&EPA
              United States
              Environmental Protection
              Agency	
             Solid Waste And
             Emergency Response
             5403W
EPA510-K-92-809
March 1988
Survey of State Programs
Pertaining to
Contaminated Soils
                                      y Printed on Recycled Paper

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                                                 EPA 510-K-92-809
SURVEY OF STATE PROGRAMS PERTAINING TO CONTAMINATED SOILS
                    March 22, 1988
         U. S. Environmental  Protection Agency
          Office of Underground Storage Tanks
                  401 M Street,  S.tf.
                Washington, D.C.  20460

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     This report was prepared under the direction of Mr. Michael R.
Kalinoski of the U. S. Environmental Protection Agency and was written and
researched by Ms. Janet Dean, Ms. Rashne Baetz, Ms. Lori Bailey, and
Mr. Lee Humphrey of Midwest Research Institute, under EPA contract
No. 68-01-7383.

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           SURVEY OF STATE PROGRAMS PERTAINING TO CONTAMINATED SOILS
    I.   PURPOSE
        A telephone survey of persons in each of the 50 states and the
  District of Columbia was conducted in order to identify current policies
  and procedures pertaining to soils contaminated with petroleum and
  hazardous substances.  The purpose of this report is to describe the key
  findings and results of this survey.
        Numerous technical  and regulatory issues confront state  regulatory
  personnel  and owners and  operators of underground storage tanks  (USTs)
  containing petroleum and  hazardous substances.   These  issues include how
  the soils  contaminated  with  released  substances  are  classified (i.e., are
  soils considered hazardous waste or not),  how the determination  is made
  and who makes  it, and what type of treatment Is  allowed or required.  The
  state contaminated soils programs described In this report are undergoing
  change and further refinement as more information is known on the issues
 described above.  This survey will help the reader identify other state
 regulatory programs that appear to be effective and hopefully will provide
 some solutions to their implementation problems..
       Individuals in the states were contacted  by telephone  and questioned
 about  their procedures and policies pertaining  to soils contaminated  from
 leaking underground storage tanks.   The same questions  were  asked of  each
 participant.  Questions  were asked  about program  administration?  soil
 classification criteria; cleanup management for spills,  releases,  or
 closure;  disposal  and treatment options;  cleanup  levels; anticipated
 regulatory changes; disposal  and treatment  effectiveness; extent of the
 state contaminated soils problem; tank testing; and followup tests.  The
 results of  the survey are tabulated  in Section IV.

  II.  RESULTS
      All 50 states and the District of Columbia were contacted  by
telephone.  Summaries of the state responses for each of the  question
areas are presented below.  The table in Section IV provides  more  detailed
answers on a state-by-state basis.   The questions are divided into
administrative and technical areas.

                                     1

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       A.  Administrative
       1.  Responsible office.  This is the state agency, department, or
 office that administers the contaminated soil program; if there is not a
 state program, this is the local administrator.  Forty-eight of the
 51 survey respondents had formal programs for the management of
 contaminated soils.  The agencies responsible for the programs included
 state departments of water, health, natural resources, solid waste
 management, hazardous waste management, underground storage tanks, and
 environmental protection; local agencies; and state fire marshals.  Three
 states (Florida, Nebraska, North Carolina)  have separate programs for
 hazardous materials and petroleum products.  Three states (Alaska,
 Arkansas, West Virginia) do not have formal programs.
       2.  Management of spills, releases, or closure.   This is the party
 responsible for soil cleanup and supervision at tank closure,  and for soil
 cleanup  from spills and releases from tanks.   In many  cases, the
 department that is responsible for a state's  contaminated soils program
 also  is  responsible for cleanup management  of spills and  releases  or
 closure.  Twenty-four states oversee the  cleanup activities performed by
 the responsible party,  either the tank  owner  or local  agency.
       3.  Soil  classification criteria.   These  are  the classification
 criteria used  by the states  to determine  if the soil is hazardous  or
 nonhazardous.   Most states use visibility,  odor,  and some analytical
 method to determine if  soil  is contaminated with  petroleum products.   In
 many  states, soils  are  considered  hazardous according  to the RCRA
 characteristics  of  corrosivity, reactivity, extraction procedure (EP)
 toxicity (i.e.,  lead content),  or  ignitability.  Some  states currently are
 using the  proposed  toxicity characteristic leaching procedure (TCLP)  (see
 51 FR 21648 December 26, 1986)  to classify soils contaminated with organic
 compounds.  If soils contaminated with petroleum products exceed the RCRA
 characteristic levels, they are treated as hazardous by 46 of the
 51 survey respondents.
      4.  Cleanup levels.  These are numerical standards set by the state
for soil cleanup.  Twenty-one states have set numerical standards  for soil
cleanup.  Twenty-eight states allow the local  agency or owner to make
site-specific judgments based on either numerical criteria or subjective

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  criteria such as odor or visibility  to  set cleanup  levels.   Two states
  (Oregon, Pennsylvania) did not provide  this  information.
        5-  Anticipated regulatory changes.  Twenty-nine of the  states  are
  anticipating changes in rules and regulations governing soils  contaminated
  from leaking underground storage tanks.  Most are looking to EPA and  the
  final UST regulations for guidelines by which to design their  programs.
        6-  Extent of problem.   The states were asked for their  perspective
  on the extent of their contaminated soils problem.  Twenty-four of the
  states are experiencing problems today and anticipating very significant
  problems in the  future.   These problems include  the volume of contaminated
  soils being generated and the lack  of specific treatment  and disposal
  options  for these soils.   Seventeen states are unsure of  the extent of
  their contaminated  soils  problems,  while 10 other  states  do  not feel their
  contaminated  soils  problem is  significant.
        B.  Technical Categories
        !•  Disposal  and treatment alternatives.  These are the methods
  currently used for disposal and treatment of hazardous or nonhazardous
  contaminated soil.  Thirty-nine states treat petroleum product
  contaminated soils with aeration, either on site or off site, then either
 dispose of the soil  in a landfill or leave it on site.  Most states
 dispose of soils  contaminated  with hazardous waste  by transportation off
 site to permitted hazardous waste treatment and! disposal  facilities (RCRA
 Subtitle C).  Ten states use incineration as  a disposal method for soils.
       2.   Followup tests.   States  were asked  iflfollowup tests were  done
 to  ensure that the disposal and treatment methods were  effective.  Ten
 states require followup  testing at the release  site after a leak has been
 noticed while  nine states  require followup tests; only on a case-by-case
 basis.  Thirteen states require no followup testing.
       3.  Disposal and treatment effectiveness.  The states were asked for
 their  perspective on the effectiveness from a cost and results standpoint
 of their current disposal and  treatment alternatives.  Twenty-nine states
 are unsure about the effectiveness of their program.  Some  states (18)
feel their contaminated soil programs are working.   Most states feel  that
the extent of the  problem is just beginning to  be  known and  it will  take
time to evaluate the  effectiveness  of their programs.

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       4.  Required tank testing.  States were asked if they require
 testing to determine if tanks are leaking.  Thirty-five states surveyed
 require testing only if a release is confirmed.  Six states require
.testing at tank closure.  Ten states require periodic testing and
 monitoring of ground water or tank volumes.

 III.  DISCUSSION
       The state agencies currently implementing contaminated soil programs
 expressed the most concern over the following issues.  First, the majority
 of the states surveyed, either have or anticipate significant contaminated
 soils problems with the volume of soils to be generated and the
 availability of options to treat and dispose of them.  Second, although
 most of these state programs are currently in place, there is some
 uncertainty over their effectiveness.  The states without effective
 programs in this area are looking to the U. S. EPA to assist in program
 development especially through the final rule for USTs.  These state
 agencies need information such as alternative implementation policies and
 technical procedures to design contaminated soils programs that are
 effective and best meet their individual needs.
       Therefore, in order to provide information on alternative policy and
 technical procedures, selected state programs are described below.   These
 programs appear to be the most comprehensive and effective in dealing with
 contaminated soil from both an administrative and a technical
 perspective.  The common elements in an effective program seem to be:
 (1) responsibility for management and decision making is  clearly
 established; (2) both hazardous and nonhazardous materials are regulated;
 (3) any effective treatment and disposal alternatives are allowed for use;
 and (4) cleanup criteria are established.
       A.  Florida
       The Florida Department of Environmental  Regulations administers  the
 contaminated soils program.  Petroleum product and nonpetroleum hazardous
 material contamination are considered separately.   Soils  contaminated  with
 petroleum products are considered hazardous if they are contaminated with
 a listed waste or if they fail  the EP toxicity test for lead  or
 ignitability characteristic.  Soils contaminated with nonpetroleum

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   hazardous  chemicals  are considered hazardous if they fail  the EP toxicity
   test or the  proposed TCLP for organic  substances (including pesticides).
        Soils  contaminated by nonhazardous petroleum products are treated on
   or off site  then disposed at either a municipal  landfill or incinerator.
   On-site treatments consist of soil spreading to  allow volatilization  or in
   situ vacuum  extraction.  Off-site treatments include  volatilization in  an
   asphalt dryer and the use of a mobile incinerator.
        Several treatments are used on hazardous material contaminated  soil,
   including incineration, soil  washing with water or methylene chloride, and
  solidification (mixing soil  with a solidifying agent such as concrete or
  lime).   Contaminated  soils of this type are not placed in landfills in
  Florida;  they must  be shipped  to another state for disposal in a
  Subtitle  C  facility.
       After treatment,  soils contaminated with  nonhazardous petroleum
  products are  tested and must have  less  than 500 parts  per billion (ppb)
  total hydrocarbons and  less than 100 ppb total  aromatic hydrocarbons in
  order to be disposed  in a municipal landfill.   So  far, all  petroleum
  contaminated  soils in the state have been classified as nonhazardous after
  treatment.
       A risk  assessment is performed in all cases to determine the cleanup
  levels for each site contaminated with hazardous material.   The risk
 assessment is based  on such factors as population in the area, future land
 use,  and whether the ground water is  the future water supply for the
 area.   Ground-water  monitoring  is routinely performed as  a followup
 test.                                           ;
       B.   Rhode Island
                     - --               •                  **,
       The Rhode Island Department of Environmental  Management administers
 the contaminated  soils program.  Soils are classified as either hazardous
 or nonhazardous depending upon the lead content,; flammability, odor, and
 visibility of  the contaminant.  After excavation, contaminated soils that
 are considered hazardous may be temporarily stored on site (30 days) if
 covered with polyethylene and  placed on an impervious base.   If the soil
 is determined  to be hazardous,  it must be transported out of  the state to
a Subtitle C facility.   Currently, discussions are being held to determine
the feasibility of siting a Subtitle C  facility in Rhode Island for

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 contaminated soils disposal.   The  state  also  is  trying to determine the
 best possible treatment methods.   Contaminated soils are no longer used in
 asphalt production because the state felt that such use of these soils was
 contributing to air pollution.  Cleanup  levels for the soils are
 established on a site-by-site  basis but  usually  are visual.
      C.  Vermont
      The Vermont Department of Environmental Conservation in the Agency
 of Natural Resources administers the state's  contaminated soils  program.
 An "HNU meter" or "Photovac" calibrated  to benzene is  used to determine
 whether the soil is hazardous.  Soil may be replaced on site if  the level
 of contamination is less than  20 parts per million (ppm).   The soil  is
 hazardous waste and must be shipped to a licensed  facility under manifest
 if the level of contamination  is greater than 100  ppm.   If the soil  is
 contaminated with between 20 and 100 ppm of benzene, then  it may be
 disposed in a municipal landfill.  The state has placed a  moratorium on
 shipping hazardous wastes out of state because of  the expense to tank
 owners and the possibility that some states used the hazardous soils as
 fill in municipal landfills.  The state  is currently testing  several on-
 site programs, most notably biorestoration.
      D.  Wisconsin
      The Wisconsin Department of Natural Resources administers  the
 state's contaminated soil  cleanup program through the Bureau of  Solid
 Waste Management.  The Wisconsin program covers three types of
 contamination:  petroleum contamination,  hazardous waste contamination,
 and nonpetroleum product contamination.   Soil  contaminated with petroleum
 products is considered nonhazardous but  must be cleaned up to levels
 between 10 and 50 ppm total  hydrocarbons; a  lower cleanup level may be
 required depending upon the  applicable ground-water standards.  The soil
 is usually excavated,  and  any soil  with  lower  contamination levels
 (<50 ppm)   may be used as  landfill  cover. Soil with high contamination
 levels  (>50 ppm)  must  go to  one of  the state's newer clay-lined
 landfills.   Some  contaminated soils are used in asphalt production.  The
only other treatment currently being used is aeration of the soil to allow
volatilization and  to  decrease the  total  hydrocarbon level.

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       Any soil contaminated with wastes known to be hazardous  is removed
 from the site, if practical, until the remaining soil is at background
 levels.  The excavated material is then shipped to a Subtitle  C facility
 out of state.
       Any soils contaminated with hazardous products, such as
 trichloroethylene, are considered hazardous by Wisconsin's mixture rule
 (i.e., solid waste + hazardous waste = hazardous waste).  The cleanup
 level  may be between 1 and 10 ppm, depending upon the site and the
 contaminant of concern.   If contamination is greater than 10 ppm,  the
 responsible party must send the soil  to a hazardous waste facility, or
 submit a plan for state  approval  to reclaim the  site by "cleaning"  the
 soil with appropriate  treatment methods.   Soil that is  cleaned  up to 1 ppm
 or less  of the contaminant of concern may  be returned to the  site.   Soil
 that cannot be cleaned up  to  that  level must be  sent to  a Subtitle  C
 facility.
      As  a result  of implementation of this  program, the amount of  soil
 shipped to  Subtitle C facilities has  decreased by about  50 percent.   In
 addition, the program administrators  have developed a decision  tree for
 their district staff to assist them in site assessment and cleanup.

 IV.  TABLES SUMMARIZING INDIVIDUAL STATE RESPONSES TO THE VARIOUS
      QUESTION CATEGORIES
      The responses are organized into administrative categories (Table 1)
and technical categories (Table 2).

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r
                                                                  TABLE  1.   SUMMARY  OF  RESPONSES  ON  ADMINISTRATIVE  ISSUES
State
Alabama
Responsible office
Department of
Environs ental
Management -
Groundwater Section
Soil classifica-
tion criteria
RCRA characteristics
Management of spills,
releases, or closure
Owner/contractor -
closure/corrective
action
Cleanup levels
Site-specific: <1 ppn
hydrocarbon concentra-
tion"
Anticipated
regulatory
changes
Yes
Extent of problen
Current problen Is "fairly"
significant
                            Alaska
                            Arizona
                 00
                            Arkansas
                            California
                            Colorado
                                             Ho formal  progran
                                             Department of Environ-
                                               mental  Quality
                                             Ho formal progran
                                             Water Quality Control
                                               Board and Department
                                               of Health Services,
                                               Toxic Substances
                                               Control Division,  and
                                               Local Agency
                                             Department of Health
RCRA characteristics
RCRA characteristics for
  nonpetroleun products,
  the soils  contaminated
  with petroleum
  products are called
  "special waste* or
  nonhazardous
RCRA characteristics or
  listed waste
Local agency decides if
  hazardous or non-
  hazardous - State
  recommendations
  include:   ignitabil-
  tty, corrosivity, and
  toxicity

EP toxicity and other
  RCRA characteristics
Department  of Environ-
  mental  Control-
  closure/ corrective
  action
Hazardous - hazardous
  waste coaplfance unit;
Nonhazardous - UST/water
  pollution compliance
  unit -  closure/
  corrective action
Environmental  Field
  Services  - Hazardous
  Waste Division -
  closure/corrective
  action

Local agency - closure/
  corrective action
                                                                                                   Owner - closure/correc-
                                                                                                     tive action
                                                                                                                              Appearance and odor
Remedial  action  levels -
  total petroleum hydro-
  carbons:   10,000 ppbb
  Benzene:   67 ppb
  Toluene;   200  ppn
  Xylene:  44 ppn
  Ethylene  dibromide:
    0.05  ppb

Case-by-case
  determination
Local agency decides
                                                                                 Ho
Yes
                                                                                                                                                         Ho
Ho
                           Hone.  Owner must pro-
                             vide state with final
                             analysis for judgment
                           Yes
                                                                                                                                                                        Hot a significant problen at
                                                                                                                                                                          this point.
               Hot a significant problem
                 because ground water Is
                 very deep
                Extent of the problem is
                  uncertain
                                           Since January 1984,
                                             4,000 sites of UST leaks
                                             have been Identified
                                           Approximately 0.5 percent of
                                             tanks are reported to be
                                             leaking
                                                                                                                                                                                         (continued)

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                                                                      TABLE  1.    (continued)
 State
 '   | '       i-

 Connecticut
 Delaware
 District of
   Columbia
 Flor1dac
 Florida"1
Georgia
Hawaii
 Responsible office
—	•———________
 Department of Environ-
   mental Protection
                   Department of  Natural
                     Resources
 Department  of Consider
   and Regulatory
   Affairs,  Environnental
   Control Division
                  Bureau of Operations
                  Department of Environ-
                    mental Regulations
Hazardous waste only -
  Hazardous Waste Man-
  agement Division
No program for petroleum
  products

Department of Health -
  Hazardous Waste
  Departnent
Sod classifica-
tion criteria
                                               Visibility, odor, THC
                             RCRA characteristics
Visibility,  odor,
  ignitability
                                              EP toxiclty/proposed
                                                TCLP (organic
                                                substances)
                            On Florida list  of
                              hazardous waste
                            EP toxlcity
                            igni tabimy
                                             RCRA Appendix 9 list
                                             Petroleum products -
                                               visibility, odor, some
                                               soil sampling
                                             (Ho problens with
                                               hazardous waste tanks)
Management of spills,
releases, or closure
— — — — — — — — 	
Oil and chemical spills
unit - corrective
ftrHnn
Cleanup levels
Visibility
=======.=
Anticipated
regulatory
changes
Yes
Extent of problem
Extent of problem Is
uncertain
 Hazardous  materials
   •anagenent  unit  -
   closure

 Consultants following
   state  guidelines -
   corrective  action; UST
   Branch - closure

 EPA - now
 (Environmental Control
   Division - soon)
   closure, corrective
   action

 District offices of
   state agency and
   Bureau of Operations -
   closure/corrective
   action

 District office of  state
   agency -  closure;
 Emergency response
   section of state
   agency -  corrective
   action

Hazardous Waste Manage-
  ment Division -
  closure/corrective
  action
                           Responsible party with
                            state oversight -
                            closure/corrective
                            action
                                                                                     1 ppa of  benzene,          yes
                                                                                     toluene, xylene, and
                                                                                     ethyl benzene
                                                                                                     EPA guidance                yes
                                                                                   Based upon risk assess-
                                                                                     ment performed at each
                                                                                     site
                                                      
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                                                                    TABLE  1.    (continued)
State
Idaho
Responsible office
Division of Environment
Soil classifica-
tion criteria
RCRA characteristics.
Hanagenent of spills,
releases, or closure Cleanup levels
ResDonslhle nartv with H*7«rH™ic . urns ..HI*
Anticipated
regulatory
changes
.* VAC
Extent of problen

                   Water Quality Bureau
Illinois




Indiana





Iowa




Kansas


Kentucky
State fire narshall
Department of Envlron-
  nental  Hanagenent
Department of Natural
  Resources
Department of Health and
  Envlronnent

Division of Waste
  Hanagenent
                             CERCLA or otherwise
                             EPA listed
                            Petroleun - nonhazardous
                             unless neets one of
                             the above criteria
Hazardous - lead con-
  tent, flashpoint;
  petroleun products  are
  called "special waste"

RCRA characteristics
Visibility, odor
Sone soil sanpllng,
  sometlnes use portable
  GC

Visibility, odor,
  Ignllability

EP toxiclty, ignit-
  ablllty, nostly site
  specific
  state oversight for
  corrective  action
Closure - State Fire
  Marshall's  Office Mist
  Issue a permit for
  abandonment,  lay
  require Inspection by
  local or stati fir*
  officials

State fire marshal! -
  closure/corrective
  action
Responsible party with
  state oversight -
  corrective action
Responsible party -
  closure

State - corrective
  action; owner-closure
Bureau of Environmental
  Remediation - closure/
  corrective action
Energency response
  teas - corrective
  action; Division of
  Waste Management -
  closure
                                                                                                                               Yes
                                                                                                    Konhazardous  -  site-
                                                                                                      specific,  to  back-
                                                                                                      ground levels If
                                                                                                      feasible
                                                                                                  Hot a large percentage of
                                                                                                    leaking tanks but this Is
                                                                                                    the leading cause of
                                                                                                    ground-water contanlnatlon
                                                                                                    In Idaho
                                                                                  Analytical testing to
                                                                                    meet health-based
                                                                                    criteria
                                                       Background levels,  if
                                                         practical
Hone specified
1HC below 100 ppn
                                                                                                    Background levels on a
                                                                                                      site-specific basis,
                                                                                                      related to health and
                                                                                                      environmental consid-
                                                                                                      erations
                           Yes
                           No
                            No
No
                            No
                                           Not an extensive problem
                                           Problems are increasing as
                                             new laws are enforced
                                           Extent of the problen is
                                             uncertain
                Not an  extensive problen


                Problen is  extensive
                                                                                                                                                                (continued)

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                                                                     TABLE  1.    (continued)
State
Louisiana
Responsible office
Office of Solid and
Hazardous Waste
Hanagenent
Soil classifica-
tion criteria
EP toxlclty. Ignlt-
ablllty
Management of spills,
releases, or closure
Responsible party with
state oversight -
closure/ corrective
action
Cleanup levels
Totals BTEXf around SO
to 100 ppo or lower,
site specific
Anticipated
regulatory
changes
Yes
Extent of problem
Currently the problei
severe
J 	 —
Is
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
                  Oepartnent of Environ-
                    mental Protection
                  Department of Environ-
                    nent
                  Department of
                    Envlronnental  Quality
                    Engineering
                  Environmental  Protection
                    Bureau
                  Solid and Hazardous
                    Waste Management
Bureau of Pollution
  Control
                  Local authorities or
                    state agency (DHR)
                            Sensory  observation, HNU
                              tieter
                            Flashpoint
                           Any petroleun
                             contaalnation makes
                             soil hazardous
                            Visibility, odor
                            If gasoline - nonhazard-
                             ous  (unless leaded)
                            Haste  oils-tested for
                             lead or leachates

                            KNU meter
                                             LEL aeter (lower explo-
                                               sive Unit)
                           Reportable quantities,
                             all RCRA charac-
                             teristics
 State field investi-
   gator - corrective
   action; certified
   installer and/or
   professional flrenan
   closure

 State - closure/correc-
   tive action
Responsible party with
  state oversight -
  closure/corrective
  action

Responsible party -
  closure
State - corrective
  action
Responsible party with
  state oversight -
  closure/corrective
  action

Responsible party with
  state oversight -
  closure/corrective
  action

Owner/operator with
  state oversight -
  closure/corrective
  action
Site specific-environ-      No
  •ental and health
  considerations
BTX9 - petroleum            Ho
THC - hazardous to site
  specific cleanup
  levels

Site specific, odor         Yes
  detection
Hone specified              Yes
                                                                                   Hondetectable  levels of     Yes
                                                                                    volatlles
<10 percent LEL             yes
Site specific -             Yes
  envlronnental and
  safety considerations
Problen appears to be Severe
                                                                                                                               500 to 1,100 closures last
                                                                                                                                year had contaminated
                                                                                                                                soils
The problem is very
  extensive
                                            Greater than 90 percent
                                              leakage or overfill
                                              contamination when tanks
                                              are pulled
                                            Problen is very severe.
                                              Currently 450 sites are
                                              contaminated
                                                                                                                              Currently problem Is
                                                                                                                                extensive
Extent of problem 1s
  uncertain
                                                                                                                                                                (continued)

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                                                                     TABLE  1.    (continued)
State
Montana
Responsible office
Solid and Hazardous
Haste Bureau
Soil classifica-
tion criteria
Flashpoint, lead content
Hanageaent of spills,
releases, or closure Cleanup levels
Responsible party with Hone
state oversight -
closure/corrective
action
Anticipated
regulatory
changes
Yes
Extent of problea
Extent of problen Is
uncertain
Nebraska
Nevada
New Hanpshlre
New Jersey
New Mexico
New York
Departnent of Environ-
  mental Control - If:
Hazardous - hazardous
  waste section
Petroleun - technical
  service section

Division of Underground
  Storage Tanks
Department of Environ-
  nental Services
Division of Water
  Resources, Bureau of
  Hazardous Waste
  Management

Department of Health and
  Environment - Environ-
  mental Improvement
  Division
                  Departnent of Under-
                    ground Storage Tanks
                                              Hazardous  - RCRA
                                                characteristics if
                                                hazardous
                                              Petroleun  - visibility,
                                                odor
                                              RCRA  -  Ignltablllty,
                                                lead  content
                                              Flashpoint, sensory
                                               observatIon
RCRA - EP toxicity
  characteristics, THC,
  or total PCB's, or
  percent saturation

EP toxicity or source of
  contamination nay
  cause soil to be
  considered hazardous.
  fill petroleun con-
  taninated soil has
  passed EP toxicity
  tests.  Ho known
  nonpetroleun leaks in
  state.

Visibility, odor
  (petroleum)
                            Hazardous  -  hazardous
                              waste section
                            Petroleun  -  technical
                              service  section
Division of Underground
  Storage Tanks -
  closure/corrective
  action

Water supply and pollu-
  tion control
  division - closure/
  corrective action

Bureau of Enforcement -
  closure/corrective
  action
                                                                         Responsible party with
                                                                           local  oversight at
                                                                           closure,  state over-
                                                                           sight  for corrective
                                                                           action
                            Visual  inspection
                                                        Ho              Problen Is not very
                                                                         extensive
                                                       RCRA - Ignitability.
                                                         lead content
                                                       Total volatiles, lead
                                                                                                    Background levels
                            Visual and olfactory
                              observation after
                              aeration
No
                                                                                   Yes
                                                                                                                                Yes
Yes
                Extent of problem uncertain
                                                                                                   Problem appears  to be
                                                                                                     extensive
                                                                                                                                                Problen is very extensive
                Problem is  very  extensive
                                                       State - corrective
                                                         action;  owner-closure
                           Hone specified
                                                       No
                                                                       Problen is very extensive,
                                                                         approximately 4,000 sites
                                                                                                                                                                 (continued)

-------
                                                                                TABLE  1.    (continued)
State
North Carolina






Responsible office
Hazardous - Division of
Health and Hunan
Services - Solid and
Hazardous Waste
Management Branch
Nonhazardous - Division
of Environmental
Management
Soil classlfica- Management of spills,
tlon criteria releases, or closure Cleanup levels
RCRA characteristics - Owner/contractor THC below 100 pp>
teachability






Anticipated
regulatory
changes
No






Extent of
problem
400 Incidents are In some
phase of
disposal




treatment/





co
 North Dakota




 Ohio





 Oklahoma





 Oregon



 Pennsylvania


 Rhode Island



South Carolina
                             Department of Health  -
                               Division of Waste
                               Hanagenent  Special
                               Studies

                             State fire narshall and
                               EPA
                             Department of Health
                               (prograa Is just
                               beginning, v«ry few
                               cases  at this point,
                               no set rules)

                             Department of
                               Environmental Quality
                             Department of Environ-
                               mental Resources

                             Department of Environ-
                               mental Management
                             State Department of
                              Health and Environ-
                              mental Control
 Classify petroleum as
   nonhazardous
 Hone established yet
  considered on
  individual basis
Owner/contractor
Owner/operator (o/o)
  with state fire
  marshal! oversight  -
  closure/ corrective
  action
                            Site specific  levels
Site specific unless
  close to aquifer, then
  ground water (health,
  environmental-based)
  levels required
Intonation not obtained    Infomation not obtained    Inflation not obtained
EPA listed hazardous
  wastes

Visibility, odor, lead,
  flammabillty, some
  others If necessary

Petroleum - nonhazardous
Others - 100 ppn trigger
  level with OVA or  HNU
  analyzer
Unable to obtain this
  information

State - closure and
  corrective action
                                                                        State - with contractor
                                                                          hired by 0/0 - at
                                                                          closure only unless
                                                                          otherwise reported by
                                                                          0/0
Uiable to obtain this
  information

Visual observation
                           100 ppm THC - arbitrary
                             "clean" level
                                                       No
Yes
Infcrsation
  not
  obtained

Yes
                            Yes
                            Yes
                                                                       Problem Is not extensive
                                                                                                                                                           Problem  is consistent with
                                                                                                                                                             EPA  projections
Inforraation not obtained



Information not obtained


Problem is not extensive
                                           Will he a problem in the
                                             future
                                                                                                                                                                           (continued)

-------
                                                                     TABLE  1.    (continued)
State
South Dakota
Responsible office
Departwnt of Kater and
Natural Resources
Soil classifica-
tion criteria
RCRA characteristics
Management of spills,
releases, or closure
Owner/contractor -
closure/corrective
action
Antlclt
regulat
Cleanup levels change!
RCRA characteristics Ho
 Tennessee        Division of Groundwater
                    Protection
 Texas             Texas Hater Cowlsslon
                    and Department of
                    Health
Utah              Regulated by local
                    county Health Depart-
                    ments with variability
                    among counties.
                    Example:  Salt Lake
                    County Health Depart-
                    ment, Bureau of Hater
                    Qua!Ity

Vermont           Agency of Natural
                    Resources, Department
                    of Environmental
                    Conservation

Virginia          state Hater Control
                    Board
Washington        Department  of Ecology -
                    Four regional  offices
                    which nay vary In
                    procedure,  information
                    Is  from the Southwest
                    Region

West Virginia     Ho formal program
 Laboratory analysis of
   total BTX by GC or
   photo lonizatfon

 Petroleum - total BTX,
   Ignltabllity
 Hazardous - EPA listed
 Nonpetroleun - any
   amount

 Total hydrocarbons
 Responsible party with
  state oversight for
  corrective action

 Responsible party with
  state oversight -
  closure/corrective
  action
                            Responsible party with
                              county oversight for
                              corrective action
<10 ppn BTX
<500 ppo BTX and
  nonlgnltable
                            1  mg/1  THC  in water,
                              100 «g/l  THC  in soil
                            Yes
Yes
                            Ho
"Photovac" calibrated to    State - closure, correc-    Hone specified yet
  benzene                     tive action
RCRA guidelines for
  leaded product
RCRA characteristics,
  PCB levels.  EP toxtc-
  Hy characteristics
                                             Nonhazardous
State Water Control
  Board
Owner/contractor

Responsible party with
  state oversight -
  closure/corrective
  action
                                                                         Owner/contractor
RCRA guidelines for
  leaded (EP toxicity
  levels) products

Hone specified
                                                       Yes
                                                                                                                                Ho
                            Yes
                                                                                                                                                Extent of problem
                Problem is  not very
                  extensive


                Approxinately 130 sites
                Extent  of  the problen  is
                  uncertain
                                           Extent of the problem is
                                             uncertain
                                                                                                    Background levels
                                                                                                                                Yes
                                                                       High percent  of  closures
                                                                         have contaminated soils
                                                                                                                                                Extent of the problen Is
                                                                                                                                                  uncertain
                                           Problem is extensive and
                                             getting worse
                                                                                                                                               Problem may be severe
                                                                                                                                                                (continued)

-------
tn
           Wyoming
                                                                               TABLE  1.    (continued)
State
Wisconsin
Soil classifica-
Responslble office tion criteria
Hanagenent of spills,
releases, or closure Cleanup levels
Anticipated
regulatory
changes
Extent of problem
                               Management,  Hazardous
                               Haste Management
                               Section
                  Department of Envlron-
                   nental Quality - Water
                   Quality Division
?Parts per nil lion  In soil.
"Parts per billion  In soil.
[jNonpetroleum  products.
"Petroleim products.
Hotal hydrocarbons.
 Benzene,  toluene,  ethylbenzene, xylene.
"Benzene,  toluene,  xylene.
                                             Hazardous waste - any
                                               aaount Is hazardous
                                             Hazardous "product" -
                                               any Mount is hazard-
                                               ous by Wisconsin
                                               mixture rule
                                                        HNU neter and/or
                                                          analysis of soil
                                                          samples
Responsible party with
  state oversight -
  closure/corrective
  action
Responsible party with
  state oversight -
  closure/corrective
  action
Petroleu» - 10 to 50 pp«    Yes
  THC, site specific
  using ground water
  standards
Hazardous waste -
  background levels
"Product" - 1 to 10 ppn
  of contaminant of
  concern - site and
  contaminant specific

Olfactory levels            Yes
                                                                                                                                                          Problem is extensive
                                           Problem is severe

-------
                                          TABLE  2.   SUMMARY  OF RESPONSES  ON TECHNICAL ISSUES
         State
         Alabama
         Alaska
         Arizona
CTl
        Arkansas
        Californla
        Colorado
Disposal and treatment
effectiveness


Program currently effective
  but extent of the problem
  Is uncertain.
                           Unsure of  program's
                             effectiveness.
                          Effective from a results
                            standpoint, unsure about
                            effectiveness from a cost
                            standpoint.
                          Unsure of program's
                            effectiveness.
                          Studies currently are being
                            done to determine
                            effectiveness.
                          Unsure of program's
                            effectiveness.
Disposal and treatment
alternatives
On-slte aeration then moved
  to Subtitle D landfill for
  petroIeum-contamInated
  soils.

Aeration both on- and off-
  slte.
Hazardous to Subtitle C
  facllIty out-of-state.
Nonhazardous to Subtitle D
  landfill or asphalt plant.

Special:  evaporation after
  placing on plastic lining,
  air stripping, sent to
  Subtitle D landfill or
  reuse on site.
Nonhazardous:  Subtitle D
  landfill (If they will
  accept it).

Aeration, evaporation by
  negative pressure, or
  Incineration.
Hazardous to Subtitle C
  facility, Incinerated,
  Injection well,  or fuel
  blenders.

If treated, taken  back to
  site for refill, or to a
  Class II  or Class III
  landfill.
Hazardous to Subtitle C
  facility.
                               Hazardous:  out-of-state
                                 Subtitle C  facility.
                               Nonhazardous:   I andf)11
                                 after  solidification,
                                 volatilization, or
                                 bioreclamation.
                                                                                         Required tank testing
                                                                                         Only when a tank Is noticed
                                                                                           to have leaked.
                                                              According to Federal UST
                                                                program.
                                                              No routine testing is done.
                                                                Testing is required If a
                                                                problem is suspected.
                                                              No required testing.
Precision tests done
  annually on existing
  tanks.  New tanks are con-
  tinuously monitored.
  Monthly tests done on soil
  underneath tanks contain-
  ing hazardous chemicals.

No required testing.
                                                               Followup testing
                                No followup tests
                                  are done.
                                No followup tests
                                  are done.
                                Ground-water
                                  monitoring Is
                                  required.
                                No followup  tests
                                  are  done.
                                                                                             Followup tests are
                                                                                               site specific.
                                                              Tank owner must
                                                                provide final
                                                                soil analysis.
                                                                                                                              (continued)

-------
                                                    TABLE 2.    (continued)
State
Disposal and treatment
effectiveness
Connecticut
Delaware
Washington,
  D.C.
Florida9




Florida6





Georgia


HawaIi



Idaho
                  The program Is effective.
                  Very effective.
Unsure of program's
  effectiveness.
Unsure what the long-term
  effectiveness will be.
Programs are effective.
Unsure of program's  -_
  effectiveness.

Programs are effective.
                  Unsure of  program's
                    effectiveness.
Disposal  and treatment
alternatives
Evaporation, aeration before
  use  in Subtitle D
  landfill.

Subtitle D landfill or Sub-
  title C facility, which-
  ever is appropriate.

Hazardous:  Subtitle C
  facility.
Nonhazardous:  Subtitle D
  landfill.
No treatment at this time.

Out-of-state Subtitle C
  facility, incineration,
  soil washing,
  solidification.

Subtitle D landfill or
  incinerator, on-slte
  volatilization, vacuum
  extraction, asphalt dryer,
  mobile
Landfill (Subtitle C).


Petroleum nonhazardous
  products to Subtitle D
  landfill after aeration.

Nonhazardous:  to Subtitle D
  landfill or asphalt plant
  after removal  of free
  product by pumping and any
  treatment that the respon-
  sible party wants to use.
Hazardous:  RCRA rules.
                                                                                 Required tank testing
Annual testing for steel
  tanks >12 years old and
  a 11 new tanks.

Testing when a tank  is
  removed, abandoned, or
  retrofitted.

Unknown.
Unsure of state's testing
  requIrements.
                                                               According  to Florida's tanks
                                                                 program:   Code 1761.
                               No routine testing required.
                                                              Testing  done  only  when
                                                                 problem  is  noticed.
                                                              No  periodic  testing
                                                                required.
                                                                                              Followup testing
                                                                                                                No followup tests
                                                                                                                  are  done.
                                                                                                                No followup tests
                                                                                                                  are done.
                                Unknown.
                                                               Ground-water moni-
                                                                 toring required.
                                Ground-water  mon tu-
                                  tor Ing  required.
                               Ground-water  moni-
                                  toring  required.

                               No followup tests
                                  are  done.
                                                               No followup tests
                                                                 are done.
                                                                                                                      (continued)

-------
                                                            TABLE  2.   (continued)
         Stote
         Illinois
         Indiana
oo
Iowa




Kansas


Kentucky





Louisiana
        Maine
                  Disposal and treatment
                  effectiveness
                          Only effective on some types
                            of pollutants.
                          Unsure of program's
                            effectiveness.
                          Unsure of program's
                            effectiveness.
                          Program  Is effective.
                          Unsure of program's
                            effectiveness.
                          Program  Is effective at this
                            time.
                          Unsure of program's
                            effectiveness.
Disposal and treatment
alternatives
 Landfills, experimenting
   with aeration and soil
   washing.

 Hazardous:  to In- or out-
   of-state Subtitle C
   facility.
 Special:  To  licensed
   special waste facility
   after aeration.

 Aeration then landfill or
   added to farmland.
 Hazardous waste:  out-of-
   state Subtitle C facility.

 Aeration, venting,
   Subtitle D  landfill.

 Hazardous to Subtitle C
   facllity, petroleum
   products to Subtitle D
   facility.
 On-slte passive aeration.

 Hazardous:  In-state
   Subtitle C facility
 Nonhazardous:  industrial
   waste facility or
   Subtitle D landfill,
   aeration, venting

 Commercial landfill, public
   landfill, landspreading,
   asphalt production, road-
   bulIding, venting.
                                                                                 Required  tank testing


                                                                                 Testing at tank closure.
                                                                                No  periodic testing
                                                                                  required.
Testing at tank closure.
Test only If a problem is
  suspected.

No periodic testing
  required.
                                                                                Testing required but details
                                                                                  of the testing program not
                                                                                  disclosed.
                                                                                New tanks must have
                                                                                  monI tor Ing we 11s.
                                                                                                                        Followup testing
                                No followup  tests
                                  are  done.
                               Recommended to
                                 owner  for legal
                                 protection.
No followup tests
  are done.
Monitoring we I Is
  are installed.

Periodic followup
  tests required.
                               No followup tests
                                 are done.
                               Unknown.
                                                                                                                              (continued)

-------
                                                    TABLE  2.   (continued)
 State
Disposal and treatment
effectiveness
Disposal and treatment
alternatives
                                                                                 Required tank testing
                                                                                              Fo!lowup testing
 Maryland





 Massachusetts


 Michigan




 Minnesota




 Mississippi


 Missouri




 Montana





 Nebraska




Nevada
Venting  is an effective
  option.
Unsure of program's
  effectiveness.

Unsure of program's
  effectiveness.
Studies on program's
  effectiveness currently
  are being done.
Unsure of program's
  effectiveness.

Because there are no
  standard procedures,
  effectiveness cannot be
  determined.

Unsure of program's
  effectiveness.
Unsure of program's
  effectiveness.
                  Unsure of program's
                    effectiveness.
 Hazardous:  most to out-of-
   state Subtitle C facility.
 Nonhazardous:  Subtitle D
   landfill or  incinerator,
   on-slte forced venting.

 Subtitle C facilities out-
   of-state.

 Hazardous:  Subtitle C
   facility.
 Nonhazardous;  Type 11
   landfill.

 Petroleum-contaminated soil
   is used in asphalt produc-
   tion after incineration,
   some on-slte venting.

 Ventilation, Subtitle  D
   landfill.

 Compaction/extraction  -
   aeration,
Hazardous:  possibly
  Incineration (have not had
  any HW yet).
Nonhazardous:   on-sIte
  venting or landfarmlng.

Hazardous:  Subtitle C
  facility.
Nonhazardous:   Subtitle D
  landfill.

Landfill/aeration.
No  periodic  testing
  required.
Testing  done  according  to
  RCRA regulations.

No periodic testing
  required.
No periodic testing
  required.
No periodic testing
  required.

No periodic testing
  required.
Are in the process of
  developing requirements.
Testing required when tank
  is removed.
                                                              Testing  done only  when
                                                                problem  is noticed.
Unknown.





Unknown.


Unknown.




Unknown.




Unknown.
Site-specific
  continuous
  fflOiil I or Ing.
Unknown.
No followup tests
  required.
                                                               Site specific.
                                                                                                                       (continued)

-------
                                                             TABLE 2.   (continued)
ro
o
         State
         New .HampshI re
Disposal and treatment
effectiveness
         New York
Unsure of program's
  effectiveness.
         New Jersey        Unsure of program's
                             effectiveness.


         New Mexico        Unsure of program's
                             effectiveness.
                           Unsure of  program's
                             effectiveness.
         North Carolina    Program is effective so far.




         North Dakota      Program is effective.


         Ohl°              Program is effective.
Disposal and treatment
alternatives
Oil contaminated Is non-
  hazardous, use In asphalt
  production; gasoline con-
  taminated  Is hazardous,
  air stripping and/or
  passive aeration then ship
  to appropriate landfill,
  usually In-state.

Incinerators, oil recyclers,
  out-of-state Subtitle C
  landfill.

Saturated:  remove to solid
  waste landfill, aerate and
  use for cover.
Nonsaturated soil:   leave In
  place.

Hazardous:   Incineration,
  Subtitle C facility.
Nonhazardous:  Subtitle D
  landfill, aeration.

Hazardous:  removed to
  landfill (Subtitle C).
Nonhazardous:  on-slte
  venting.

Venting/landfill.
                                                          Hazardous:   Subtitle C
                                                            facility.
                                                          Nonhazardous:   aeration/
                                                            biorestoration.
                                                                                          Required  tank  testing
                                                                                              Followup  testing
                                                                                         No  periodic testing
                                                                                           required.
                                                              Monitoring wells set up near
                                                                some tanks.
                                                              No testing required.
                                                              No testing required.
                                                              Testing only when a problem
                                                                 is noticed.
                                                              Testing only when a problem
                                                                is noticed.

                                                              No periodic testing
                                                                required.
Unknown.
Unknown.
Unknown.
Site specific.
Some monitoring
  required.
                                                               Some monitoring
                                                                 required.

                                                               Only on large
                                                                 spills.
         Ok Iahoma
                           Program  Is  just beginning.
                                                                                                                               (continued)

-------
                                                    TABLE 2.    (continued)
State
Disposal and treatment
effectiveness
Oregon


Pennsylvania


Rhode Island


South CarolIna



South Dakota



Tennessee
Texas
Information not obtained.


Information not obtained.


Program Is effective.
Unsure of program's
  effectiveness.
Program Is effective for
  petroleum products.
                  Program Is effective.
                  Program is effective.
Disposal and treatment
alternatives
 Information not obtained.
Aeration, Subtitle D
   landfill.

If hazardous, presently ship
  to Maine or Ohio.

Hazardous:  Incinerated.
Nonhazardous:  aerated and
   landfllled.

Vent ing/landfill:  If
  hazardous, shipped out-of-
  state.

Hazardous:  >100 ppm BTX, is
  either shipped to out-of-
  state Subtitle C facility
  or aerated on an imperme-
  able base and treated.
Nonhazardous:  OO ppm and
  >100 ppm BTX, treated In
  place or taken to a sol id
  _waste landfill .or. used-for<
  asphalt.
Treated by venting, bio-
  degradation, Incineration.

Hazardous:  Subtitle C
  facility in-state or
  treatment (aeration on an
  impermeable base) before
  going to a regular
  landfIII.
Nonhazardous:   if <50 ppm
  BTX may go to a landfill
  with enough room.
                                                                                 Required  tank  testing
 Information not obtained.
Information not obtained.
                                                               They  have ongoing  tests.
Testing only if problem is
  noticed.
Testing when tank is
  removed.
                                                                                No testing  is  required.
                                                                                No testing Is required.
                                                                                              Followup testing
Information not
  obtained.

Information not
  obtained.

Site specific.
No followup
  testing is done.
Some monitoring ,is
  done.
                                                                                              No followup
                                                                                                testing is done.
                                                                                              Unknown.
                                                                                                                      (continued)

-------
                                                             TABLE 2.   (continued)
         Vermont
                           Disposal  and treatment
                           effectiveness
                           Unsure of program's
                             effectiveness.
                           Program Is effective.
ro
         Virginia


         Washington
Unsure of program's
  effectiveness.

Unsure of program's
  effectiveness.
         West Virginia      Unsure of  program's
                             effectiveness.
         Wisconsin
                           Program  is  effective.
                               Disposal and treatment
                               alternatives
 In situ vapor extraction or
   landfarmlng for petroleum
  products (have not had any
  nonfuel leaks).

Testing blorestoratlon,
  moratorium on shipping out
  until develop new regula-
  tions, nonhazardous soils
  taken to Subtitle D land-
  fill or rep Iaced on sI te
  depending on level of
  contamination.

Landfills/venting off site
  and some Incineration.

Landfarming.
No in-state landfill will
  take petroleum-
  contaminated soils.

Venting/incineration/
  landfills.

Petroleum:  aeration, then
  landfill cover, or clay-
  lined landfill, or asphalt
  production.
Hazardous waste to out-of-
  state Subtitle C facility.
Hazardous "product":  if
  >10 ppm of  contaminant  of
  concern, to Subtitle C
  facility;  If  treated to
  <1  ppm, may go back in
  hole; midrange - to
  landfill or asphalt pro-
  duction. Treatment by
  venting, bloreclamatlon,
  or  other approved methods.
                                                                                         Required tank testing
                                                                                              Pollowup testing
                                                               Unknown.
                                                                                         When problem  is noticed.
                                                                                              Unknown.
                                                                                              Site specific.
Testing required when tanks
  are removed.

No periodic testing
  required.
                                                               Testing  done only  If  someone
                                                                 notices  a problem.

                                                               Some  periodic testing of
                                                                 petroleum tanks  may be
                                                                 starting soon.
Periodic followup
  tests required.

Unknown.
                               Unknown.
                                                                                                                         Periodic  followup
                                                                                                                           tests required.
                                                                                                                               (continued)

-------
                                                            TABLE  2.   (continued)
         State
         Wyoming
Disposal  and treatment
effectiveness
Unsure of program's
  effectiveness.
Disposal  and treatment
alternatives
                                                                                        Required tank  testing
                                                         Aeration, Subtitle D  land-
                                                           fill  for nonsaturated
                                                           soils.
                               No periodic testing Is
                                 required.
                                                                                            Followup testing
Unknown.
ro
oo

-------
    V.  LIST OF TELEPHONE INTERVIEWS

        The following persons were contacted for information about their

  state's policies and procedures for the treatment and disposal of

  contaminated soils.

   1.   Alabama.  Massey,  S., Alabama Department of Environmental Management,
       with Baetz, R., MRI.   September 29, 1987.

   2.   Alaska.   Miller, 6. and S. Osborne, Alaska Department of
       Environmental  Conservation, with Baetz,  R.,  MRI.  September 29,
       1987.

   3.   Arizona.  Ceilings, T.,  Arizona Department of Environmental  Quality,
       with Baetz,  R., MRI.  September 30, 1987.

   4.   Arkansas.   Dunn, E.,  Arkansas  Department  of  Pollution Control  and
       Ecology, with  Baetz,  R., MRI.   September  30,  1987.

   5.   California.  Patton,  A., and K.  Woodhouse, California Water  Resources
       Board, Department of  Health Services, with Baetz, R.,  MRI.
       September 30,  1987.

  6.   Colorado.  Winters S., Colorado Department of Health, with Baetz, R.,
      MRI.  October 2, 1987.

  7.  Connecticut.  Lee,  C., and M. DeCaprio, Connecticut Department of
      Environmental Protection, with Baetz, R., MRI.  September 30, 1987.

  8.  Delaware.  Herman,  K., Delaware Department of Natural Resources, with
      Baetz,  R.,  MRI.  October 2, 1987.

  9.  Washington,  D.C. Padmanabha,  A., Washington, D.C.,  Department of
      Consumer and Regulatory  Affairs, with Baetz,  R.,  MRI.  September 30,
      1987.

 10.   Florida.  Kulakowski,,  Z., and  J.  Gentry,  Florida  Department of
      Environmental Regulations,  with Baetz, R.,  MRI.   October  1, 1987.

 11.   Georgia.  Langley, B., Georgia  Hazardous Waste Management  Division,
      with  Humphrey,  L., MRI.  October  5,  1987.

 12.   Hawaii.   Lau, R., Hawaii Department of Health, with Humphrey, L.,
     MRI.  October 19, 1987.

13.   Idaho.  Brower, C.,  Idaho Water Quality Bureau, with Bailey, L.,
     MRI.  October 12, 1987.

14.  Illinois.  Ayers, T.,  Illinois Division of Land Pollutants Control,
     with Humphrey, L., MRI.  October 1, 1987.
                                    24

-------
 15.  Indiana.  Scranton, M., and 6. Oliver,  Indiana Department  of
      Environmental Management, with Dean, J., MRI.   October  16,  1987.

 16.  Iowa.  Home, J., Iowa Department of Natural Resources, with
      Bailey, L., MRI.  October 5, 1987.

 17.  Kansas.  Linn, C., Kansas Department of Health  and Environment, with
      Humphrey, L., MRI.  October 2, 1987.

 18.  Kentucky.  Huckaby, A., Kentucky Natural Resources and Environmental
      Protection Cabinet, Division of Waste Management, with Dean, J.,
      MRI.  October 6, 1987.

 19.  Louisiana.  Romanowsky, P.,  Louisiana Department of Environmental
      Quality, Office of Solid and Hazardous Waste, with Bailey,  L., MRI.
      October 8, 1987.

 20.  Maine.  Cogburn, P.,  Maine Department of Environmental Protection,
      with Bailey,  L., MRI.   October 7,  1987.

 21.  Maryland.   Meade, H.,  Maryland Department of Environment, with
      Bailey, L., MRI.  October  6,  1987.

 22.  Massachusetts.   Benoit,  E.,  Massachusetts Department  of  Environmental
      Quality, with Bailey,  L.,  MRI.  October  13,,  1987.

 23.  Michigan.   Couture, A.,  Michigan Department  of  Natural Resources
      Environmental Protection Bureau, with Bailey, L., MRI.  October 6.
      1987.

 24.  Minnesota.  Kable, D., Minnesota Pollution Control Agency Solid and
      Hazardous Waste  Management Division, with Efailey, L., MRI.
      October 9, 1987.

 25.   Mississippi.  Huff, W.9 Mississippi Bureau of Pollution Control, with
      Bailey, L., MRI.  October 9,  1987.

 26.   Missouri.  Ackley, 6., Missouri Department of National Resources,
      with Dean, J., MRI.  October 6, 1987.

 27.   Montana.  Riley, J., Montana  Solid and Hazardous Waste Bureau,  with
      Bailey, L., MRI.  October 9,  1987.          \

 28.   Nebraska.  Imig, B., Nebraska Department  of Environmental  Control,
     with Humphrey,  L., MRI.  October 5,  1987.

29.  Nevada.  Biaggi, A.,  Nevada Division of Underground Storage  Tanks,
     with Humphrey,  L., MRI.  October 5,  1987.

30.  New Hampshire.   Woodbury, C.,  and R.  Barry, New  Hampshire Department
     of Environmental  Services,  with  Bailey, L., MRI.  October 6,  1987.
                                    25

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&EPA
   United States
   Environmental Protection
   Agency
   5403W
   Washington, DC 20460

   Official Business
   Penalty for Private Use
   $300

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