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J.4.2 Corrective Action Management Units EPA recently amended the regulations for RCRA facilities to allow more flexibility in treatment of waste generated during corrective actions (58 FR 8658, February 16, 1993). These regulations allow the EPA Regional Administrator to designate Corrective Action Management Units (CAMUs) at a RCRA facility for treatment of remediation wastes; however, the regulations specifically exclude using CAMUs to treat normal 'as-generated'wastes. Although these regulations were developed specifically for corrective actions at RCRA hazardous waste facilities,the regulations also may be applied as ARARs to CERCLA sites, particularly where CERCLA remediation Involves management of RCRA hazardous wastes. In the past,wastes that were removed from the ground (e.g., excavation of contaminated soils) were required to comply with the treatment standards established under the LDR. An important provision of the new regulations is the specification in 40 CFR 264.552(a)(1) and (2) that: I 1. Placement of remediation wastes into or within a CAMU does not constitute land disposal of hazardous wastes 2. Consolidation or placement of remediation wastes into or within a CAMU does not constitute creation of a unit subject to MTRs (minimum technology requirements) As a result, an area or several areas at a RCRA facility (or CERCLA site) can be designated as a CAMU and the wastes can be removed from the ground,treated, and replaced within the boundaries of that CAMU without being required to comply with the LDR treatment standards. EPA's goal in issuing these regulations Is to encourage the use of more effective treatment technologies at a specific site. The regulatory impact analysis of the CAMU regulation indicated that the regulation will result in more onsite waste management, less reliance on incineration, greater reliance on innovative technologies, and a lower incidence of capping waste in place without treatment. J.5 THE CLEAN AIR ACT (CAA) OF 1990 (42 USC 7401-7642) The CAA promulgated the following standards that may or may not be ARAB at the site due to the following reasons: • National Ambient Air Quality Standards (NAAQS). NAAQS apply to total suspended particulate, sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, and lead concentrations in ambient air, and are not applicable to individual emission sources. "Prevention of significant deterioration" (PSD) regulations may apply preconstruction guidelines and monitoring to statutory sources. • New Source Performance Standards (NSPS) were developed for specific industrial categories to provide a ceiling for emissions from new sources. • National Emission Standards for Hazardous Air Pollutants (NESHAPS) regulate asbestos, beryllium, mercury, vinyl chloride, coke oven emissions, benzene, radionuclides, and Inorganic arsenic. J.6 OCCUPATIONAL SAFETY AND HEALTH ACT (OSHA) (29 USC 651-678 AND 29 CFR PARTS 1904, 1910,AND 1926) This act provides occupational safety and health requirements applicable to workers engaged in onsite field activities. The regulations are applicable to onsite work performed during implementation of a remedial action. They are applicable to nearly all remedial action options. J-3