the Bay Area of California, Colorado, Ohio and New York; and facility representatives for Oxychem, Toole Army Depot, Arnold Engineering and Milliken Chemical. From the additional information received from these contacts, based on the remediation waste activities and the controls described, information for one facility indicates that there are no currently ongoing remediation activities, and information for another facility indicated that the remediation was not performed under RCRA or CERCLA. For these two facilities, we assume there would be no new Site Remediation NESHAP requirements as a result of this action. In addition, the available information suggests that another facility had less than 1.1 tons of regulated HAP in the handled waste and two other facilities had remediation waste for which no control requirements would apply. We assumed that recordkeeping and reporting requirements would apply for these three facilities. This would include the initial determination regarding the amount of regulated HAP in the handled waste, and for the two facilities with over 1.1 tons of regulated HAP in the handled waste, the recordkeeping for transfer of remediation waste off-site to another facility (in cases where some remediation waste is transferred offsite) and also the initial and on-going compliance reporting and recordkeeping. 

The remaining 18 facilities that reported onsite treatment of remediation waste appear to already meet the control requirements of the Site Remediation NESHAP based on the descriptions of the remediation activities and controls in place. Therefore, the only new requirements that would apply to these 18 facilities would be recordkeeping and reporting requirements and would include the initial determination that the remediation waste handled contains 1.1 tons or more of regulated HAP, the recordkeeping for transfer of remediation waste materials off-site to another facility (for the facilities that ship some waste offsite) and the initial and on-going compliance reporting and recordkeeping. 

	2.2.2  	CERCLA Regulated Facilities

From examination of the data supplied by OLEM staff for the CERCLA-regulated facilities, it was determined that of the three included facilities, two annually handle remediation waste that contains less than 1.1 tons of HAP. For the other facility, the remediation waste does not contain HAP regulated by the Site Remediation NESHAP. For these three facilities, we assume the only applicable requirements are the minimum recordkeeping requirements to document that the total quantity of HAP in the remediation material handled annually is less than 1.1 tons. 

	2.3	Summary of Findings

To summarize these findings, Table 2 shows the projected requirements that would apply to the 125 facilities initially identified as performing remediation activities required either under RCRA or CERCLA. In addition, the table includes a qualitative description of the emissions reduction and facility cost impacts associated with the removal of the RCRA/CERCLA exemption from the Site Remediation NESHAP. Based on the analysis described above, the facilities were regrouped into categories showing facilities with no impacts, very low administrative costs and low administrative costs. As shown in Table 2, we estimate 56 of the 125 facilities included in the analysis will have no impacts and 69 facilities will have some impacts associated with the removal of the RCRA/CERCLA exemptions from the Site Remediation NESHAP. Of these 69 facilities, 24 are expected to have very low administrative costs and 45 are estimated to have low administrative costs, due to recordkeeping and reporting requirements, and no emission reductions are expected. The workbook titled Economic Impact Analysis Workbook for the Proposed Site Remediation NESHAP Amendments, available in the docket for this action, contains the quantitative cost impacts associated with this action.



  Table 2. Summary of Projected Applicable Site Remediation NESHAP Requirements and Associated Impacts
                             Number of Facilities
                     Facility Remediation Activity Status
           Projected Applicable Site Remediation NESHAP Requirements
Estimated Impacts of Projected Applicable Site Remediation NESHAP Requirements
                                      55
No RCRA or CERCLA regulated remediation material handled
Remediation activity already subject to Site Remediation NESHAP
No impacts

                                       1
No ongoing remediation activities
Not subject to Site Remediation NESHAP

                                      56
Subtotal: No impacts
                                      15
Handles <1.1 tpy remediation material
Subject to initial recordkeeping requirements

No emissions reductions, very low administrative costs
                                       9
Annual remediation material handled contains <1.1 ton HAP


                                      24
Subtotal: No emissions reductions, very low administrative costs
                                      11
Annual remediation material handled contains 1.1 ton or more HAP, no units meet GGGGG applicability requirements.
Subject to initial and ongoing recordkeeping and reporting requirements

No emissions reductions, low administrative costs

                                      34
Annual remediation material handled contains 1.1 ton or more HAP, units already in compliance with Site Remediation NESHAP requirements.


                                      45
Subtotal: No emissions reductions, low administrative costs
                                      125
Total Number of Facilities Examined


                                   Appendix
                                       
        Table A-1. BR Waste Codes for Remediation of Past Contamination
 Code
 Source Code Description*
  G41
 Closure of hazardous waste management unit under RCRA
  G42
 Corrective action at a solid waste management unit under RCRA
  G43
 Remedial action or emergency response under Superfund
  G44
 Cleanup under State or voluntary program
  G45
 Cleanup of underground storage tank
  G49
 Other remediation (specify in comments)
*Source Code descriptions can be found in the 2013 Hazardous Waste Report Instructions and Forms on the Biennial Report Overview webpage located at : https://rcrainfo.epa.gov/rcrainfoweb/action/modules/br/broverview .













	
Table A-2. Facilities Performing Site Remediation Activities and Projected Applicable Site Remediation NESHAP Requirements
Facility ID
Handler Name
                                     State
City
                  Sum of All Facility Waste Generation (Tons)
                   Has some RCRA or CERCLA Waste Generation?
                     Facility Generates >1.1 TPY Waste?
               Facility Generates Waste With >1.1 TPY of HAP?
                      Facility Has Some Onsite Treatment?
Projected Applicable Site Remediation NESHAP Requirements after RCRA/CERCLA Exemption Removal
CAD076528678
THE DOW CHEMICAL COMPANY
                                      CA
PITTSBURG
                                                                         40,723
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
KSD007482029
OCCIDENTAL CHEMICAL CORPORATION
                                      KS
WICHITA
                                                                      1,052,057
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
LAD092681824
OCCIDENTAL CHEMICAL CORPORATION GEISMAR FACILITY
                                      LA
GEISMAR
                                                                            120
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
LAD008213191
RUBICON LLC
                                      LA
GEISMAR
                                                                          6,717
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - no units meet GGGGG applicability requirements
MID048090633
WAYNE DISPOSAL INC
                                      MI
BELLEVILLE
                                                                            131
                                       Y
                                       Y
                                       Y
                                       Y
No impacts - no remediation ongoing
NYD002080034
MPM SILICONES LLC
                                      NY
WATERFORD
                                                                      1,256,102
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
NYD000824482
OCCIDENTAL CHEMICAL - NIAGARA PLANT
                                      NY
NIAGARA FALLS
                                                                        989,988
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
NYD066832023
SABIC INOVATIVE PLASTICS US LLC
                                      NY
SELKIRK
                                                                            814
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
NYD002211324
XEROX CORPORATION
                                      NY
WEBSTER
                                                                        182,198
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
OHD980613541
HERITAGE THERMAL SERVICES INC
                                      OH
EAST LIVERPOOL
                                                                              3
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
SCD069314045
MILLIKEN CHEMICAL DEWEY PLANT
                                      SC
INMAN
                                                                              9
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
TXD990757486
AIR PRODUCTS PASADENA PLANT
                                      TX
PASADENA
                                                                          4,502
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
TXD008081101
E I DU PONT DE NEMOURS BEAUMONT WORKS
                                      TX
NEDERLAND
                                                                         61,972
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
TXD007330202
EASTMAN CHEMICAL COMPANY
                                      TX
LONGVIEW
                                                                         24,148
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
TXD000836486
GB BIOSCIENCES CORPORATION GREENS BAYOU PLANT
                                      TX
HOUSTON
                                                                             15
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
TXD026481523
KM LIQUIDS TERMINALS
                                      TX
GALENA PARK
                                                                         21,506
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements 
TXD007365984
L-3 COMMUNICATIONS INTEGRATED SYSTEMS MAJOR FIELD
                                      TX
GREENVILLE
                                                                            676
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements 
TX7170022787
NAVAL AIR STATION CORPUS CHRISTI
                                      TX
CORPUS CHRISTI
                                                                             29
                                      Y*
                                       Y
                                       Y
                                       Y
Recordkeeping only - no units meet GGGGG applicability requirements
TXD980626782
UNION CARBIDE
                                      TX
TEXAS CITY
                                                                          1,954
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
TXD000461533
UNION CARBIDE TEXAS CITY
                                      TX
TEXAS CITY
                                                                         15,723
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
UT5210090002
TOOELE ARMY DEPOT-SOUTH AREA
                                      UT
STOCKTON
                                                                            661
                                       Y
                                       Y
                                       Y
                                       Y
Recordkeeping only - existing site controls likely meet GGGGG requirements
AKD048679682
TESORO ALASKA COMPANY, KENAI REFINERY
                                      AK
KENAI
                                                                              2
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
AL7210020742
U.S. ARMY GARRISON - REDSTONE
                                      AL
REDSTONE ARSENAL
                                                                            158
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
COD007057961
EVRAZ ROCKY MOUNTAIN STEEL
                                      CO
PUEBLO
                                                                             60
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
COD076470525
CORDEN PHARMA COLORADO INC
                                      CO
BOULDER
                                                                             78
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements
CTD001145341
HAMILTON SUNDSTRAND CORP
                                      CT
WINDSOR LOCKS
                                                                             14
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
DED003913266
OCCIDENTAL CHEMICAL CORPORATION
                                      DE
NEW CASTLE
                                                                              7
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
FL2800016121
CAPE CANAVERAL AFS
                                      FL
PATRICK AFB
                                                                             33
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
IAD005289806
JOHN DEERE WATERLOO WORKS - DRIVETRAIN OPERATIONS 
                                      IA
WATERLOO
                                                                             12
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
ILD041550567
CITGO LEMONT REFINERY
                                      IL
LEMONT
                                                                             15
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
ILD080012305
EQUILON DBA SHELL OIL PRODUCTS
                                      IL
ROXANA
                                                                             82
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
KYD003924198
E. I. DU PONT DE NEMOURS & COMPANY
                                      KY
LOUISVILLE
                                                                             23
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements
LAD008184137
EXIDE TECHNOLOGIES, BATON ROUGE RECYCLING CENTER
                                      LA
BATON ROUGE
                                                                            915
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements - no regulated HAP
LAD040776809
BASF GEISMAR SITE
                                      LA
GEISMAR
                                                                              2
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
LAD041581422
UNION CARBIDE CORP. - ST. CHARLES OPERATIONS
                                      LA
TAFT
                                                                            530
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
LAD053783445
SYNGENTA CROP PROTECTION, LLC
                                      LA
ST GABRIEL
                                                                              6
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements
MD4170024687
NAVAL SUPPORT ACTIVITY BETHESDA
                                      MD
BETHESDA
                                                                             15
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements - no regulated HAP
MID009305665
FORD MOTOR COMPANY- SALINE PLANT
                                      MI
SALINE
                                                                              5
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
NJD081982902
CHEVRON OIL CO AT PERTH AMBOY REFINERY
                                      NJ
PERTH AMBOY
                                                                             21
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
NYD000707901
IBM CORP-EAST FISHKILL FACILITY
                                      NY
HOPEWELL JUNCTION
                                                                             75
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements
OHD004198917
PPG BARBERTON INC
                                      OH
BARBERTON
                                                                            512
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
OHD032271975
NUCOR STEEL MARION INC
                                      OH
MARION
                                                                            568
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements
PRD090021056
BRISTOL-MYERS SQUIBB MANUFACTURING CO.
                                      PR
HUMACAO
                                                                            225
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
WAD009256819
BOEING PLANT 2
                                      WA
SEATTLE
                                                                          8,386
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, existing site controls for storage likely meet GGGGG requirements
WID006125215
TYCO SAFETY PRODUCTS - ANSUL STANTON ST FAC
                                      WI
MARINETTE
                                                                         10,090
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements - no regulated HAP
WVD005012851
E.I. DU PONT DE NEMOURS AND COMPANY
                                      WV
BELLE
                                                                              8
                                       Y
                                       Y
                                       Y
                                       N
Recordkeeping only - no onsite treatment, no units meet GGGGG applicability requirements
CTD001449784
SIKORSKY AIRCRAFT CORP
                                      CT
STRATFORD
                                                                              2
                                       Y
                                       Y
                                       N
                                      **
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
FL6800014585
JOHN F. KENNEDY SPACE CENTER
                                      FL
KENNEDY SPACE CENTER
                                                                              7
                                       Y
                                       Y
                                       N
                                      **
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
GAD004065520
PINOVA, INC. (FORMERLY HERCULES INCORPORATED)
                                      GA
BRUNSWICK
                                                                              3
                                       Y
                                       Y
                                       N
                                      **
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
GAD980729974
BLUE BIRD CORPORATION
                                      GA
FORT VALLEY
                                                                              1
                                       Y
                                       Y
                                       N
                                      **
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
TXT490011293
FORMOSA PLASTICS POINT COMFORT PLANT
                                      TX
POINT COMFORT
                                                                          1,188
                                      Y*
                                       Y
                                       N
                                       Y
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
PAD002312791
HONEYWELL RESINS & CHEMICALS LLC
                                      PA
PHILADELPHIA
                                                                              3
                                       Y
                                       Y
                                       N
                                      **
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
WA1890090078
HANFORD 200-AREA (USDOE)***
                                      WA
RICHLAND
                                 not available
                                       Y
                                 not available
                                       N
                                       Y
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
ID3572124557
MOUNTAIN HOME AIR FORCE BASE***
                                      ID
MOUNTAIN HOME
                                 not available
                                       Y
                                 not available
                                       N
                                       Y
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
AR0213820707
PINE BLUFF ARSENAL
                                      AR
PINE BLUFF
                                                                            0.3
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
CAD093245645
DUCOMMUN AEROSTRUCTURES, INC.
                                      CA
EL MIRAGE
                                                                              1
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
GA0210020368
U.S. ARMY GARRISON, FORT GORDON
                                      GA
FORT GORDON
                                                                            0.4
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
GAD078106846
TRIUMPH AEROSTRUCTURES - VOUGHT AIRCRAFT DIVISION
                                      GA
MILLEDGEVILLE
                                                                            0.5
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
IAD005273594
MONSANTO COMPANY
                                      IA
MUSCATINE
                                                                              0
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
ILD005476882
MARATHON PETROLEUM CO LP
                                      IL
ROBINSON
                                                                              1
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
LAD001700756
MONSANTO LULING FACILITY
                                      LA
LULING
                                                                            0.9
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
LAR000018333
LYONDELL CHEMICAL COMPANY
                                      LA
WESTLAKE
                                                                            0.2
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
MO9890010524
U.S. DEPT. OF ENERGY - KANSAS CITY PLANT
                                      MO
KANSAS CITY
                                                                            0.4
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
NC6170022580
MARINE CORPS BASE CAMP LEJEUNE
                                      NC
CAMP LEJEUNE
                                                                            0.2
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
NCD018652339
DAIMLER TRUCKS NORTH AMERICA, LLC
                                      NC
CLEVELAND
                                                                           0.04
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
OHD004218673
ARCELORMITTAL CLEVELAND LLC
                                      OH
CLEVELAND
                                                                            0.4
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
OKD990750960
HOLLY REFINING & MARKETING - TULSA LLC
                                      OK
TULSA
                                                                            0.1
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
VAD001307495
HUNTINGTON INGALLS INCORPORATED
                                      VA
NEWPORT NEWS
                                                                              1
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
WYD079959185
SINCLAIR WYOMING REFINING COMPANY
                                      WY
SINCLAIR
                                                                              0
                                       Y
                                       N
                                       N
                                      **
Recordkeeping only - generates <1.1 tpy remediation waste
NY7890008975
BROOKHAVEN NATIONAL LABORATORY (USDOE)***
                                      NY
UPTON
                                 not available
                                       Y
                                 not available
                                       N
                                       Y
Recordkeeping only - annual remediation waste generated contains <1.1 ton HAP
AKD000850701
FLINT HILLS RESOURCES ALASKA, LLC, NORTH POLE REFINERY
                                      AK
NORTH POLE
                                                                            0.5
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
CAD066676123
CARSON TERMINAL
                                      CA
CARSON
                                                                              4
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
CA2170023152
NAWS, CHINA LAKE
                                      CA
CHINA LAKE
                                                                              6
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
CAD077227049
TESORO LOS ANGELES REFINERY - CARSON OPERATIONS
                                      CA
CARSON
                                                                            0.1
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
CTD001147842
ELECTRIC BOAT CORP
                                      CT
GROTON
                                                                              1
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
CTD990672081
PRATT & WHITNEY
                                      CT
EAST HARTFORD
                                                                             22
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
CTD000845131
PRATT & WHITNEY ANDREW WILLGOOS TURBINE LAB
                                      CT
EAST HARTFORD
                                                                             85
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
GAD006924872
DELTA AIR LINES INC
                                      GA
ATLANTA
                                                                              1
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
ILD041889023
PREMCOR REFINING GROUP INC
                                      IL
HARTFORD
                                                                             26
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
ILD000802702
SOLUTIA INC WG KRUMMRICH PLANT
                                      IL
SAUGET
                                                                              5
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
IND006413348
ALLISON TRANSMISSION INC SPEEDWAY MAIN
                                      IN
INDIANAPOLIS
                                                                            413
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
KS0213820467
GREAT PLAINS DEVELOPMENT AUTHORITY/INDUSTRIAL PARK
                                      KS
PARSONS
                                                                              2
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
LAD008086506
EAGLE US 2 LLC
                                      LA
WESTLAKE
                                                                             15
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
LAD990683716
PHILLIPS 66, LAKE CHARLES REFINERY
                                      LA
WESTLAKE
                                                                              5
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
LAD008187080
THE DOW CHEMICAL CO., LOUISIANA OPERATIONS
                                      LA
PLAQUEMINE
                                                                             36
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MAD001408517
GENERAL ELECTRIC AVIATION
                                      MA
LYNN
                                                                            0.2
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MDD001710227
W.R. GRACE & CP- CONN
                                      MD
BALTIIMORE
                                                                            0.5
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MED001095041
RUMFORD PAPER COMPANY
                                      ME
RUMFORD
                                                                            0.1
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MID064197742
BASF CORP
                                      MI
WYANDOTTE
                                                                            137
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MID005356894
GENERAL MOTORS LLC
                                      MI
LANSING
                                                                            0.9
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MID050615996
GENERAL MOTORS WARREN TECHNICAL CENTER
                                      MI
WARREN
                                                                              1
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MID087738431
SEVERSTAL DEARBORN LLC
                                      MI
DEARBORN
                                                                            0.5
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MID000724724
THE DOW CHEMICAL COMPANY, MICHIGAN OPERATIONS
                                      MI
MIDLAND
                                                                            0.0
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MOD059200089
BUICK RESOURCE RECYCLING FACILITY, LLC
                                      MO
BOSS
                                                                             47
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
MSD096046792
E.I. DU PONT DE NEMOURS AND CO
                                      MS
PASS CHRISTIAN
                                                                            0.1
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NC1170027261
MCAB EAST - MCAS CHERRY POINT
                                      NC
HAVELOCK
                                                                            0.2
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NDD000690594
DAKOTA GASIFICATION COMPANY - GREAT PLAINS SYNFUELS PLANT
                                      ND
BEULAH
                                                                              1
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NJD002385730
DUPONT CHAMBERS WORKS
                                      NJ
DEEPWATER
                                                                              6
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NJD062037031
EXXONMOBIL OIL CORP
                                      NJ
LINDEN
                                                                            497
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NJD001317601
MERCK SHARP & DOHME CORP - UNION NJ
                                      NJ
UNION
                                                                            0.0
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NM0890010515
LOS ALAMOS NATIONAL LABORATORY
                                      NM
LOS ALAMOS
                                                                            0.0
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NYD980593636
CON EDISON - ASTORIA
                                      NY
LONG ISLAND CITY
                                                                          2,843
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NYD980592497
EASTMAN BUSINESS PARK - FORMERLY  KODAK PARK
                                      NY
ROCHESTER
                                                                            0.1
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NYD002084135
GENERAL ELECTRIC SCHENECTADY
                                      NY
SCHENECTADY
                                                                              2
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NYD030485288
REVERE SMELTING & REFINING CORPORATION
                                      NY
MIDDLETOWN
                                                                         55,063
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
NYD002081396
WYETH PHARMACEUTICALS
                                      NY
ROUSES POINT
                                                                            0.4
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
OHD068111327
EVERGREEN RECYCLING & DISPOSAL
                                      OH
NORTHWOOD
                                                                             38
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
OHD981529688
SOLVAY SPECIALTY POLYMERS USA LLC
                                      OH
MARIETTA
                                                                            0.1
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
PAD077883346
ROHM AND HAAS CHEMICALS LLC
                                      PA
PHILADELPHIA
                                                                              3
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
PAD000000554
SPS TECHNOLOGIES LLC
                                      PA
JENKINTOWN
                                                                              6
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
PAD004498010
US STEEL CORP MVW CLAIRTON PLT
                                      PA
CLAIRTON
                                                                             76
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TN8570024044
ARNOLD ENGINEERING DEVELOPMENT COMPLEX / TSDCI
                                      TN
ARNOLD AFB
                                                                              5
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD008013468
ALON USA REFINERY
                                      TX
BIG SPRING
                                                                              8
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD074185141
BAYPORT CHEMICAL PLANT
                                      TX
PASADENA
                                                                            0.2
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD051161990
CITGO REFINING AND CHEMICALS EAST PLANT
                                      TX
CORPUS CHRISTI
                                                                             16
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD006451090
EXIDE FRISCO BATTERY RECYCLING PLANT
                                      TX
FRISCO
                                                                          2,149
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD074195678
GULF CHEMICAL & METALLURGICAL FREEPORT
                                      TX
FREEPORT
                                                                            114
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD083472266
LYONDELL CHEMICAL CHANNELVIEW
                                      TX
CHANNELVIEW
                                                                            622
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD980626022
MOTIVA PORT NECHES TERMINAL PLANT
                                      TX
PORT NECHES
                                                                              3
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TX3213820738
RED RIVER ARMY DEPOT
                                      TX
TEXARKANA
                                                                            0.2
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TXD067285973
SHELL OIL DEER PARK
                                      TX
DEER PARK
                                                                             50
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
TX6170022770
VOUGHT INTEGRATED PROGRAMS DIVISION JSF
                                      TX
DALLAS
                                                                              1
                                       N
                                       N
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
WAD041337130
BOEING COMPANY  AUBURN
                                      WA
AUBURN
                                                                             22
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
WAD041585464
BOEING EVERETT
                                      WA
EVERETT
                                                                            824
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
WVD005005483
UNION CARBIDE CORPORATION - SOUTH CHARLESTON PLANT
                                      WV
SOUTH CHARLESTON
                                                                              1
                                       N
                                       Y
                                      **
                                      **
No impacts - no RCRA or CERCLA regulated waste generation
*   Information from an EPA Region, state or local permitting agency or facility representative indicated RCRA or CERCLA waste generation but RCRAInfo data did not indicate this.
** This information was not gathered since we were able to determine the impacts based on other basic applicability criteria. *** Facility is subject to CERCLA and not RCRA. All other facilities are subject to RCRA and not CERCLA.









