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
                                  10

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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
                                   11

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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.
                               13

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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
                                  14

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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
                                  15

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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
                                    16

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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.
                                  18

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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
                                   19

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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.
                                  20

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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.
                                  21

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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.
                                   22

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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
                               23

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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.
                                25

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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
                                    26

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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
                                   27

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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
                                    28

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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
                                    29

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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
                                    30

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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
                                    31

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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
                                    32

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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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