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<br />7A - ATTACHMENT NO.2 <br />Page 16 <br /> <br />RCRA. The Resource Conservation and Recovery Act ("RCRA") provides <br />USEPA with authority to identify hazardous wastes; issue permits for the operation of <br />hazardous waste treatment, storage and disposal facilities; and promulgate standards for <br />generators and transporters of hazardous wastes and operators of hazardous waste <br />facilities. USEP A has delegated to the State authority to administer the RCRA program <br />and to issue hazardous waste permits under RCRA. <br /> <br />The Saltworks proposal will require decommissioning the salt production facility, <br />including the potential management and disposal of salt and bittern material. USEP A has <br />adopted pretreatment standards governing the discharge of industrial solution produced <br />through the saltmaking process to a sewer treatment plant. (40 C.F.R. ~ 415.161.) These <br />regulations do not apply to Cargill's salt production facility because there is no discharge <br />from this facility to a treatment plant. The adoption of these regulations suggests that <br />wastes containing salt or bittern may have water quality impacts. We do not know <br />whether it has been determined that these materials will qualify as hazardous wastes, or <br />be subject to regulation under RCRA. We also do not know whether other hazardous <br />waste or materials may be present. In the event the City decides to proceed with the <br />environmental review process, the City should anticipate that further details regarding the <br />decommissioning process will have to be provided. Depending on the nature of the <br />decommission/restoration plan, USEP A may have jurisdiction under RCRA. <br /> <br />Clean Air Act. Under the Clean Air Act, USEPA has promulgated National <br />Ambient Air Quality Standards for pollutants considered harmful to public health and the <br />environment. A project requiring approval of a Federal agency generally cannot result in <br />a violation of these standards, or prevent reasonable further progress towards attainment <br />of these standards. Administration of these programs and enforcement of these <br />requirements are primarily the responsibility of the States. Given the nature of the <br />Saltworks project, and the delegation of authority to the State, USEP A is unlikely to <br />assume a lead role with respect to air quality issues associated with the proposal. <br /> <br />If approved, the Saltworks project would place residential development at a site <br />adjacent to existing sources of air pollutant emissions (i.e., the U.S. 101 corridor and the <br />Port of Redwood City). USEP A does not have direct regulatory authority with respect to <br />land-use decisions involving land-use compatibility concerns. This issue is discussed <br />further below in the context of guidance issued by the California Air Resources Board. <br /> <br />Summary. USEPA's jurisdiction touches on a variety of resource issues <br />potentially implicated by the Saltworks proposal, including water quality, NPDES <br />permits, ocean dumping, hazardous waste management and disposal, and air quality. <br />Generally, USEPA would not ordinarily playa lead role in making permitting decisions <br />for projects of this sort. Rather, USEP A would provide guidance and input to the <br />permitting decisions made by other Federal or State agencies. <br /> <br />16 <br />