530-SW-90-057
LOW-LEVEL MIXED WASTE
A RCRA PERSPECTIVE FOR
NRC LICENSEES
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Washington, D.C.
1990
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CONTENTS
Page
Mixed Waste: A RCRA Perspective 2
Mixed Waste Definition 4
Commercial Mixed Waste Generators 6
The Scope of RCRA 8
RCRA Requirements 14
RCRA Implementation 18
RCRA Enforcement 20
Mixed Waste Minimization 22
Information Resources 24
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MIXED WASTE: A RCRA PERSPECTIVE
The purpose of this booklet is to
introduce specific Resource
Conservation and Recovery Act
(RCRA) requirements to potential
commercial mixed waste generators
and treatment, storage, and/or
disposal facilities. In particular, it is
designed for Nuclear Regulatory
Commission (NRC) licensees who
may not be familiar with the
Environmental Protection Agency
(EPA) regulations that apply to their
waste products. Most commercially
generated mixed waste consists of
low-level radioactive waste (LLW)
and hazardous waste combined in a
single waste matrix. These wastes are
generally produced in small
quantities.
RCRA establishes a regulatory
framework to ensure the proper
management of solid and hazardous
wastes. The RCRA program's goals
are to:
Protect human health and the
environment
• Reduce solid waste and conserve
energy and natural resources
• Reduce or eliminate the
generation of hazardous waste as
expeditiously as possible.
Under the RCRA Subtitle C program,
the U.S. EPA regulates the
management of hazardous waste from
its generation through ultimate
Potential commercial low-level
mixed waste universe
LOW - LEVEL
RADIOACTIVE
WASTE (LLW)
low-level
mixed waste
disposal. This "cradle-to-grave"
approach ensures the proper handling
and management of hazardous waste
at every step in the waste cycle,
including documentation of every
transfer of the waste through
manifests.
One particularly challenging aspect of
the RCRA program is the
management of mixed waste, which
contains both RCRA-regulated
hazardous waste and radioactive
components in one waste matrix. This
presents unique issues for waste
handlers and regulators. The
hazardous waste is subject to
regulation by EPA under RCRA and
the radioactive component is subject
to regulation by the NRC or the
Department of Energy (DOE) under
the Atomic Energy Act (AEA).
Because mixed waste generally
cannot be physically separated into
hazardous and radioactive
components, a single waste
management approach must address
both RCRA and AEA waste handling
and disposal requirements. DOE or
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state requirements may also apply.
This booklet provides an overview of
the applicability of RCRA
requirements to commercially
generated mixed waste, including
information on the types of facilities
that are likely to generate mixed
waste, the RCRA regulatory
framework and requirements, and
opportunities for pollution prevention.
For specific requirements and further
information, refer to the statutes,
federal and state regulations, and the
sources listed in the back of this
booklet.
Storage Facility
Manifest
returned to
generator to
confirm
disposal
Generator
The cradle-to-grave management system tracks hazardous
waste from its generation through ultimate disposal
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MIXED WASTE DEFINITION
AEA
RCRA
RADIOACTIVE
WASTE
HAZARDOUS
WASTE
Mixed waste contains radioactive
material subject to the AEA and
hazardous waste subject to RCRA.
A dual regulatory framework exists
for mixed waste, with EPA or
authorized states regulating the
hazardous waste and NRC, NRC
agreement states, or DOE regulating
the radioactive waste. NRC generally
administers the AEA for commercial
and non-DOE federal facilities while
DOE regulates radioactive materials at
DOE facilities.
The dual regulatory framework for
mixed waste stems from the RCRA
definition of solid waste. Hazardous
waste is defined as a subset of solid
waste. RCRA specifically excludes
from the definition of solid waste
"source, special nuclear, or byproduct
material as defined by the Atomic
Energy Act of 1954, as amended"
[RCRA Section 1004 (27)]. The AEA
MIXED WASTE
regulates source material, special
nuclear material, and byproduct
material. Classes of radioactive waste
are transuranic waste, high-level
waste, low-level waste, and spent
nuclear fuel. These wastes are subject
to regulation by the NRC.
Any class of radioactive waste that
contains a hazardous waste as defined
under Subtitle C of RCRA is
considered mixed waste. The
radioactive component of commercial
mixed waste will generally be low-
level radioactive waste.
For more information regarding the
NRC regulations resulting from AEA,
consult Title 10 of the Code of
Federal Regulations.
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Low-Level Mixed Waste Contains:
Low-level waste (LLW), defined in 10 CFR 61.2 as "radioactive
waste not classified as high-level radioactive waste, transuranic
waste, spent nuclear fuel, or byproduct material as defined in
section lie. (2) of the Atomic Energy Act"
and
Hazardous waste that is either listed as a hazardous waste in
Subpart D of 40 CFR Part 261.31-33 or which exhibits any of the
hazardous waste characteristics identified in Subpart C of 40 CFR
Part 261.20-24 (ignitability, corrosivity, reactivity, toxicity).
RCRA
AEA
RCRA Subtitle C
Mixed | Waste
I
Hazardous I
Waste j
I
Radioactive
Component
Hazardous Waste
Solid Waste
Radioactive Materials
MIXED WASTE REGULATORY FRAMEWORK
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COMMERCIAL MIXED WASTE GENERATORS
Industrial Facilities
• Pharmaceutical, Sealed Source,
and Irradialor Manufacturing
• Biotechnology Manufacturing
• Targeted Organ Research
• Fuel Storage
• Waste Processing
• Fuel Fabrication
Medical and
Academic Institutions
• Pilot Plants
• Reactors
• Laboratory Research
Nuclear Power Plants
• Routine Maintenance
• Outage Maintenance
• Health Physics
• Radiochemical
• Laboratory
• Plant Operations
Typical practices that generate mixed
waste and associated constituents are
shown in the matrix on the next page.
These practices usually involve the
removal of radioactivity from
equipment or system components or
the manufacture of radioactive
materials or products.
The hazardous waste components of
mixed waste typically are organic
solvents, metallic lead, chromate and
cadmium wastes, or corrosive liquids.
Waste oil may also be subject to
RCRA requirements if it exhibits the
hazardous characteristics or contains
hazardous constituents specified in 40
CFR Part 261. EPA's adoption of the
Toxicity Characteristic Leaching
Procedure (TCLP) for determining
toxicity (55 FR 11798) resulted in the
addition of 25 organic chemicals to
the list of hazardous constituents,
some of which may be found in
significant concentrations in used oil.
State requirements should also be
reviewed to determine the regulatory
status of waste oil.
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FACILITY TYPE
HAZARDOUS
WASTES
Organic solvents of liquid
scintillation cocktails
rv, • h • i
Lead wastes
Chromate and cadmium wastes
Chlorinated fluorocarbon wastes
(CFC)
Aqueous corrosive liquids
Waste oil *
Phenol/chloroform
WASTE GENERATING
PRACTICES
Laboratory counting procedures
Residue from research and
manufacturing/spent reagents
Cleaning of laboratory equipment
Cleaning of contaminated
components
Decontamination of lead shielding
Lead contaminated during process
Equipment/tool decontamination
Laundering garments
Backflush of resin filters and
changeouts
Cleaning of spent fuel casks and
welding rods
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* If waste oil meets RCRA characteristics for a hazardous waste or contains listed constituents.
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THE SCOPE OF RCRA
STATUTORY CHRONOLOGY
Solid Waste Disposal Act 1965
Resource Recovery Act 1970
Resource Conservation and Recovery Act (RCRA) 1976
RCRA Amendments 1980
Hazardous and Solid Waste Amendments (HSWA) 1984
Congressional concern about waste
management began with enactment of
the Solid Waste Disposal Act of 1965.
Since then, Congress has responded to
changing waste management
problems by amending the Act several
times. RCRA and the Hazardous and
Solid Waste Amendments (HSWA)
set the regulatory framework to deal
with solid waste problems in an
environmentally sound manner. The
RCRA statute (42 U.S.C. 6901 et seq.)
includes Subtitles A through J, listed
on the following page. Hazardous
waste is addressed by Subtitle C and
the regulations pursuant to Subtitle C
in Title 40 of the Code of Federal
Regulations (CFR).
Subtitle C of RCRA establishes the
"cradle-to-grave" management
program for hazardous waste. EPA
regulates hazardous waste from its
generation through its ultimate
disposal. The hazardous component
of mixed waste is subject to Subtitle C
regulations.
RCRA defines solid waste as "any
garbage, refuse, sludge from a waste
treatment plant, water supply
treatment plant, or air pollution
control facility and other discarded
material, including solid, liquid,
semisolid, or contained gaseous
material resulting from industrial,
commercial, mining, and agricultural
operations, and from community
activities," but does not include
"source, special nuclear, or byproduct
material as defined by the Atomic
Energy Act of 1954..." [RCRA
Section 1004(27)]. EPA, NRC, and
DOE interpret the exception for
source, special nuclear, or byproduct
material as referring only to the
radionuclide component, and not to
the entire waste mixture. The
radionuclides within the waste matrix
are subject to regulations pursuant to
the AEA.
A hazardous waste is defined in the
statute as "...a solid waste, or
combination of solid wastes, which
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ORGANIZATION OF THE RCRA STATUTE
Subtitle Provisions
A
B
C
D
E
F
G
H
I
J
General Provisions
Office of Solid Waste and Emergency Response; Authorities of the
Administrator
Hazardous Waste Management (includes mixed waste)
State or Regional Solid Waste Plans
Duties of the Secretary of Commerce in Resource and Recovery
Federal Responsibilities
Miscellaneous Provisions
Research Development, Demonstration, and Information
Regulation of Underground Storage Tanks
Demonstration Medical Waste Tracking Program
because of its quantity, concentration,
or physical, chemical, or infectious
characteristics may..." pose a
"substantial present or potential
hazard to human health or the
environment when improperly...
managed." [RCRA Section 1004(5)].
The Subtitle C regulations listed on
the next page set forth the framework
to identify and manage hazardous
wastes. Waste handlers should
consult the appropriate regulatory
agencies and guidance to determine if
they have mixed waste.
Once a waste is determined to be a
mixed waste, the waste handler must
comply with both AEA and RCRA
regulations.
The requirements of RCRA and AEA
are generally consistent and
compatible. However, the provisions
in Section 1006(a) of RCRA allow the
AEA to take precedence in the event
provisions or requirements of the two
acts are found to be inconsistent. EPA
interprets "inconsistencies" as being
limited to actual conflicts in the
regulations, RCRA requirements that
are inconsistent with national security
interests protected by the AEA, cases
of technical infeasibility, and cases
where a RCRA requirement can be
shown to violate the AEA policy that
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ORGANIZATION OF THE RCRA HAZARDOUS WASTE
REGULATIONS
40 CFR Part 260
40 CFR Part 261
40 CFR Part 262
40 CFR Part 263
40 CFR Part 264
40 CFR Part 265
40 CFR Part 266
40 CFR Part 267
40 CFR Part 268
40 CFR Part 270
40 CFR Part 271
40 CFR Part 272
Hazardous Waste Management System: General
Identification and Listing of Hazardous Waste
Standards Applicable to Generators of Hazardous
Waste
Standards Applicable to Transporters of Hazardous
Waste
Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities
Interim Status Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal
Facilities
Standards for the Management of Specific Hazardous
Wastes and Specific Types of Hazardous Waste
Management Facilities
Interim Standards for Owners and Operators of New
Hazardous Waste Land Disposal Facilities
Land Disposal Restrictions
EPA Administered Permit Programs: The Hazardous
Waste Permit Program
Requirements for Authorization of State Hazardous
Waste Programs
Approved State Hazardous Waste Management
radiation exposures be limited to "as
low as reasonably achievable."
HSWA significantly expanded the
scope of RCRA as it relates to
hazardous waste. The expanded
requirements that are particularly
relevant to mixed waste include land
disposal restrictions, minimum
technology requirements, and
corrective action requirements.
Land Disposal Restrictions (LDR)
HSWA requires EPA to evaluate all
listed and characteristic hazardous
wastes to determine which wastes
should be restricted from land
disposal. The Agency is required to
set treatment standards that will
diminish the toxicity of hazardous
wastes or reduce the likelihood that
hazardous constituents will migrate
from a disposal site. EPA may set
either a concentration level or a
treatment method as the standard. The
restricted waste must be treated to the
promulgated standard prior to land
disposal.
In addition to prohibiting the land
disposal of hazardous wastes without
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proper treatment, the LDR program
prohibits the storage of restricted
wastes unless the storage is for the
sole purpose of accumulating suffi-
cient quantities for proper recovery,
treatment, or disposal of the waste.
LDR regulations currently apply to
mixed wastes that contain spent
solvents, dioxins, or California list
wastes (halogenated wastes, certain
metal-bearing wastes, polychlorinated
biphenyls, and cyanide and corrosive
wastes).
Other hazardous wastes were placed in
three groups known as the First,
Second, and Third Thirds for which
treatment standards were issued on a
schedule concluding on May 8,1990.
On that date, EPA issued a two-year
national capacity variance for mixed
wastes based upon a determination
that there is inadequate treatment
capacity available for these wastes.
The waste covered under this variance
must be stored in accordance with
RCRA requirements until treatment or
disposal capacity becomes available.
This variance applies to all mixed
waste except those for which specific
treatment technologies are identified
and those which fall under the land
disposal restrictions for spent solvents,
dioxins, and California list wastes.
EPA established four treatability
groups for types of mixed waste that
cannot be treated with the best demon-
strated available technologies (BOAT)
for the hazardous waste component
involved. One of the groups ad-
dresses high-level mixed waste, the
others address low-level mixed waste.
They are:
• Macroencapsulation: which is
the BDAT standard for radioac-
tive lead solids. This entails ap-
plying surface coating materials to
reduce surface exposure to poten-
tial leaching media.
• Amalgamation: which is the
BDAT for radioactive elemental
mercury. Combination with rea-
gents such as copper, zinc, nickel,
gold, and sulfur results in a semi-
solid amalgam that will reduce
potential emissions of mercury
vapors.
• Incineration: which is the BDAT
standard for radioactive hydraulic
oil contaminated with mercury.
In addition, EPA has determined that
mixed waste with metals can be
treated through chemical precipitation
and stabilization, and mixed waste
with organics can be treated by
incineration or carbon adsorption.
Finally, the land disposal restriction
rule states that the RCRA-regulated
hazardous portion of all mixed waste
must meet the appropriate treatment
standards for all applicable waste
codes before land disposal. Problems
that arise relating to achieving the
treatment levels specified by EPA for
the hazardous portion of mixed waste
can be addressed through either a
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rulemaking or site-specific treatability
variance. Mixed waste for which ade-
quate treatment capacity is not avail-
able must be stored in accordance
with RCRA storage requirements until
treatment capacity becomes available
or a site-specific variance is granted.
Minimum Technology Standards
HSWA also sets forth specific
structural and design requirements for
Subtitle C treatment, storage, and
disposal (TSD) facilities. These
minimum technology standards
require landfills and surface
impoundments to contain two or more
liners, a leachate collection system,
and a ground water monitoring
system. Landfills are required to have
two leachate collection systems.
Landfills in use prior to promulgation
of the minimum technology standards
are exempt from these requirements.
Existing surface impoundments,
however, must be retrofitted to meet
the minimum technology
requirements or taken out of service.
Mixed waste facilities are subject to
these minimum technology standards.
EPA's RCRA requirement for a
double liner and leachate collection
system and NRC's requirement that
radioactive waste not come in contact
with liquids present unique design
challenges for mixed low-level waste
disposal facilities. EPA and NRC
issued joint guidance on a conceptual
design approach that meets minimum
technology requirements. This
approach includes placing the mixed
low-level waste above the original
ground surface in tumulus blended
into the site topography. The
conceptual design, which would have
to be adapted to the site-specific
conditions, also fulfills both EPA and
NRC requirements to assure long-term
stability and require minimal
maintenance after site closure.
Corrective Action
The corrective action provisions of
HSWA apply to facilities that handle
mixed waste, and are designed to
address releases from waste
management operations in a timely
manner. Corrective actions are
required whenever hazardous waste or
constituents from a RCRA-regulated
unit or solid waste management unit
(SWMU) are released into the
environment.
The RCRA corrective action process
includes the following stages:
• RCRA Facility Assessment
(RFA): During the RFA, EPA or
state investigators gather
information on solid waste
management units and other areas
of concern at RCRA facilities,
evaluate this information to
determine whether there are
releases that warrant further
investigation or action, and
determine the need to proceed to a
RCRA Facility Investigation.
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RCRA Facility Investigation
(RFI): The RFT generally
includes characterization of the
hydrogeological setting, the type
and concentration of hazardous
waste released, the rate and
direction at which the
contaminants are migrating, and
the extent of migration that has
occurred. Information generated
during the RFI is used to
determine the potential need for
corrective measures and to aid in
the selection and implementation
of these measures.
Corrective Measures Study
(CMS): If the potential need for
corrective measures is verified
during the RFI process, the owner
or operator is then responsible for
performing a CMS. During the
CMS, the owner or operator
identifies, evaluates, and
recommends specific corrective
measures based on a detailed
engineering evaluation.
• Corrective Measures
Implementation (CMI): The
CMI includes designing,
constructing, operating,
maintaining, and monitoring the
performance of the corrective
measure(s).
EPA has the authority to require
corrective actions at permitted and
interim status facilities and to impose
fines for violations or noncompliance.
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RCRA REQUIREMENTS
RCRA
Generators
Transporters
Treatment j
Storage j» Facilities
Disposal J
Generators
Under RCRA regulations, mixed
waste generators, like other hazardous
waste generators, must determine if
their waste is hazardous and must
oversee its ultimate disposition.
• The generator must obtain an EPA
identification number for each
facility at which hazardous waste is
generated.
• Department of Transportation
requirements for transport of
hazardous and radioactive waste
must be followed.
• Generators must prepare a Uniform
Hazardous Waste Manifest (EPA
Form 8700-22) that will accompany
the waste to its final destination and
will be returned to the generators to
verify that the waste has been
treated and disposed of.
• Every 2 years, generators must
report on their hazardous mixed
waste activities to the authorized
state agency or EPA.
• Generators may accumulate wastes
in accordance with certain
requirements up to 90 days (180 or
270 days for Small Quantity
Generators, depending on distance
transported) without a permit.
In addition, all generators must
comply with the basic requirements
for labeling, marking, recordkeeping,
and reporting specified in 40 CFR
262. If the generator is also a
treatment, storage, or disposal facility,
it must meet the requirements for
emergency preparedness, ground
water protection, closure, and other
requirements specified in 40 CFR 264
or 265.
Currently, under the RCRA Subtitle C
program, there are three categories of
generators based on the total quantity
of hazardous waste, not just mixed
waste, that is produced in one
calendar month:
Conditionally-exempt small quantity
generators (< 100 kg/moX Facilities
that generate no more than 100
kilograms (about 220 pounds or 25
gallons) of hazardous waste and no
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more than 1 kg (about 2 pounds) of
acutely hazardous waste in any
calendar month. Conditionally
exempt SQGs (generating less than
100 kg of hazardous waste in a
calendar month) are required to
identify the hazardous waste
generated, send this waste to an
approved hazardous waste facility,
and never accumulate more than
1000 kg of waste on the property.
Small quantity generators (100-1000
kg/mo). Facilities that generate more
than 100 kg and less than 1000 kg
(between 220 and 2200 pounds) of
hazardous waste and no more than 1
kg of acutely hazardous waste in any
month. Small quantity generators are
exempt from some of the RCRA
offsite disposal requirements for
larger generators. Exemptions
include, for example, reduced
recordkeeping requirements and
extended accumulation times (before
interim status or a permit is required).
Large quantity generators (> 1000
kg/mo). Facilities that generate 1000
kg (about 2200 pounds) or more of
hazardous waste or more than 1 kg of
acutely hazardous waste in any
month.
Acutely hazardous wastes have been
determined by EPA to be so
dangerous in small amounts that they
are subject to the same requirements
as large amounts of hazardous waste.
Examples include wastes from
pesticide formulators and some
dioxin-containing wastes.
For further information on the
regulations that apply to mixed waste
generators, consult 40 CFR Part 262,
Standards Applicable to Generators
of Hazardous Waste.
Treatment, Storage, and Disposal
Facilities
Treatment, storage, and disposal
(TSD) facilities that handle mixed
waste are subject to EPA's permitting
system to ensure safe operations.
The three functions are defined in 40
CFR Part 260.10 as follows:
Treatment: Any method, technique,
or process, including neutralization,
designed to change the physical,
chemical, or biological character or
composition of any hazardous waste
so as to neutralize such waste; or so
as to recover energy or material
resources from the waste or render
such waste non-hazardous or less
hazardous; safer to transport, store,
or dispose of; amenable for recovery;
amenable for storage; or reduced in
volume.
Storage: The holding of hazardous
waste for a temporary period, at the
end of which the hazardous waste is
treated, disposed of, or stored
elsewhere.
Disposal: The discharge, deposit,
injection, dumping, spilling, leaking,
or placing of any solid waste or
hazardous waste into or on any land
or water such that the waste or any
constituent thereof may enter the
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environment or be emitted into the air
or discharged into any waters,
including ground waters.
TSD is the last link in the cradle-to-
grave hazardous waste management
system. In order to handle mixed
wastes, they must obtain a permit and
abide by TSD regulations.
Prevent the entry of unauthorized
personnel into the facility by
installing fences and surveillance
systems and by posting warning
signs
Periodically inspect the facility to
identify any problems
There are two sets of TSD regulations: • Adequately train employees
Interim Status Standards - These are
self-implementing requirements which
are found in 40 CFR Part 265. Interim
status allows owners and operators of
certain existing facilities to continue
operating until their permit application
is issued or denied (40 CFR 265.1).
The applicability of interim status
requirements to mixed waste is
clarified in 53 FR 37045 (see
references).
Permit Standards - These are facility-
specific "design and operating"
requirements incorporated into a
facility permit. The performance
standards in the regulations serve as
guidelines for permit writers in setting
the specific design and operating
requirements through "best
engineering judgment."
The permit system ensures that mixed
waste facilities meet RCRA standards
for proper waste management. TSD
facilities must, among other things:
• Analyze and identify wastes prior
to treatment, storage, or disposal
(waste analysis plan)
• Prepare a contingency plan for
emergencies and establish other
emergency response procedures
Comply with the manifest system
and with various reporting and
recordkeeping requirements
Comply with technology
requirements, such as installing
double liners and leachate
detection and collection systems
• Undertake any necessary
corrective action for the site.
Permits will also contain requirements
specific to the particular mixed waste
facility.
RCRA also specifies stringent
requirements associated with closing
down of mixed waste facilities to
minimize the potential for adverse
environmental consequences after
closure. RCRA requires owners to:
• Acquire sufficient financial
assurance mechanisms (such as
trust funds, surety bonds, letters
of credit, closure insurance, or
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financial test and corporate system maintenance, and security
guarantee) to pay for closing of measures after the facility closes
the facility
• Obtain liability insurance to cover
Be prepared to pay for 30 years of third-party damages that may
ground water monitoring, waste arise from accidents or
mismanage-ment.
RCRA TECHNICAL REQUIREMENTS FOR TSDs
Permit Standards - 40
Containers
Tanks
Surface Impoundments
Waste Piles
Land Treatment
Incinerators
Landfill
Miscellaneous Unit
Interim
Containers
Tanks
Surface Impoundments
Waste Piles
Land Treatment
Landfills
Incinerators
Thermal Treatment
Underground Injection
Chemical, Physical, &
Biological Treatment
Subpart I
Subpart J
Subpart K
Subpart L
Subpart M
Subpart O
Subpart N
Subpart X
Status Standards -
Subpart I
Subpart J
Subpart K
Subpart L
Subpart M
Subpart N
Subpart O
Subpart P
Subpart R
Subpart Q
CFR Part 264
264.170-264.178
264.190-264.199
264.220-264.231
264.250-264.259
264.270-264.283
264.340-264.351
264.300-264.317
264.600-264.603
40 CFR Part 265
265.170-265.177
265.190-265.201
265.220-265.230
265.250-265.257
265.270-265.282
265.300-265.316
265.340-265.352
265.370-265.383
265.430
265.400-265.406
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RCRA IMPLEMENTATION
The federal RCRA program was
developed to be implemented by the
states, with EPA oversight. To be
authorized to implement the RCRA
program, a state must develop a
program that is equivalent to, no less
stringent than, and consistent with the
federal program. State programs may
be more stringent than the federal
requirements. The program must be
available for public review and
comment before it is approved by
EPA. Once authorized, the state has
primary responsibility for
implementation and enforcement of
RCRA requirements within its
boundaries. However, EPA retains
oversight and enforcement authority.
Also, state programs must be modified
in accordance with subsequent
changes in the federal statutory or
regulatory requirements. EPA
maintains responsibility for any
portion of the RCRA program for
which a state has not received
authorization.
There are two parts of the RCRA
program that states implement, the
base program (pre-HSWA), and the
Hazardous and Solid Waste
Amendments of 1984 (HSWA).
The hazardous components of mixed
wastes come under RCRA's base
program. As of July 1990, 20 states
and 1 territory (Guam) have been
authorized to regulate mixed waste.
Mixed wastes are currently regulated
under RCRA by EPA in those states
and territories lacking base
authorization. In a state with base
authorization, but without an
approved mixed waste program, the
state may have program requirements
that apply to mixed wastes, but they
are not regarded as RCRA require-
ments. The date when a state receives
mixed waste authorization also
determines when a facility must be in
existence to qualify for interim status.
A state must have an approved mixed
waste program to complete the base
program requirements before it is
eligible for HSWA approval. Five
states have been authorized to
implement the HSWA corrective
action program; these states are
Georgia, Colorado, Minnesota, Idaho,
and Utah. RCRA program changes,
such as the the toxicity characteristic
revisions adopted by EPA in March
1990 (55 FR 11798), may be
regulated by EPA in all states until
authorized states have incorporated
the changes into their own programs.
For complete information on a state's
authorization status and specific
requirements, consult with appropriate
state and regional contacts listed in
the back of this booklet.
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REGULATORY RESPONSIBILITIES
EPA Headquarters
Develop RCRA regulations
Review and approve state hazardous waste programs
• Oversee regional programs
Maintain Hazardous Waste Data Management System (HWDMS), which houses
data on all RCRA permitted and interim status facilities
• Provide technical, policy, and programmatic support to the regions and states.
EPA Regions
• Review and oversee state hazardous waste programs
• Review facility permit applications in states without RCRA authorization
Enforce federal and approved state programs
• Implement the base RCRA program and HSWA program in states without
authorization.
States
• Implement EPA-authorized RCRA program
• Modify state program to respond to changes in federal requirements
• Review facility permit applications
• Enforce regulatory and permit requirements
• Apply for mixed waste authorization if a RCRA-authorized state.
STATES AUTHORIZED TO IMPLEMENT RCRA
EPA implements: stale not authorized to implement base RCRA or mixed waste programs
RCRA authorized state without mixed waste authorization
RCRA authorized state with mixed waste authorization as of July 1990
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RCRA ENFORCEMENT
Enforcement Authorities
RCRA has three main types of
statutory enforcement authorities, all
applicable to the hazardous
component of mixed wastes. These
include inspection and information
gathering, compliance, and corrective
action authorities:
Inspections and Information
Gathering: Section 3007 of RCRA
provides authority to EPA and
authorized states to inspect
facilities or obtain information
from anyone who has handled or
is handling hazardous waste,
including mixed waste, in order to
determine compliance with
RCRA. Under Section 3013 of
RCRA, EPA may require
monitoring, analysis, and testing
by the owner of any site where
hazardous waste is stored, treated,
or disposed.
Compliance: Section 3008(a) of
RCRA gives EPA authority to
enforce federal or RCRA-
authorized state requirements
under Subtitle C. Section 3008(a)
is used to bring a hazardous waste
facility into compliance and can
be used to assess a penalty of up
to $25,000 per day for each
violation.
Corrective Action: Section
3008(h) of RCRA is the interim
status corrective action authority
which allows EPA to respond to a
release of hazardous waste or
hazardous constituents into the
environment by requiring
corrective action. EPA may shut
down a facility's operations under
this section and can assess a
penalty of up to $25,000 per day
for each violation. Section
3004(u) provides similar authority
for releases at permitted facilities,
including requiring a schedule for
compliance and assurances of
financial responsibility for
completing the corrective action.
Section 3004(v) states that
corrective action must be taken
beyond the facility boundary if
necessary to protect human health
and the environment. Section
7003 allows EPA to act in the
event that a hazardous waste
presents an imminent and
substantial endangerment to health
or the environment.
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• Citizen Suits: Under the authority
of Section 7002, citizens may
commence civil actions against
violators of RCRA requirements.
Enforcement Options
EPA and RCRA-authorized states
have several enforcement options
available to ensure compliance with
RCRA's waste management system.
EPA may impose civil and criminal
penalties, issue orders, and seek
imprisonment of violators if
violations of RCRA occur.
• Administrative actions;
nonjudicial enforcement options
which include informal actions
such as letters or phone calls from
EPA notifying facilities of
noncompliance or the issuance of
formal administrative orders.
• Civil actions: enforcement actions
that are filed against a facility
through civil law suits.
• Criminal actions: lawsuits or other
criminal proceedings brought
against a facility for a knowing
violation of specified hazardous
waste requirements. Examples
include providing false
information to EPA, or
transporting hazardous waste
without a manifest or to a facility
without a permit.
All of these enforcement options are
available to EPA and the states and
are applicable to mixed waste
generators and handlers of all sizes.
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MIXED WASTE MINIMIZATION
HSWA mandates that waste
minimization be an integral part of the
operations of facilities generating and
handling hazardous waste, including
mixed waste.
EPA has implemented a nationwide,
multimedia, pollution prevention
policy emphasizing reduction of
waste at its source, recycling and
reuse of hazardous materials to the
maximum extent possible, and
minimizing the volume and toxicity of
waste that is generated. Waste
minimization, part of the overall
pollution prevention program,
specifically addresses the reduction of
hazardous wastes.
Hazardous and mixed waste
generators who work toward these
goals can realize the benefits of
decreased liabilities associated with
waste disposal and radiation exposure,
and decreased waste management
costs. The public image of a company
can also be bolstered by its
commitment to environmental quality
as demonstrated through such
pollution prevention practices.
Hazardous waste generators are
required to submit biennial reports
describing efforts undertaken to
reduce the volume and toxicity of the
waste they generate and the changes
in volume and toxicity actually
achieved. Owners and operators of
hazardous waste treatment, storage, or
disposal facilities must certify that
there is a waste minimization program
in place and that the TSD method
proposed minimizes the present and
future threat to human health and the
environment.
A pollution prevention program
begins with a waste minimization
assessment. This entails a detailed
evaluation of the facility's processes
and identifies the potential for
reducing wastes at the point at which
they are actually generated.
The success of a waste minimization
program may depend on a
commitment by senior management to
ensure that the program addresses
facility-wide issues and maximizes
use of resources within the facility.
For example, a nonhazardous material
could be substituted for a hazardous
material, or the material could be
obtained from an onsite source with
excess stock that would otherwise
have become waste.
Waste segregation can ensure that
hazardous wastes are not mixed with
nonhazardous wastes, radioactive
wastes are not mixed with
nonradioactive wastes, and recyclable
items are identified.
Recycling includes techniques to
return materials to the originating
process or to another process, hi
some cases, materials can be
reclaimed from a potential waste for
reuse.
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HAZARDOUS WASTE MINIMIZATION TECHNIQUES
Inventory Management and Improved Operations
• Inventory and trace all raw materials
• Purchase more nontoxic production materials
• Provide waste minimization/reduction training for employees
• Improve material receiving, storage, and handling practices
Modification of Equipment
• Install equipment that produces minimal or no waste
• Modify equipment to enhance recovery or recycling options
• Redesign equipment or production lines to produce less waste
Improve operating efficiency of equipment
• Maintain strict preventive maintenance program
Production Process Changes
Substitute nonhazardous for hazardous raw materials
Segregate wastes by type for recovery
• Eliminate sources of leaks or spills
• Separate hazardous from nonhazardous and radioactive from
nonradioactive wastes
• Redesign or reformulate end products to be less hazardous
• Optimize reactions and raw material use
Recycling and Reuse
Install closed-loop systems
• Recycle onsite for reuse
• Recycle offsite for reuse
• Exchange wastes
Treatment to Reduce Toxicity and Volume
• Evaporation
• Incineration
• Compaction
• Chemical conversion
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INFORMATION RESOURCES
For further information regarding the management of mixed waste, refer to the
documents listed below or contact the appropriate EPA, NRC, or state offices
listed on the following pages.
Brookhaven National Laboratory. An Analysis of Low-Level Wastes: Review of
Hazardous Waste Regulations and Identification of Radioactive Mixed Wastes.
NUREG/CR-4406. December 1985.
Brookhaven National Laboratory. Management of Radioactive Mixed Wastes in
Commercial Low-Level Wastes. NUREG/CR-4450. January 1986.
Brookhaven National Laboratory. Document Review Regarding Hazardous
Chemical Characteristics of Low-Level Waste. NUREG/CR-4433. March
1986.
Brookhaven National Laboratory. Evaluation of Potential Mixed Wastes
Containing Lead, Chromium, Used Oil, or Organic Liquids. NUREG/CR-
4730. January 1987.
51 Federal Register 24504. State Authorization to Regulate the Hazardous
Components of Radioactive Mixed Wastes Under the Resource Conservation
and Recovery Act. July 3, 1986.
52 Federal Register 15937. Radioactive Waste; Byproduct Material. May 1,
1987.
53 Federal Register 37045. Clarification of Interim Status Qualification
Requirements for the Hazardous Components of Radioactive Mixed Wastes.
September 23, 1988.
55 Federal Register 11798. Identification and Listing of Hazardous Waste;
Toxicity Characteristic Revisions. March 29,1990.
55 Federal Register 22520 . Land Disposal Restrictions for Third Third
Scheduled Wastes. June 1, 1990.
Office of Technology Assessment, U.S. Congress. Partnerships Under
Pressure: Managing Commerical Low-Level Radioactive Waste. Washington,
D.C.: U.S. GPO. (OTA-O-426). November 1989.
24
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OSWER Directive 9432.00-2. Joint EPAINRC Guidance on the Definition and
Identification of Commercial Mixed Low-Level Radioactive and Hazardous
Waste. March 1990.
OSWER Directive 9487.00-8. Joint NRCiEPA Guidance on a Conceptual
Design Approach for Commercial Mixed Low-Level Radioactive and
Hazardous Waste Disposal Facilities. September 1987.
OSWER Directive 9480.00-14. Combined NRCIEPA Siting Guidelines for
Disposal of Commercial Mixed Low-Level Radioactive and Hazardous Waste.
June 1987.
OSWER Directive 9541.00-6. State Program Advisory (SPA) #2 - RCRA
Authorization to Regulate Mixed Waste. July 1987.
Rogers and Associates Engineering Corporation. The Management of Mixed
Waste in the Nuclear Power Industry. Prepared for Nuclear Management and
Resource Council, Inc., Salt Lake City, Utah: RAE-8807-1. January 1989.
Rogers and Associates Engineering Corporation. Management Practices and
Disposal Concepts for Low-Level Radioactive Mixed Waste: A Background
Report. Prepared for the Office of Technology Assessment. Salt Lake City,
Utah: RAE-8830-1. March 1989.
U.S. Environmental Protection Agency. RCRA Orientation Manual. 1990
Edition. Washington, DC: U.S. Government Printing Office.
U.S. Environmental Protection Agency. Solving the Hazardous Waste
Problem: EPA's RCRA Program. Washington, DC: Office of Solid Waste.
EPA/530-SW-86-037. November 1986.
U.S. Environmental Protection Agency. Waste Minimization: Environmental
Quality and Economic Benefits, Washington, DC: OSWER. EPA/530-SW-87-
026. October 1987.
U.S. Environmental Protection Agency. Land Disposal Restrictions: Summary
of Requirements. Washington, DC: Office of Solid Waste and Emergency
Response. OS-520. June 1989.
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EPA CONTACTS
EPA Headquarters
RCRA Hotline
800-424-9346 (toll free)
382-3000 in Washington, DC
U.S. Environmental Protection Agency
Office Waste Programs Enforcement
401 M Street, SW (OS-520)
Washington, DC 20460
(202) 382-4849
EPA REGIONAL OFFICES
EPA Region 1
Waste Management Division (HHA)
John F. Kennedy Building
Boston, MA 02203
(617) 565-3715
EPA Region 2
Air and Waste Management Division
26 Federal Plaza
New York, NY 10278
(212) 264-2657
EPA Region 3
Hazardous Waste Management Division
(3HWOO)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
EPA Region 4
Air and Hazardous Materials Division
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
EPA Region 5
Waste Management Division (SH13)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
EPA Region 6
Hazardous Waste Management Div. (6H)
Inter First Two Building
1201 Elm Street
Dallas, TX 75270
(214) 655-6444
EPA Region 7
Waste Management Division
726 Minnesota Avenue
Kansas City, KS 66101
(913)236-2800
EPA Region 8
Air and Hazardous Materials Division
One Denver Place Suite 1300
999 18th Street
Denver, CO 80202
(303)293-1603
EPA Region 9
Toxics and Waste Management Division
(T-l)
215 Fremont Street
San Francisco, C A 94105
(415) 744-8071
EPA Region 10
Hazardous Waste Division
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-1200
NRC CONTACTS
NRC Headquarters
U.S. Nuclear Regulatory Commission
Division of Low-Level Waste
Management and Decommissioning
Washington, DC 20555
(301) 492-0557
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NRC REGIONAL OFFICES
U.S. Nuclear Regulatory Commission
Region 1
475 Allendale Road
King of Prussia, PA 19406
(215) 337-5000
U.S. Nuclear Regulatory Commission
Region 2
101 Marietta Street, Suite 2900
Atlanta, GA 30323
(404)331-5000
U.S. Nuclear Regulatory Commission
Region 3
799 Roosevelt Road
GlenEllyn,IL 60137
(312) 790-5500
U.S. Nuclear Regulatory Commission
Region 4
Parkway Central Plaza Bldg.
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
(817)860-8100
U.S. Nuclear Regulatory Commission
Region 5
1450 Maria Lane Suite 210
Walnut Creek, CA 945%
(415)943-3700
STATE AND TERRITORIAL
AGENCIES
ALABAMA
Dept. of Environmental Management
Land Division
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36130
Bureau of Radiological Health
Environmental Health Administration
Room 314, State Office Building
Montgomery, AL 36130
ALASKA
Dept. of Environmental Conservation
Air and Solid Waste Management
3200 Hospital Drive
P.O. Box O
Juneau,AK 99811
AMERICAN SAMOA
Environmental Quality Commission
Government of American Samoa
Pago Pago, American Samoa 96799
ARIZONA
Arizona Radiation Regulatory Agency
4814 South 40th Street
Phoenix, AZ 85040
Arizona Dept. of Environmental Quality
Office of Waste Programs
2005 North Central Avenue
Phoenix, AZ 85004
ARKANSAS
Dept. of Pollution Control and Ecology
Hazardous Waste Division
8001 National Drive
P.O. Box 9583
Little Rock, AR 72209
Division of Radiation Control and
Emergency Management
Arkansas Department of Health
4815WestMarkham
Little Rock, AR 72205-3867
CALIFORNIA
California Dept. of Health Services
Toxic Substances Control Division
400 P Street
Sacramento, CA 94234
California State Water Resources Control
Board
901 P Street
P.O. Box 100
Sacramento, CA 95801
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California Waste Management Board
1020 Ninth Street, Suite 300
Sacramento, CA 95814
California Radiological Health Branch
Department of Health
714 P Street, Room 498
Sacramento, CA 95814
COLORADO
Colorado Department of Health
Waste Management Division
4210 E. llth Avenue
Denver, CO 80220
Radiation Control Division
Office of Health Protection
Department of Public Health
4210 East llth Avenue
Denver, CO 80220
COMMONWEALTH OF NORTHERN
MARIANA ISLANDS
Division of Environmental Quality
Commonwealth of the Northern Mariana
Islands
Office of the Governor
Saipan, Mariana Islands 96950
CONNECTICUT
Dept. of Environmental Protection
Bureau of Waste Management
State Office Building
165 Capitol Avenue
Hartford, CT 06106
Connecticut Resource Recovery Authority
179 Allyn Street, Suite 603
Professional Building
Hartford, CT 06103
DELAWARE
Dept. of Natural Resources and
Environmental Control
Solid Waste Management Branch
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
DISTRICT OF COLUMBIA
Association of State and Territorial Solid
Waste Management Officials
Suite 345
Hall of the States
444 North Capitol Street, NW
Washington, DC 20001
Dept. of Consumer and Regulatory
Affairs
Pesticides and Hazardous Waste Materials
Division
614 H Street NW, Room 505
Washington, DC 20001
FLORIDA
Dept. of Environmental Regulation
Bureau of Waste Planning and Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32399
Office of Radiation Control
Dept. of Health & Rehabilitative Services
State Health Office
1317 Winewood Boulevard
Tallahassee, FL 32399-0700
GEORGIA
Land Protection Branch
Industrial and Hazardous Waste
Management Program
Floyd Towers East
205 Butler Street, SE
Atlanta, GA 30334
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Radiological Health Section
Department of Human Resources
Room 600
878 Peachtree Street
Atlan(a,GA 30309
GUAM
Guam Environmental Protection Agency
P.O. Box 2999
Agana,Guam 96910
HAWAII
Dept. of Health
Environmental Health Division
P.O. Box 3378
Honolulu, ffl 96801
IDAHO
Department of Health and Welfare
Bureau of Hazardous Materials
450 West State Street
Boise, ID 83720
Compliance Section
Idaho Dept. of Health and Welfare
Statehouse
Boise, ID 83720
ILLINOIS
Environmental Protection Agency
Division of Land Pollution Control
2200 Churchill Road
P.O. Box 19276
Springfield, DL 62794
Department of Nuclear Safety
1035 Outer Park Drive
Springfield, IL 62704
INDIANA
State Board of Health
Division of Land Pollution Control
1330 West Michigan Street
Indianapolis, IN 46206
Department of Environmental MgmL
105 South Meridian Street
Indianapolis, IN 46225
IOWA
Dept. of Air, Water, and Waste Mgmt.
900 East Grand Avenue
Henry A. Wallace Building
DesMoines,IA50319
Bureau of Radiological Health
Iowa Department of Health
Lucas State Office Building
DesMoines, IA 50319
KANSAS
Dept. of Health and Environment
Bureau of Waste Management
Forbes Field, Building 740
Topeka,KS 66620
Bureau of Air Quality and Radiation
Control
Dept. of Health & Environment
Forbes Field, Building 740
Topeka, Kansas 66620
KENTUCKY
Cabinet for Natural Resources and
Environmental Protection
Dept. of Environmental Protection
Division of Waste Management
18 Reilly Road
Frankfort, KY 40601
Radiation Control Branch
Dept. of Health Services
Cabinet for Human Services
275 East Main Street
Frankfort, KY 40621
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LOUISIANA
Office of Solid and Hazardous Waste
Hazardous Waste Division
Dept. of Environmental Quality
P.O. Box 44307
625 North 4th Street
Baton Rouge, LA 70804
Nuclear Energy Division
Office of Air Quality & Nuclear Energy
P.O. Box 14690
Baton Rouge, LA 70898
MAINE
Dept. of Environmental Protection
Bureau of Oil and Hazardous Materials
Control
State House Station #17
Augusta, ME 04333
MARYLAND
Maryland Waste Management
Administration
Office of Environmental Programs
Dept. of Health and Mental Hygiene
201 W. Preston Street
Baltimore, MD 21201
Center for Radiological Health
Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
MASSACHUSETTS
Dept. of Environmental Quality
Engineering
Division of Solid and Hazardous Waste
One Winter Street
Boston, MA 02108
MICHIGAN
Environmental Protection Bureau
Hazardous Waste Division
Box 30028
Lansing, MI 48909
Dept. of Natural Resources
Waste Management Division
P.O. Box 30241
Lansing, MI 48909
MINNESOTA
Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Rd.
St. Paul, MN 55155
MISSISSIPPI
Dept. of Natural Resources
Bureau of Pollution Control
Division of Solid and Hazardous Waste
Management
P.O. Box 10385
Jackson, MS 39209
Division of Radiological Health
State Board of Health
3150 Lawson Street
P.O. Box 1700
Jackson, MS 39215-1700
MISSOURI
Department of Natural Resources
Waste Management Program
P.O. Box 176
205 Jefferson Street
Jefferson City, MO 65102
MONTANA
Dept. of Health and Environmental
Sciences
Solid and Hazardous Waste Bureau
Cogswell Building
Helena, MT 59620
NEBRASKA
Dept. of Environmental Control
Hazardous Waste Section
P.O. Box 98922
Lincoln, NE 68509
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Division of Radiological Health
State Department of Health
301 Centennial Mall South
P.O. Box 95007
Lincoln, ME 68509
NEVADA
Dept. of Conservation and Natural
Resources
Division of Environmental Protection
Waste Management Program
Capitol Complex, Nye Bldg.
201 South Fall Street
Carson City, NV 89710
Radiological Health Section
Health Division
Department of Human Resources
505 East King Street, Room 202
Carson City, NV 89710
NEW HAMPSHIRE
Department of Health and Welfare
Division of Public Health Services
Office of Waste Management
Health and Welfare Building
6 Hazen Drive
Concord, NH 03301
Radiological Health Program
Bureau of Environmental Health
Division of Health Services
Health & Welfare Building, Hazen Drive
Concord, NH 03301
NEW JERSEY
Dept. of Environmental Protection
Division of Hazardous Waste Mgmt.
401 E. State Street
Trenton, NJ 08625
NEW MEXICO
Health and Environment Department
Environmental Improvement Division
Groundwater and Special Waste Bureau
Harold Runnels Bldg.
1190 SL Francis Drive
Santa Fe.NM 87503
Community Service Bureau
Environmental Improvement Division
Harold Runnels Bldg.
1190 St. Francis Drive
Santa Fe.NM 87503
NEW YORK
Dept. of Environmental Conservation
Division of Solid and Hazardous Waste
50 Wolf Road
Albany, NY 12233
Bureau of Nuclear Operation
New York State Energy Office
Agency Building 2
2 Rockefeller Plaza
Albany, NY 12223
NORTH CAROLINA
Dept. of Environment, Health, and Natural
Resources
401 Oberlin Road
P.O. Box 27687
Raleigh, NC 27611
Radiological Protection Section
Division of Facility Service
701 Barbour Drive
Raleigh, NC 27603
NORTH DAKOTA
Department of Health
Division of Hazardous Waste
Management and Special Studies
1200 Missouri Avenue
Box 5520
Bismarck, ND 58502
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Division of Environmental Engineering
Radiological Health Program
State Department of Health
1200 Missouri Avenue
Bismarck, ND 58502
OHIO
Ohio EPA
Division of Solid and Hazardous Waste
Management
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43266
OKLAHOMA
Oklahoma State Dept. of Health
Waste Management Service
P.O. Box 53551
1000 ME 10th Street
Oklahoma City, OK 73152
OREGON
Dept. of Environmental Quality
Hazardous and Solid Waste Division
811SW Sixth Avenue
Portland, OR 97204
Radiation Control Section
Department of Human Resources
1400 SW Fifth Avenue
Portland, OR 97201
PENNSYLVANIA
Pennsylvania Department of
Environmental Resources
Bureau of Waste Management
9th Floor, Fulton Bldg.
P.O. Box 2063
Harrisburg, PA 17120
PUERTO RICO
Environmental Quality Board
P.O. Box 11488
Santurce, Puerto Rico 00910
RHODE ISLAND
Dept. of Environmental Management
Solid Waste Management Program
291 Promenade Street
Providence, RI 02908
Division of Occupational Health and
Radiation Control
Rhode Island Department of Health
Cannon Building, Davis Street
Providence, RI 02908
SOUTH CAROLINA
Dept. of Health and Environmental
Control
Bureau of Solid and Hazardous Waste
Management
J. Marion Sims Bldg.
2600 Bull Street
Columbia, SC 29201
Bureau of Radiological Health
S.C. Department of Health and
Environmental Control
J. Marion Sims Building
2600 Bull Street
Columbia, SC 29201
SOUTH DAKOTA
Dept. of Water and Natural Resources
Office of Air Quality and Solid Waste
Foss Building
523 East Capitol
Pierre, SD 57501
TENNESSEE
Tennessee Department of Public Health
Division of Solid Waste Management
701 Broadway
Customs House
Nashville, TN 37219
Division of Radiological Health
TERRA Building, 150 9th Avenue, N.
Nashville, TN 37219-5404
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TEXAS
Texas Department of Health
Bureau of Environmantal Health
1100 West 49th Street
Austin, TX 78756
Texas Water Commission
Hazardous and Solid Waste Division
1700 North Congress
P.O. Box 13087, Capitol Station
Austin, TX 78711
Bureau of Radiation Control
Texas Department of Health
1100 W. 49th Street (Mail Only)
Austin, TX 78756
UTAH
Division of Environmental Health
Bureau of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 16690
Salt Lake City, UT 84116
Bureau of Radiation Control
State Department of Health
288 North 1460 West
P.O. Box 16690
Salt Lake City, UT 84116-0690
VERMONT
Dept. of Environmental Conservation
Solid Waste Management Division
103 South Main Street, West Bldg.
Waterbury, VT 05676
VIRGIN ISLANDS
Division of Environmental Protection
Dept. of Planning and Natural Resources
Government of the Virgin Islands
Bldg. Ill, Apt. 114
Christiansted
St. Croix, VI00820
VIRGINIA
Virginia Department of Health
Division of Solid and Hazardous Waste
Management
James Monroe Building
101 North 14th Street
Richmond, VA 23219
WASHINGTON
Department of Ecology
Solid and Hazardous Waste Management
Division
Mail Stop PV-11
Olympia.WA 98504
Office of Radiation Protection
Dept. of Social and Health Services
Mail Stop LE-13
Olympia,WA 98504
WEST VIRGINIA
Division of Waste Management
Dept. of Natural Resources
1260 Greenbrier Street
Charleston, WV 25311
West Virginia DepL of Natural Resources
1800 Washington Street, East
Charleston, WV 25305
WISCONSIN
Department of Natural Resources
Bureau of Solid Waste Management
101 South Webster Street
Madison, WI 53703
WYOMING
Dept. of Environmental Quality
Solid Waste Management Program
122 West 25th Street
Herschler Building
Cheyenne, WY 82002
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