has been superseded by

                         -•^; v
                         •sL? <. I - -

This publication was prepared under the
guidance of Joan Warren and Devorah
Zeitlin, Office of Solid Waste, U.S.
Environmental Protection Agency,
Washington, D.C. The document was pre-
pared by Heidi Schultz, with assistance
from Brana Lobel, Jan Connery, and
David Meyers, Eastern Research Group,
Inc., Arlington, Massachusetts. The docu-
ment was illustrated by Elizabeth Stubbs
and designed by Howie Green. Photo-
graphs were provided by the U.S. Environ-
mental Protection Agency and the
American Petroleum Institute. This docu-
ment has been reviewed by the U.S.
Environmental Protection Agency and
approved for publication.


Characteristic Wastes	 5
Listed Wastes	 7
Expanding Definitions	7

The Tracking System	9
  Generators  	 9
  The Manifest	 9
  Transporters	10
The Permitting System	10
  Treatment, Storage, and Disposal Facilities (TSDFs)	1.0
Land Disposal: Unacceptable Risks, Acceptable Alternatives	14
  Waste Reduction, Recycling, and Treatment	18
  Banning Unsafe Wastes from Land Disposal	20
  Stringent Standards for Land Disposal Facilities	20
  Corrective Action Requirements for Hazardous Waste Releases	20

Small Quantity Generators	21
Underground Storage Tanks	23
Burning of Hazardous Waste and Used Oil Fuel Mixtures	24
Solid Waste Disposal Facilities	25

Monitoring  	26
Enforcement	26
Citizen Action and Participation	26
Coordinating Environmental Laws	26



RCRA: A  Historical Perspective
Following World War II, our nation's
phenomenal industrial growth was matched
by a surge in consumer demand for new
products. The country seized upon new
"miracle" products, such as plastics, nylon
stockings, and coated paper goods, as soon
as industry introduced them. Our appetite
for material goods also created a problem:
how to manage the increasing amounts of
waste produced by industry and consumers

In 1965 Congress passed the Solid Waste
Disposal Act, the first federal law to
                  Common household trash, while primarily
                  nonhazardous, can contain a variety of
                  hazardous wastes.

require safeguards and encourage environ-
mentally sound methods for disposal of
household, municipal, commercial, and
industrial refuse. Congress amended this
law in 1970 by passing the Resource
Recovery Act and again in 1976 by passing
the Resource Conservation and Recovery
Act (RCRA).  The primary goals of RCRA
• To protect human health and the environ-
  ment from the potential hazards of waste
• To conserve energy and natural
• To reduce the amount of waste gener-
  ated, including hazardous waste.
• To ensure that wastes are managed in an
  environmentally sound manner.

As our knowledge about the health and
environmental impacts of waste disposal
increased, Congress revised RCRA, first
in 1980 and again in 1984. The 1984
amendments-referred to as the Hazardous
and Solid Waste Amendments (HSWA)-
significantly expanded the scope of RCRA.
HSWA was created,  in large part, in
response to strongly voiced citizen con-
cerns that existing methods of hazardous
waste disposal, particularly land disposal,
were not safe.

RCRA, including its 1984 amendments, is
divided into sections called Subtitles. Sub-
titles C, D, and I set forth the framework
for EPA's comprehensive waste manage-
ment programs:
• EPA's Subtitle C program establishes a
  system for controlling hazardous waste
  from generation until ultimate disposal.
• EPA's Subtitle D program establishes a
  system for controlling solid (primarily
  nonhazardous) waste, such as household
• EPA's Subtitle I program, established by
  HSWA, regulates toxic substances and
  petroleum products stored in under-
  ground tanks.

Problems associated with past mis-
management of hazardous wastes are
covered by RCRA's companion law—the
Comprehensive Environmental Re-
sponse, Compensation, and Liability Act
(CERCLA or Superfund) of 1980-which
addresses the cleanup of inactive and aban-
doned hazardous waste sites.

The term "RCRA" is often used inter-
changeably to mean the law, the regula-
tions, and EPA policy and guidance. The
law describes the waste management pro-
gram mandated by Congress and gives
EPA the authority to develop it. The regu-
lations carry out the Congressional intent
by providing explicit requirements for
waste management that are legally enforce-
able. EPA guidance documents and policy
directives clarify issues related to imple-
mentation of the regulations. Together,
these three elements are all essential parts
of the RCRA program.

This booklet focuses on EPA's hazardous
waste regulatory program under Subtitle C
of RCRA and briefly discusses the Subtitle
D and I programs. The booklet is intended
to provide an overall perspective on how
RCRA works, including the roles of EPA,
the states, and the regulated community.
Further information and publications on
EPA's RCRA program can be obtained by
calling the EPA toll-free RCRA/Superfund
Hotline (1-800-424-9346 outside of
Washington, D.C., and 382-3000 in D.C.),
and from EPA Regional Offices (see inside
back cover).

What is a Hazardous


Hazardous wastes come in all shapes and
forms. They may be liquids, solids, or
sludges. They may be the by-products of
manufacturing processes, or simply com-
mercial products—such as household
cleaning fluids or battery acid—that have
been discarded. Whatever their form, how-
ever, proper management and disposal of
hazardous wastes are essential to protect
our country's valuable resources.

The RCRA law provides a general defini-
tion of the term "hazardous waste" (see
Inset). However, in order to regulate haz-
ardous wastes, EPA first had to determine
which specific wastes are hazardous.  Since
there  are tens of thousands of wastes that
can be hazardous for many different rea-
sons,  this was not a simple task. The  defi-
nition of hazardous waste had important
economic ramifications.  Only wastes
determined to be hazardous would be sub-
ject to RCRA's hazardous waste regu-

EPA spent many months interacting with
industry and the public to develop a defini-
tion of "hazardous waste" for its regula-
tions. As a result of this work, RCRA
regulations identify hazardous wastes
based on their characteristics and also pro-
vide a list of specific hazardous wastes.

Characteristic Wastes
A waste is hazardous if it exhibits one or
more  of the following characteristics:

 • Ignitability. Ignitable wastes can create
  fires under certain conditions. Examples
  include liquids, such as solvents that
  readily catch fire, and friction-sensitive
 • Corrosivity. Corrosive wastes include
According to EPA estimates, of the six bil-
lion tons of industrial, agricultural, com-
mercial, and domestic wastes we generate
annually, about 250 million tons are "haz-
ardous" as defined by RCRA regulations.
  those that are acidic and those that are
  capable of corroding metal (such as
  tanks, containers, drums, and barrels).

 • Reactivity. Reactive wastes are unstable
  under normal conditions. They can
  create explosions and/or toxic fumes,
  gases, and vapors when mixed with

 • Toxicity. Toxic wastes are harmful or
  fatal when ingested or absorbed. When
  toxic wastes are disposed of on land,
  contaminated liquid may drain (leach)
  from the waste and pollute ground water.
  Toxicity is identified through a labora-
  tory procedure called the Extraction
  Procedure (EP) toxicity test.

Hazardous Waste:

The Definition in the RCRA Law

To Be a Hazardous Waste, a Waste
Must Be a "Solid Waste"  . . .

. .  . defined in RCRA as "garbage, refuse, or sludge or any other waste
material." According to RCRA, a solid waste can be a solid, a semi-solid, a
liquid, or a contained gas.

.  . . And It Must Meet These Criteria. . .

"Because of its quantity, concentration, or physical, chemical, or infectious
characteristics, (it) may cause, or significantly contribute to, an increase in
mortality or an increase in serious irreversible, or incapacitating reversible,
illness; or pose a substantial present or potential hazard to human health and
the environment when improperly treated, stored, transported, or disposed
of, or otherwise managed."

Not  Included in RCRA Hazardous
Waste Regulations Are . .  .

• Domestic sewage.
• Irrigation waters or industrial discharges permitted under the Federal Water
 Pollution Control Act,

• Certain nuclear material as defined by the Atomic Energy Act,
* Household wastes, including toxic and hazardous waste,

* Certain mining wastes.
• Agricultural wastes, excluding some pesticides.
• Small quantity wastes (that is, wastes from businesses generating fewer
 than 220 pounds of hazardous waste per month).

      Ignitability      Corrosivity
            A waste is hazardous if it exhibits any of these four characteristics.
EPA regulations require that all waste
generators evaluate their wastes to deter-
mine if any of the four hazardous charac-
teristics are exhibited. Wastes exhibiting
these characteristics are subject to EPA's
Subtitle C hazardous waste regulations.

Listed Wastes

EPA has already determined that some
specific wastes are hazardous. These
wastes are now incorporated into lists pub-
lished by EPA. The lists are organized into
three categories:
• Source-Specific Wastes. This list
  includes wastes from specific industries
  such as petroleum refining and wood
  preserving. Sludges and wastewaters
  from treatment and production processes
  in these industries are examples of
  source-specific wastes.

• Generic Wastes. This list identifies
  wastes from common manufacturing and
  industrial processes. Generic wastes
  include solvents that have been used in
  degreasing operations in any industry.
• Commercial Chemical Products. This
  list includes specific commercial chemi-
  cal products such as creosote and some

All "listed" wastes are presumed to be haz-
ardous regardless of their concentrations
and must be handled according to EPA's
Subtitle C hazardous waste regulations.
However, if a company can demonstrate
that its specific waste is not hazardous,  the
waste may be "delisted" and is then no
longer  subject to Subtitle C requirements.
A delisted waste is still covered by Subtitle
D solid waste management requirements.

Expanding Definitions

Determining which wastes are hazardous is
a dynamic process, influenced by new con-
cerns, research data, and test development.
EPA is now adding certain types and
classes of wastes to its hazardous waste
lists, and is deciding whether to identify
additional hazardous characteristics.

Examples of Hazardous Waste
Generated by Businesses and Industries
Waste Generators

Chemical Manufacturers

Vehicle Maintenance Shops

Printing Industry
Leather Products Manufacturing

Paper Industry

Construction Industry
Cleaning Agents and Cosmetics
Furniture and Wood Manufacturing
  and Refinishing

Metal Manufacturing
Waste Type

Strong Acids and Bases
Spent Solvents
Reactive Wastes

Heavy Metal Faint Wastes
Ignitable Wastes
Used Lead Acid Batteries
Spent Solvents

Heavy Metal Solutions
Waste Inks
Spent Solvents
Spent Electroplating Wastes
Ink Sludges Containing Heavy Metals
Waste Toluene and Benzene

Paint Wastes Containing Heavy Metals
Ignitable Solvents
Strong Acids and Bases
Ignitable Faint Wastes
Spent Solvents
Strong Acids and Bases

Heavy Metal Dusts
Ignitable Wastes
Flammable Solvents
Strong Acids and Bases

Ignitable Wastes
Spent Solvents

Mnt Wastes Containing Heavy Metals
Strong Acids and Bases
Cyanide Wastes
Stodges Containing Heavy Metals

Controlling  Waste:

From  Generation to


The tragic consequences of hazardous
waste mismanagement in the past are
reflected in polluted ground water,
streams, lakes, and rivers, and in areas
now void of vegetation and wildlife.
Improper disposal of hazardous waste has
been linked to elevated levels of toxic con-
taminants in humans, aquatic species, and
livestock. Illegal dumping of hazardous
waste on roadsides or in open fields  has
resulted in explosions,  fires, contamination
of underlying ground water, and genera-
tion of toxic vapors.

To prevent such tragedies, EPA designed
the RCRA regulations to ensure proper
management of hazardous waste from the
moment the waste is generated until  its
ultimate disposal. This step-by-step
management approach enables EPA and
the states to monitor and control hazardous
waste at every point in the waste cycle,
thereby protecting human health and natu-
ral resources from the dangers of mis-
management. This approach has three key
• A tracking system requiring that a  uni-
  form manifest document accompany any
  transported hazardous waste  from the
  point of generation to the point of final
• An identification and permitting system
  that enables EPA and the states to assure
  the safe operation of all facilities
  involved in the treatment, storage,  and
  disposal of hazardous waste.
• A system of restrictions and controls on
  the placement of hazardous waste on or
  into the land.
The Tracking System


The first step in the waste cycle is the
generator, the person who actually
produces the waste or first causes the
waste to become subject to the RCRA
regulations. Generators include large
industries, small businesses, universities,
and hospitals.

Under RCRA regulations, generators must
determine if their waste is hazardous and
must oversee the ultimate fate of the waste.
Once a generator determines that a waste
is hazardous, he or she must obtain an
EPA identification number for each site at
which hazardous waste is generated.
According to EPA estimates, generators
treat or dispose of about 96 percent of the
nation's hazardous waste on site. Onsite
treatment, storage, and disposal facilities
generally are found at larger businesses
that can afford treatment equipment and
that possess the necessary space for stor-
age and disposal. Smaller firms, and those
in crowded urban locations, are more
likely to transport their waste offsite where
the waste is managed by a commercial firm
or a publicly owned and operated facility.
RCRA regulations apply  to both onsite and
offsite facilities.

If the generator chooses to dispose of the
hazardous waste offsite, the generator must
package and label the waste properly for
transportation. Proper packaging ensures
that no hazardous waste leaks from con-
tainers during transport. Labeling enables
transporters and public officials, including
those who respond to emergencies, to
rapidly identify the waste and its hazards.

The Manifest
Although only  a small percentage of
the nation's hazardous waste is actually
transported offsite to treatment, storage,

or disposal facilities, this still comprises a
substantial volume: approximately 12 mil-
lion tons per year. To track transported
waste, EPA requires generators to prepare
a Uniform Hazardous Waste Manifest.
This one-page form,  with carbon copies
for participants in the shipment, identifies
the type and quantity of waste, the genera-
tor, the transporter, and the facility to
which the waste is being shipped. Genera-
tors must also certify on the manifest that
they are minimizing the amount and toxic -
ity of their waste, and that the method of
treatment, storage, or disposal they have
chosen will minimize the risk to human
health and the environment. The certifica-
tion requirement was added by the 1984
RCRA amendments.  It reflects RCRA's
new emphasis on reducing the volume
of waste and providing  higher levels of

The manifest must accompany the
waste wherever it travels. Each individual
handler of the waste must sign the mani-
fest and keep one copy. When the waste
reaches its destination, the owner of that
facility returns a copy of the manifest to
the generator to confirm that the waste

If the waste does not arrive as scheduled,
generators must immediately notify EPA
or the authorized state environmental
agency (see Inset) so that they can inves-
tigate and take appropriate action. Genera-
tors must retain copies of the manifest for
three years after shipment. Every other
year, generators also must provide infor-
mation on their activities to their autho-
rized state agency or to EPA. Some
businesses that generate small quanti-
ties of hazardous waste are subject to
lesser paperwork requirements.

 Transporters pick up properly packaged
 and labeled hazardous waste from genera-
 tors and transport it to the designated facil-
 ities that treat, store, or dispose of the
 waste. Transporters must carry copies of
 the completed manifests and must put
 proper symbols on  the transport vehicle
 to identify the type of waste being trans-
 ported. These symbols, like the labels
 on the hazardous waste containers, enable
 firefighters, police, and other officials to
 immediately identify the potential hazards
 in case of an emergency. Like generators,
 transporters must obtain an EPA identifica-
 tion number. Because an accident involv-
 ing hazardous waste could create  very
 serious problems, EPA regulations also
 require transporters to comply with proce-
 dures for hazardous waste spill cleanup.

 The Permitting System
 Treatment, Storage, and Disposal Facilities
 The treatment, storage, and disposal facili-
 ties that receive hazardous waste from the
 transporter are subject to an EPA permit-
 ting system that ensures their safe opera-
 tion. Treatment facilities use various
 processes (see Inset) to alter the character
 or composition of a hazardous waste.
 Some treatment processes enable waste to
 be recovered and reused in  manufacturing
 settings,  while other treatment processes
 dramatically reduce the volume of waste to
 be disposed of. Storage facilities hold haz-
 ardous waste temporarily until it is treated
 or disposed of. Historically, most disposal
facilities buried hazardous waste or piled it
 on the land.

 Like generators  and transporters, TSDFs
 must obtain an EPA identification number.
 They must also obtain a permit to operate.
 The permit system ensures that facilities
 meet the standards established by  the
 RCRA program for proper waste manage-
                        Contmued on page 14

                                                Storage Facility
                                                           EPA or State
A one-page manifest must accompany every waste shipment.  The resulting paper trail
documents the waste's progress through treatment, storage, and disposal. A missing form
alerts the generator to investigate, which may mean calling in the state agency or EPA.

    The  Role of the States
    RCRA, like most federal environmental legislation, encourages states to develop and run
    their own hazardous waste programs as an alternative to direct EPA management. Thus, in
    a given state, the hazardous waste regulatory program described in this document may be
    run by the EPA or by a state agency. For a state to have jurisdiction over its hazardous waste
    program, it must receive approval from the EPA by showing that its program is at least
    as stringent as the EPA program. States that are authorized to operate RCRA programs
    oversee the hazardous waste tracking system in their state, operate the permitting system for
    hazardous waste facilities, and act as the enforcement arm in cases where an individual or a
    company practices illegal hazardous waste management. If needed, EPA steps in to assist the
    states in enforcing the law. EPA also acts directly to enforce RCRA in states that do not yet
    have authorized programs. EPA and the states currently act jointly to implement and enforce
    the regulations resulting from the 1984 RCRA amendments, however, most states soon will
    be assuming full responsibility for carrying out these newest sections of the EPA program.
                                                 i  States authorized to operate
                                             .rizatic  nazar(jous waste management programs
   State Authorization Status. As of October 31, 1986, EPA had authorized 40 states, plus Guam
   and the District of Columbia, to operate their own hazardous waste management programs.
   In states lacking such authority, EPA manages and enforces RCRA. Because EPA's hazardous
   waste regulations are developed in stages, EPA has developed a phased approach to approv-
   ing state programs. Within a defined time period (generally up to two years following the
   promulgation of a new set of regulations),  each state must either adopt the new regulations
   or upgrade those elements of its program that do not meet the federal standards.

Waste Treatment

Biological treatment uses micro-
organisms to degrade organic com-
pounds in a waste stream.

Carbon adsorption is a process in
which substances adhere to the sur-
face of specially treated carbon. This
method is particularly effective in
removing organic compounds from
waste liquids.

Dechlorination removes chlorine
from a substance by chemically
replacing it with hydrogen or hydrox-
ide ions. This process is used to
detoxify chlorinated substances.
Incineration destroys or makes waste
less hazardous through burning.
Incineration is frequently used to
destroy organic wastes.

Neutralization decreases the acidity
or alkalinity of a substance by adding
to it alkaline or acidic materials
Several processes exist for rendering
hazardous wastes less hazardous.
Neutralization, illustrated here, is
the process of combining acidic and
basic substances to produce a non-
hazardous (or reduced hazard)
                                        Oxidation detoxifies a waste constit-
                                        uent by combining it with oxygen.
                                        This process is used to treat wastes
                                        such as cyanides, phenols, and
                                        organic sulfur compounds.

                                        Precipitation removes solids from a
                                        liquid waste so that the hazardous
                                        solid portion can be disposed of

                                        Solidification and stabilization
                                        remove wastewater from a waste or
                                        change it chemically, thereby making
                                        it less permeable and less susceptible
                                        to transport by water.

ment. Many of these standards are
designed to protect ground water (See
Inset). For example, permitted TSDFs

• Analyze and identify wastes prior to
  treatment, storage, or disposal.
• Prevent the entry of unauthorized per-
  sonnel into the facility by installing
  fences and surveillance systems and by
  posting warning signs.

• Periodically inspect the facility to deter-
  mine if there are any problems.
• Adequately train employees.
• Prepare a contingency plan for emergen-
  cies and establish other emergency
  response procedures.
• Comply with the manifest system and
  with various reporting and recordkeep-
  ing requirements.
• Comply with technology requirements,
  such as installing double liners and
  leachate detection and collection

Permits also contain requirements specific
to the individual facility.

Approximately 4,000 hazardous waste
TSDFs are currently authorized to operate
under RCRA. Most of these facilities are
operating under "interim status," which
enables facilities that were in existence on
November 19, 1980 and that meet certain
technical requirements and standards for
waste management to continue to operate
until their permit applications are approved
or denied. Congress established interim
status in recognition of the fact that it
would take many years for EPA and the
states to issue permits. In order to continue
to operate, facilities must receive final per-
mits before October 1992.

Air emissions released during the treat-
ment, storage, and disposal of hazardous
waste can present risks to human health
and the environment. To control these
emissions, EPA has established standards
for hazardous waste incinerators and is
developing standards to limit the emissions
from all other hazardous waste treatment,
storage, and disposal facilities. EPA will
complete these new standards by late 1988.

As their capacity is used up and as new
stringent operating requirements are
imposed, many hazardous waste disposal
facilities may decide to close. What hap-
pens to the facility  after it closes is a long-
term concern, with substantial health and
environmental implications. For example,
at Love Canal, disturbance of the hazard-
ous waste landfill after the site had been
closed caused the subsequent leakage of
hazardous chemicals into the basements
of nearby homes.

RCRA regulations  are designed to prevent
such tragedies by requiring TSDF owners
to prepare carefully for the time when their
facility will close. Owners must:
• Acquire sufficient financial assurance
  mechanisms (such  as trust funds, surety
  bonds, or letters  of credit) to pay for
  completion of all operations.
• Be prepared to pay for 30 years of
  ground-water monitoring, waste system
  maintenance, and security measures
  after the facility closes.
• Obtain liability insurance to cover third-
  party damages that may arise from acci-
  dents or waste mismanagement.

Land Disposal:
Unacceptable Risks,
Acceptable Alternatives

The tracking and permitting system for
hazardous waste, from generation through
treatment, storage, and disposal, applies to
all hazardous waste,  regardless of the dis-
posal method employed.  Most hazardous
                        Continued on page 18

                       Ground Water
What is it?
Ground water is water that naturally
flows through and is stored in soil
and rock bodies beneath the land. It
is a major source of drinking water
and of water used for agriculture in
the United States. Almost half of this
country's  population depends upon
ground water for some or all of its
drinking water.

Ground-water contamination can
occur when liquids (usually rain-
water) move through waste disposal
sites and into the ground water, car-
rying pollutants with them. The
resulting mixture of liquid and pollu-
tant is called leachate; hazardous
waste may leach through even well-
designed  and well-constructed dis-
posal focilities and enter the soil or
rock below. This waste may reach
and contaminate ground water. Once
contaminated, ground water is
expensive and difficult—sometimes
impossible—to clean up,

RCRA regulations require ground-
water monitoring, which detects
early signs of contaminants leaching
from hazardous waste disposal fccili-
ties.  The most conunon monitoring
device is a well from which samples
of water are taken and analysed for
hazardous constituents. A series of
wells is installed at each disposal
site.  RCRA regulations also require
hazardous waste landfill and surface
impoundment facilities to install
double liners to protect against
ground-water contamination. Liners
are continuous layers of natural or
synthetic materials, such as clay or
plastic, which restrict the downward
or lateral escape of hazardous waste
when placed beneath or on the sides
of a landfill or surface impoundment.

  Waste Piles,
  Land Application
      Injection Wells
Of the hazardous waste disposed of on
land, nearly 60 percent is disposed of in
underground injection wells, approxi-
mately 35 percent is disposed of in surface
impoundments, 5 percent is disposed of
in landfills, and less than 1 percent is
disposed of in  waste piles or by land

                Types of Land Disposal
Landfills are disposal facilities
where hazardous waste is placed in
or on land. Properly designed and
operated landfills are lined to prevent
leakage and contain systems to col-
lect potentially contaminated surface
water run-off. Most landfills isolate
wastes in discrete cells or trenches,
thereby preventing potential contact
of incompatible wastes,

Surface impoundments are natural
or man-made depressions or diked
areas which can be used to treat,
store, or dispose of hazardous waste.
Surface impoundments may be any
shape and any size  (from a few hun-
dred square feet to hundreds of acres
in area). Surface impoundments are
often referred to as pits, ponds,
lagoons, and basins.
 Underground injection wells are
 steel- and concrete-encased shafts
 placed deep in the earth into which
 hazardous wastes are deposited by
 force and under pressure. Liquid
 hazardous wastes are commonly
 disposed of in underground injection
In a landfill, hazardous waste is
often covered with soil before a cover
system is installed EPA's RCRA
regulations require stringent landfill
design and construction features
such as double liners and leachate
collection systems.

Waste piles are noneontainerized
accumulations of solid, nonflowing
hazardous waste. While some are
used for final disposal, many waste
piles are used for temporary storage
until the waste is transferred to its
final disposal site.

Land treatment is a disposal process
in which hazardous waste is applied
onto or incorporated into the soil
surface. Natural microbes in the soil
break down or immobilize the haz-
ardous constituents. Land treatment
facilities are also called land applica-
tion or land farming facilities.

waste—about 80 percent—has been
disposed of into or on land at a variety of
disposal locations including landfills, sur-
face impoundments, waste piles, lagoons,
and underground injection wells (see
Inset). Improper land disposal practices
in the past have endangered public health
and the environment and continue to pose
a threat, particularly to ground water.

Faced with these concerns, Congress in
the 1984 RCRA amendments provided
substantial new protection by mandating
EPA to develop regulations to:

• Minimize wastes by reducing,  recycling,
  and treating them.

• Ban unsafe, untreated wastes from land

• Require that land disposal facilities are
  designed, constructed, and operated
  according to stringent standards.
• Require corrective action for releases of
  hazardous waste into the environment.

Waste Reduction, Recycling,  and

The 1984 RCRA amendments require haz-
ardous waste generators to certify that they
have taken steps to reduce the volume of
hazardous waste they generate. Generators
may reduce their waste volume in several
ways: manufacturing process changes,
source separation, recycling, raw material
substitution, and product substitution (see
Inset). In many cases, waste reduction can
benefit industry by decreasing the costs of
waste management. When companies pro-
duce less waste, their disposal costs are
lower. Further,  companies may sell reco-
vered materials at a profit.

In addition to reducing the volume of waste
generated,  companies may treat  waste
prior to disposal to reduce the waste
volume or eliminate the waste's hazardous
constituents. Several different types of
treatment are available, involving physical,
chemical, and/or biological processes (see
Inset, page 19). One or more processes
may be used, depending on the charac-
teristics of the waste. Nearly all treatment
processes produce residues that ultimately
must be disposed of.

The land ban provisions of the 1984 RCRA
amendments have given considerable
impetus to the development of more eco-
nomic  and more effective means of treating
waste.  As a result, treatment technologies
are being improved rapidly. EPA is now
sponsoring research on new treatment
technologies to destroy, detoxify, or
incinerate hazardous waste; on ways to
recover and reuse hazardous waste; and on
methods to reduce the volume of hazard-
ous waste requiring treatment or disposal
(see Inset).
Banning Unsafe Wastes from Land

The 1984 RCRA amendments require EPA
to examine all hazardous wastes to deter-
mine if any should be banned from land
disposal. The amendments prohibit the

    Approaches to Waste Reduction
    • Source separation (or segregation) keeps hazardous waste from contaminating
      nonhazardous waste through management practices that prevent the wastes from
      coming into contact. This is the cheapest and easiest method of reducing the
      volume of hazardous waste to be disposed of, and is widely used by industry. In
      addition to reducing disposal costs, source separation reduces handling and
      transportation costs.

    • Recycling (also referred to as recovery and reuse) is also widely used by industry.
      Recycling is the process of removing a substance from a waste and returning it to
      productive use. Generators commonly recycle solvents, acids, and metals.

    • Substitution of raw materials may offer the greatest opportunity for waste
      reduction. By replacing a raw material that generates a large amount of
      hazardous waste with one that generates little or no hazardous waste,
      manufacturers can substantially reduce the waste volume.

    » Manufacturing process changes consist of either eliminating a process that
      produces a hazardous waste or altering the process so that it no longer produces
      the waste.

    • Substitution of products also may eliminate use of a hazardous material. Bor
      example, by substituting concrete posts for creosote-preserved wood posts in
      construction operations, builders can remove any possibility that the hazardous
      creosote will leach from the posts and contaminate underlying ground water or
      surrounding soil.
land disposal of untreated hazardous waste
unless EPA finds that there will be "no
migration of hazardous constituents .  . .
for as long as the wastes remain hazard-
ous." Waste that is determined not to pose
a health or environmental threat may con-
tinue to be disposed of on land.

Establishing Standards for Treatment. If a
waste is banned from land disposal, it must
be treated and rendered less hazardous
before it can be disposed of on the land.
EPA is currently establishing treatment
standards for banned wastes. These stan-
dards must specify a level or method of
treatment which substantially reduces the
toxicity or mobility of the hazardous con-
stituents so as to minimize long-term
threats to human health and the environ-
ment. EPA is examining treatment technol-
ogies that meet this requirement and is
basing treatment standards on the "best
demonstrated available technology."

Meeting a Tight Schedule. The 1984
RCRA amendments set strict deadlines for
determining whether wastes  should be
banned from land disposal and for
developing treatment standards. EPA must
complete its determination for dioxins and
certain solvents — wastes of particular con-
cern to the Agency and the public—by
November 1986. By July 1987,  EPA must
make decisions about the so-called
"California list" wastes, which include

liquid hazardous wastes containing certain
metals, cyanides, PCBs, halogenated
organic compounds, or acidic wastes. By
August 1988, EPA must assess one-third of
all other hazardous wastes; by June 1989,
EPA must assess another one-third of all
other hazardous wastes; and by May 1990,
EPA must complete its assessment of all
hazardous wastes.

If EPA fails to meet the deadline for any
waste, that waste will automatically be
banned from land disposal. Some hazard-
ous wastes may continue to be disposed of
on land for up to two years past the assess-
ment deadline if EPA determines that
sufficient or adequate treatment technol-
ogy is not available to make the waste safe
for land disposal. This is essentially a
grace period that provides limited extra
time for industry to develop acceptable
treatment technologies or capacity. How-
ever, if sufficient treatment is still unavail-
able after two years, those wastes  will be
banned from land disposal unless, on a
case-by-case basis, the Agency has granted
a variance during the construction of new
treatment  capacity. EPA may grant up to
two one-year extensions of the  ban's effec-
tive date if contractual commitments for
construction of treatment capacity exist
and there is  no  suitable alternative

Stringent Standards for Land Disposal
RCRA standards for the operation of land
disposal facilities have become increas-
ingly stringent in response to the growing
concern about adverse environmental
impacts. While RCRA regulations strongly
discourage land disposal of most hazard-
ous wastes,  it is very likely that there
always will be some wastes that must be
disposed of on  land.  The 1984 RCRA
amendments provide several new restric-
tions and  standards for land disposal facili-
ties to ensure more thorough protection of
the environment, particularly ground
water. These include:

• Banning liquids from landfills.
• Banning underground injection of haz-
  ardous waste within 14-mile of a drink-
  ing water well.

• Requiring more stringent structural and
  design conditions for landfills and sur-
  face impoundments, including two or
  more liners, leachate collection systems
  above and between the liners, and
  ground-water monitoring.

• Requiring cleanup or corrective action if
  hazardous waste leaks from a facility.

• Requiring information from disposal
  facilities on pathways of potential human
  exposure to hazardous substances.

• Requiring location standards that are
  protective of human health and the
  environment, for example, allowing dis-
  posal facilities to be constructed only in
  suitable hydrogeologic settings.

Corrective Action Requirements for Haz-
ardous Waste Releases
The  1984 RCRA amendments require that
all Subtitle C facilities take corrective
action for any release of hazardous  waste
or constituents into the environment.  To
enforce this requirement, the  amendments
provide a new type of administrative order
that enables EPA or an authorized state to
require corrective action (such as repairing
liners or pumping to remove a plume of
contamination at a facility)  when there has
been a release. EPA or the state may
require corrective action beyond the facil-
ity boundary. They also may require cor-
rective action regardless of when waste
was placed at the facility. Thus, this mech-
anism may be used to clean up past prob-
lems. The 1984 RCRA amendments also
require that Subtitle C facilities provide
financial assurance that they can complete
the corrective action.

Expansion  of the

RCRA Program

Small Quantity Generators
When EPA first issued hazardous waste
regulations under RCRA, the Agency
focused on those companies that generated
the largest amounts of waste—more than
2,200 pounds (or about five full 55-gallon
drums) per month. This regulated commu-
nity included about 15,000 companies that
produced approximately 90 percent of the
nation's hazardous waste. "Small quantity
generators"—businesses that generate less
than 2,200 pounds (1,000 kilograms) of
hazardous waste in a calendar month—
were exempted from most of the federal
hazardous waste requirements. Some
states had more stringent regulations that
did cover small quantity generators.

In the 1984 RCRA amendments, Congress
closed this gap by requiring EPA to regu-
late those small quantity generators who
produce between 220 and 2,200 pounds
(100 to  1,000 kilograms) of hazardous
waste in a calendar month. There are
about 100,000 of these 220 to 2,200
pounds per month  generators, including
businesses such as vehicle repair shops,
metal manufacturing and finishing opera-
      I	n
      -  =:..

         . Bii

    Percentage of Hazardous Waste
    Generated by Volume
                                                   According to EPA, approx-
                                                   imately 90 percent of the
                                                   nation's hazardous waste
                                                   is produced by large quan-
                                                   tity generators . . .
   . . .  However, these generators constitute
   only about 2 percent of the companies
   covered by RCRA. The remaining 98 per-
   cent are small quantity generators.
Relative Proportion of Small
Quantity Generators Versus
Large Quantity Generators

tions, laboratories, printers, laundries,
and dry cleaners. "Conditionally-exempt"
generators—businesses that generate less
than 220 pounds per month — will remain
exempt from most of the hazardous waste

Effective September 22,  1986, 220 to
2,200 pounds per month generators must
meet most of the key requirements of
the RCRA program for hazardous waste
management. For example, they must:
• Obtain an EPA identification number.

• Use the fully completed manifest when
  shipping waste offsite.
• Use only hazardous waste transporters
  and authorized facilities with EPA iden-
  tification numbers to transport, treat,
  store, or dispose of their hazardous
• Not store hazardous  waste on site for
  longer than 180 days (270 if the waste is
  to  be shipped more than 200 miles) with-
  out a permit.

To assist small businesses in under-
standing and complying with RCRA,
EPA has developed guidance publications
on the new requirements, including
industry-specific assistance on completing
the manifest form.

Underground Storage Tanks
In the South Bay area of San Francisco,
California, leaks and spills of toxic sol-
vents from underground  tanks and their
associated piping systems have  severely
contaminated the ground water. On the
other side of the country, in the small com-
munity of Truro on Cape Cod,  Massachu-
setts, residents discovered their drinking
water wells were contaminated with gaso-
line that had leaked from a nearby under-
ground storage tank. The courts ordered
the company responsible to provide resi-
dents with bottled water and to spend mil-
lions of dollars to restore the water supply.
Thousands of other communities across
the country are facing similar problems.
These problems have focused national
attention on the issue of leaking under-
ground storage tanks.

Both accidental releases and the slow seep-
age of toxic chemicals or petroleum
products from buried storage tanks can
contaminate ground water. Most of the
single-wall steel tanks in the ground even-
tually corrode and leak. Nearly one-
quarter of the estimated 1.5 million under-
ground storage tanks (excluding farm and
heating oil tanks) in the United States that
contain hazardous substances or petroleum
products are either leaking now or are
expected to leak in the next five years.
These facts led Congress, in the 1984
RCRA amendments, to require EPA to
regulate underground tanks containing haz-
ardous substances and petroleum products.

Assessing  the Problem —USTNotification.
Prior to the 1984 amendments, only a few
states had  programs to monitor under-
ground storage tanks (USTs). Therefore,
one of the first steps in the new EPA pro-
gram is to require tank owners to notify
and register their tanks with state or local

agencies. The notification form asks
owners to specify the tank's age, size, type,
location, and uses.  To assist in this effort,
the EPA's UST program requires anyone
who deposits petroleum or regulated haz-
ardous substances in an underground stor-
age tank—for example, the driver of the
gasoline tank truck who refills the storage
tanks at local gasoline service stations-to
inform the tank owner of his or her respon-
sibilities to fill out a notification form.

Preventive Measures and Future Regula-
tions. To prevent leakage due to corrosion,
RCRA regulations require that new tanks
feature certain construction precautions.
EPA's RCRA regulations require that new
underground storage tanks meet highly
protective construction and installation

For example, underground tanks cannot be
installed unless the material used to con-
struct the tank or its lining is compatible
with the substance to be stored. Tank
owners also must show that they are finan-
cially able to take corrective action if a
leak occurs and to compensate anyone who
is injured or whose property is damaged
by a leak. EPA is currently developing
regulations for leak detection, leak preven-
tion, recordkeeping, tank closure, report-
ing, and corrective action in case a leak
occurs. In addition, EPA is developing new
tank performance standards and regula-
tions for approving state programs.

Informing the Public. EPA is developing an
extensive public outreach program to com-
municate with all sectors affected by the
UST regulations. EPA is also working
closely with the states to develop the UST
program and to gather information from
the industrial community on the potential
dangers and remediation techniques for
leaking tanks.

Burning of Hazardous Waste
and Used Oil Fuel Mixtures

In the past, facilities often mixed hazard-
ous waste or used oil with fuels to increase
the heating value of the fuels and to reduce
the costs of waste disposal. When burned,
fuels containing used oil contaminated
with toxic constituents or hazardous waste
may emit toxic fumes and can cause fires
and explosions. In one incident, residents

of a building in New York City complained
of respiratory problems, headaches,
nausea, and digestive problems. An inves-
tigation revealed that a fuel blending facil-
ity had mixed hazardous wastes containing
PCBs and chlorinated solvents with the
building's heating fuel supply. Incidents
such as this prompted Congress to require
EPA to regulate the burning of hazardous
waste and used oils.

Prior to 1986,  utilities, industries, com-
mercial facilities, schools, government
institutions, and apartment and home
owners across the country burned about
1 to 2 million tons of hazardous wastes and
about 500 to 600 million gallons of used
oils per year for energy recovery purposes.
Used oils include automotive crankcase oil
and oils used in industrial processes. Used
oils are often contaminated with toxic
metals (such as arsenic, cadmium,  chro-
mium, and lead) and chlorinated organic
compounds (such as cleaning solvents).

EPA's RCRA regulations  now prohibit non-
industrial facilities, such  as homes  and
apartment buildings, from burning hazard-
ous waste fuel or used oil that contains
significant levels of hazardous con-
taminants. In addition, EPA requires all
producers, distributors, and marketers of
contaminated used oil fuel to place a label
on the bill of sale indicating that the fuel is
subject to EPA regulation. Marketers and
burners of contaminated used oil fuel also
must notify EPA of their activities, obtain
EPA identification numbers, and keep cer-
tain records. Facilities that burn or blend
hazardous waste fuel also must comply
with these notification and recordkeeping
requirements,  comply with hazardous
waste storage and facility standards, and
fill out a manifest form if they ship the
waste fuel. In the future,  EPA plans to
regulate the burning of hazardous waste
and used oil in boilers and industrial
Solid Waste Disposal Facilities

Solid wastes covered under Subtitle D of
RCRA are primarily nonhazardous. The
227,000 solid waste disposal facilities regu-
lated under Subtitle D fall into four general
categories: landfills, surface impound-
ments, land application facilities, and
waste piles. Currently, EPA has min-
imum requirements —also referred  to as
criteria-for Subtitle D facilities. These
criteria are designed to:
• Protect endangered species, food crops,
  ground water, surface water, air,  and
• Prevent disease transmission.

• Ensure the safety of employees and
  nearby residents.

Facilities must comply with the criteria or
EPA classifies them as "open dumps,"
which must close or upgrade their

EPA currently is considering whether
the existing criteria for Subtitle D facilities
are adequate to protect ground water from
contamination.  EPA also  is exploring vari-
ous mechanisms for further regulating
solid waste disposal facilities. One
approach being considered is a flexible
permitting process that would enable each
permit to include site-specific environmen-
tal considerations. EPA is also exploring
ways to extend the useful  life of municipal
landfills and to  better utilize sites that are
already filled or closed. Approaches being
considered include reducing waste  volume
and landfilling waste more efficiently.  Both
approaches would allow a larger volume of
waste to be disposed of per unit volume of

About 36,000 of the 227,000 Subtitle D
solid waste disposal facilities accept house-
hold hazardous waste and waste from small
quantity hazardous waste generators. The

1984 RCRA amendments mandated EPA to
develop new criteria to better protect the
public from potential hazards associated
with these facilities. At a minimum, the
criteria EPA now is developing will require
ground-water monitoring, location restric-
tions, and corrective action as appropriate.
Municipal landfills often contain small
amounts of hazardous waste from house-
holds and small businesses. These wastes
can create serious environmental

Making RCRA Work


For EPA's RCRA program to substantially
reduce the adverse effects caused by haz-
ardous waste, all regulated groups must
comply. To ensure compliance, program
personnel inspect and monitor facilities
and take enforcement measures when

One of the program's most important
monitoring tools  is the site inspection,
which is required of all treatment, storage,
and disposal facilities at least once every
two years. During an inspection, regula-
tory personnel review the company's
records, take waste samples, and assess the
facility's operating methods. In particular,
inspectors check for compliance with
ground-water monitoring requirements,
proper handling and labeling of wastes,
and assurance of financial responsibility. If
a facility is not complying with the RCRA
regulations, EPA or the state takes enforce-
ment action.

Enforcement may include civil and crimi-
nal penalties, orders to correct the viola-
tions, fines, and/or imprisonment. For
minor violations, EPA or the state agency
often lets the facility know, through a letter
or phone call, that it is not in compliance
and that legal actions will be taken if the
owner does not comply within a certain
time period. For  severe or recurrent viola-
tions, EPA or the state can levy a penalty
of up to $25,000 per day for each day the
facility fails to comply past the specified
deadline. EPA or the state can also suspend
the facility's permit to operate or bring a
criminal suit against a facility. Examples of
potential criminal violations of RCRA in-
clude falsifying information on a manifest,
report, or permit, or transporting a waste
either without a manifest or to a facility
without a permit. Fines of $250,000 per
person or $1 million per corporation can
be assessed in these cases.

Citizen Action  and Participation
Citizen participation is vital to solving the
hazardous waste problem. RCRA and its
1984 amendments provide ongoing oppor-
tunities for public participation in all facets
of implementation,  enable citizens to take
legal action against any individual or
group involved in the mismanagement of
hazardous waste, and require that citizens
be notified about hazardous waste issues.
RCRA includes provisions that:

• Citizens have access to information
  obtained by EPA or the states during a
  facility inspection.

• Citizens are allowed to participate in the
  permitting process from the beginning.
• Citizens may bring suits against anyone
  whose hazardous waste management
  activities may constitute an imminent
  hazard or substantial endangerment.

• Citizens may bring suits against anyone
  who may be violating a RCRA permit,
  standard, or requirement.
• EPA or the state must notify local offi-
  cials and post a sign at sites that pose an
  imminent and substantial threat to
  human health and the environment.

Coordinating Environmental

RCRA is one of a series of laws regulating
hazardous substances in the environment
(see Inset). These laws were developed at
various points in time and reflect concerns
about particular issues such as ground-
water protection, water quality, air quality,
or worker safety.  Some laws address the
same hazardous substances at different
points in their existence. For example,

RCRA may regulate the disposal of a par-
ticular hazardous waste, while the Occupa-
tional Safety and Health Act protects
workers who are exposed to that same sub-
stance in the workplace. Because the con-
cerns addressed by these laws sometimes
overlap, EPA works with the states and
other federal agencies to help ensure that
all aspects of environmental protection are
well coordinated. EPA, in conjunction
with other federal and state agencies, also
attempts to identify and address areas not
covered by existing laws.
Public participation is key to successful
implementation ofEPAs RCRA program.
Through public hearings and meetings,
citizens have an opportunity to voice con-
cerns and take an active role in shaping
the future of the nation's hazardous waste
management policies and directions.

 Looking Ahead

 The management of hazardous waste is a
 continually evolving process, reflected in
 research and technology development, new
 regulations, and amendments to the law.
 Since RCRA was enacted in 1976, we have
 seen substantial progress in solving per-
 haps the most difficult environmental
 problem facing the nation. The climate for
 productive future action is promising.
 Public interest in the problems associated
 with hazardous waste has steadily
 increased over the past several years and is
 likely to remain high. Scientific knowledge
 and technical capabilities will continue to
 grow with time. As our experience and
 expertise increase, many issues will
 require further attention, including:
• Increasing the Nation's Capacity for
  Treating Waste. Efforts must be made to
  increase the treatment capacity of exist-
  ing facilities and to encourage the con-
  struction of new facilities.
• Encouraging New and Improved Waste
  Control Technologies. More comprehen-
  sive, efficient, and inexpensive technolo-
  gies are required to render hazardous
  waste nonhazardous and to reduce its

 RCRA is a response to a complex environ-
 mental problem-one that is intimately
 connected to the way our country operates,
 its heavy reliance  on  industrial production,
 and our technologically sophisticated
 lifestyles. As long as  we demand the
 products that generate these wastes, we
 will need well-designed and well-operated
 facilities and sound alternatives for waste
 management. Technological change, popu-
 lation expansion, and economic growth
 will present new environmental challenges.
 The cooperation and  participation of
 industry, government, and the public will
ensure that these challenges are met.

  Environmental Laws Controlling

  Hazardous Substances

  • Clean Air Act (EPA)—regulates the emission of hazardous air pollutants,

  • Clean Water Act (EPA)-regulates the discharge of hazardous pollutants into the
    nation's surface waters.

  • Marine Protection, Research, and Sanctuaries Act (EPA)—regulates waste
    disposal at sea.

  » Occupational Safety and Health Act (U.S. Occupational Safety and Health
    Administration)-regulates hazards in the workplace, including worker exposure
    to hazardous substances.

  • Resource Conservation and Recovery Act (EPA)—regulates hazardous waste
    generation, storage, transportation, treatment, and disposal.
  • Safe Drinking Water Act (EPA)—regulates contaminant levels in drinking water.
  • Toxic Substances Control Act (EPA)—regulates the manufacture, use, and
    disposal of chemical substances.

  » Hazardous Materials Transportation Act (U.S. Department of Transportation)—
    regulates the transportation of hazardous materials.

  • Comprehensive Environmental Response, Compensation, and Liability Act
    (Superfund) (EPA)-provides for the cleanup of inactive and abandoned
    hazardous waste sites.

  • Atomic Energy Act (Nuclear Regulatory Commission)-regulates nuclear energy
    production and nuclear waste disposal.

  * Surface Mining Control and Reclamation Act (U.S. Department of the Interior) -
    regulates the environmental aspects of mining (particularly coal) and

State Hazardous

Waste  Agencies

Alabama Department of Environmental
Land Division
1751 Federal Drive
Montgomery, AL 36130

Department of Environmental Conservation
Air and Solid Waste Management
Pouch O
Juneau, AK 99811

Environmental Quality Commission
Government of American Samoa
Pago Pago, American Samoa 96799

Arizona Department of Health Services
Office of Waste and Water Quality Management
2005 North Central Avenue
Phoenix, AZ 85004

Department of Pollution Control and Ecology
Solid and Hazardous Waste Division
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219

Department of Health Services
Toxic Substances Control Programs
714 P Street
Sacramento, CA 95814

State Water Resources Control Board
P.O. Box 100
Sacramento, CA 95801

California Waste Management Board
1020 Ninth Street, Suite 300
Sacramento, CA 95814

Colorado Department of Health
Waste Management Division
4210 E. llth Avenue
Denver, CO 80220
Division of Environmental Quality
Commonwealth of the Northern Mariana
Office of the Governor
Saipan, Mariana Islands 96950

Department of Environmental Protection
Hazardous Material Management Unit
State Office Building
165 Capitol Avenue
Hartford, CT 06106

Connecticut Resource Recovery Authority
179 Allyn Street, Suite 603
Professional Building
Hartford, CT 06103

Department of Natural Resources and
  Environmental Control
Solid Waste Management Branch
P.O. Box 1401
Dover, DE 19903

Department of Consumer and Regulatory
Pesticides and Hazardous Waste Materials
5010 Overlook Avenue, S.W.
Washington, DC 20032

Department of Environmental Regulation
Solid and Hazardous Waste Section
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32301

Land Protection Branch
Industrial and Hazardous Waste Management
Floyd Towers East
205 Butler Street, S.E.
Atlanta, GA 30334

Guam Environmental Protection Agency
P.O. Box 2999
Agana, Guam 96910

Department of Health
Environmental Health Division
P.O. Box 3378
Honolulu, HI 96801

Department of Health and Welfare
Bureau of Hazardous Materials
450 West State Street
Boise, ID 83720

Environmental Protection Agency
Division of Land Pollution Control
2200 Churchill Road
Springfield, IL 62706

State Board of Health
Division of Land Pollution Control
1330 West Michigan Street
Indianapolis, IN 46206

U.S. EPA Region VII
Hazardous Materials Branch
726 Minnesota Avenue
Kansas City, KS 66101

Department of Health and Environment
Bureau of Waste Management
Forbes Field, Building 321
Topeka, KS 66620

Cabinet for Natural Resources and
  Environmental Protection
Department of Environmental Protection
Division of Waste Management
Ft. Boone Plaza, Building #2
18 Reilly Road
Frankfort, KY 40601

Office of Solid and Hazardous Waste
Hazardous Waste Division
Department of Environmental Quality
P.O. Box 44307
Baton Rouge, LA 70804
Department of Environmental Protection
Bureau of Oil and Hazardous Materials Control
State House Station #17
Augusta, ME 04333

Maryland Waste Management Administration
Office of Environmental Programs
Department of Health and Mental Hygiene
201 W. Preston Street
Baltimore, MD 21201

Department of Environmental Quality
Division of Solid and Hazardous Waste
One Winter Street
Boston, MA 02108

Environmental Protection Bureau
Hazardous Waste Division
Box 30028
Lansing, MI 48909

Pollution Control Agency
Solid and Hazardous Waste Division
1935 West County Road B-2
Roseville, MN 55113

Department of Natural Resources
Bureau of Pollution Control
Division of Solid and Hazardous Waste
P.O. Box 10385
Jackson, MS 39209

Department of Natural Resources
Waste Management Program
117 East Dunklin Street
P.O. Box 1368
Jefferson City, MO 65102

Department of Health and Environmental
Solid and Hazardous Waste Bureau
Cogswell Building
Helena, MT 59620

Department of Environmental Control
Hazardous Waste Management Section
State House Station
P.O. Box 94877
Lincoln, NE 68509

Department of Conservation and Natural
Division of Environmental Protection
Waste Management Program
Capitol Complex
201 South Fall Street
Carson City, NV 89710

Department of Health and Welfare
Division of Public Health Services
Office of Waste Management
Health and Welfare Building
Hazen Drive
Concord, NH 03301

Department of Environmental Protection
Division of Waste Management
32 E. Hanover Street, CN-027
Trenton, NJ 08625

Health and Environment Department
Environmental Improvement Division
Groundwater and Hazardous Waste Bureau
P.O. Box 968
Santa Fe, NM 87504-0968

Department of Environmental Conservation
Division of Solid and Hazardous Waste
50 Wolf Road
Albany, NY 12233

Department of Human Resources
Division of Health Services
Solid and Hazardous Waste Management
P.O. Box 2091
Raleigh, NC 27602
Department of Health
Division of Hazardous Waste Management and
  Special Studies
1200 Missouri Avenue
Box 5520
Bismarck, ND 58502-5520

Ohio EPA
Division of Solid and Hazardous Waste
361 East Broad Street
Columbus, OH 43215

Oklahoma State Department of Health
Waste Management Service
P.O. Box 53551
1000 N.E.  10th Street
Oklahoma City, OK 73152

Department of Environmental Quality
Hazardous and Solid Waste Division
P.O. Box 1760
Portland, OR 97207

Pennsylvania Department of Environmental
Bureau of Solid Waste Management
P.O. Box 2063
Harrisburg, PA 17120

Environmental Quality Board
P.O. Box 11488
Santurce, Puerto Rico 00910-1488

Department of Environmental Management
Solid Waste Management Program
204 Cannon Building
75 Davis Street
Providence, RI 02908

Department of Health and Environmental
Bureau of Solid and Hazardous Waste
2600 Bull Street
Columbia, SC 29201

Department of Water and Natural Resources
Office of Air Quality and Solid Waste
Foss Building
Pierre,  SD 57501

Tennessee Department of Public Health
Division of Solid Waste Management
701 Broadway
Customs House
Nashville, TN 37219-5403

Texas Department of Health
Bureau of Solid Waste Management
1100 West 49th Street, T-601A
Austin, TX 78756-3199

Texas Water Commission
Hazardous and Solid Waste Division
1700 North Congress
P.O. Box 13087, Capitol Station
Austin, TX 78711

Department of Health
Bureau of Solid and Hazardous Waste
P.O. Box 45500
State Office Building
Salt Lake City, UT 84140

Agency of Environmental Conservation
Waste Management Division
State Office Building
Montpelier, VT 05602

Department of Conservation and Cultural
P.O. Box 4399, Charlotte Amalie
St. Thomas, Virgin Islands 00801
Virginia Department of Health
Division of Solid and Hazardous Waste
Monroe Building
101 North 14th Street
Richmond, VA 23219

Department of Ecology
Solid and Hazardous Waste Management
Mail Stop PV-11
Olympia, WA 98504

Division of Water Resources
Solid and Hazardous Waste/Ground Water
1201 Greenbrier Street
Charleston, WV 25311

West Virginia Department of Natural Resources
1800 Washington Street, East
Charleston, WV 25305

Department of Natural Resources
Bureau of Solid Waste Management
P.O. Box 7921
Madison, WI 53707

Department of Environmental Quality
Solid Waste Management Program
122 West 25th Street
Herschler Building
Cheyenne, WY 82002