EPA-530-SW-86-037 has been superseded by EPA-530-K-97-004 -•^; v •sL?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. ------- Contents Page RCRA: A HISTORICAL PERSPECTIVE 3 WHAT IS A HAZARDOUS WASTE? 5 Characteristic Wastes 5 Listed Wastes 7 Expanding Definitions 7 CONTROLLING WASTE: FROM GENERATION TO DISPOSAL . . 9 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 EXPANSION OF THE RCRA PROGRAM 21 Small Quantity Generators 21 Underground Storage Tanks 23 Burning of Hazardous Waste and Used Oil Fuel Mixtures 24 Solid Waste Disposal Facilities 25 MAKING RCRA WORK 26 Monitoring 26 Enforcement 26 Citizen Action and Participation 26 Coordinating Environmental Laws 26 LOOKING AHEAD 29 EPA AND STATE AGENCY INFORMATION SOURCES 31 ------- 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 alike. 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 are: • To protect human health and the environ- ment from the potential hazards of waste disposal. • To conserve energy and natural resources. • 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 waste. • 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 Waste? 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- lations. 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 substances. • 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 water. • 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 Reactivity Toxicity 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 pesticides. 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 Manufacturing 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 Disposal 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 elements: • 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 disposal. • 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 Generators 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 protection. 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 arrived. 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. 10 Transporters 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 (TSDFs) 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 Transporter Treatment Facility EPA or State Agency 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. 11 ------- 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. 12 ------- Selected Hazardous Waste Treatment Technologies 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 respectively. 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) substance. 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 safely. Solidification and stabilization remove wastewater from a waste or change it chemically, thereby making it less permeable and less susceptible to transport by water. Incineration 13 ------- ment. Many of these standards are designed to protect ground water (See Inset). For example, permitted TSDFs must: • 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 systems. 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 14 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. Contamination 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, Protection 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. 15 ------- Landfills Waste Piles, Land Application Surface Impoundments Underground 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 application. 16 ------- 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 wells. 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. 17 ------- 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 disposal. • 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 Treatment 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 Disposal 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 18 ------- 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 19 ------- 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 capacity. Stringent Standards for Land Disposal Facilities 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. 20 ------- 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 - =:.. --P . 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 22 ------- 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 requirements. 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 wastes. • 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 23 ------- 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 standards. 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 24 ------- 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 furnaces. 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 floodplains. • 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 operations. 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 landfill. 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 25 ------- V 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 problems. 26 ------- Making RCRA Work Monitoring 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 necessary. 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 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 Laws 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, 27 ------- 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. 28 ------- 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 volume. 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. 29 ------- 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 reclamation. 30 ------- State Hazardous Waste Agencies ALABAMA Alabama Department of Environmental Management Land Division 1751 Federal Drive Montgomery, AL 36130 ALASKA Department of Environmental Conservation Air and Solid Waste Management Pouch O Juneau, AK 99811 AMERICAN SAMOA Environmental Quality Commission Government of American Samoa Pago Pago, American Samoa 96799 ARIZONA Arizona Department of Health Services Office of Waste and Water Quality Management 2005 North Central Avenue Phoenix, AZ 85004 ARKANSAS Department of Pollution Control and Ecology Solid and Hazardous Waste Division P.O. Box 9583 8001 National Drive Little Rock, AR 72219 CALIFORNIA 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 Colorado Department of Health Waste Management Division 4210 E. 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 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 DELAWARE Department of Natural Resources and Environmental Control Solid Waste Management Branch P.O. Box 1401 Dover, DE 19903 DISTRICT OF COLUMBIA Department of Consumer and Regulatory Affairs Pesticides and Hazardous Waste Materials Division 5010 Overlook Avenue, S.W. Washington, DC 20032 FLORIDA Department of Environmental Regulation Solid and Hazardous Waste Section Twin Towers Office Building 2600 Blair Stone Road Tallahassee, FL 32301 GEORGIA Land Protection Branch Industrial and Hazardous Waste Management Program Floyd Towers East 205 Butler Street, S.E. Atlanta, GA 30334 GUAM Guam Environmental Protection Agency P.O. Box 2999 Agana, Guam 96910 31 ------- HAWAII Department of Health Environmental Health Division P.O. Box 3378 Honolulu, HI 96801 IDAHO Department of Health and Welfare Bureau of Hazardous Materials 450 West State Street Boise, ID 83720 ILLINOIS Environmental Protection Agency Division of Land Pollution Control 2200 Churchill Road Springfield, IL 62706 INDIANA State Board of Health Division of Land Pollution Control 1330 West Michigan Street Indianapolis, IN 46206 IOWA U.S. EPA Region VII Hazardous Materials Branch 726 Minnesota Avenue Kansas City, KS 66101 KANSAS Department of Health and Environment Bureau of Waste Management Forbes Field, Building 321 Topeka, KS 66620 KENTUCKY 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 LOUISIANA Office of Solid and Hazardous Waste Hazardous Waste Division Department of Environmental Quality P.O. Box 44307 Baton Rouge, LA 70804 MAINE Department 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 Department of Health and Mental Hygiene 201 W. Preston Street Baltimore, MD 21201 MASSACHUSETTS Department 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 MINNESOTA Pollution Control Agency Solid and Hazardous Waste Division 1935 West County Road B-2 Roseville, MN 55113 MISSISSIPPI Department of Natural Resources Bureau of Pollution Control Division of Solid and Hazardous Waste Management P.O. Box 10385 Jackson, MS 39209 MISSOURI Department of Natural Resources Waste Management Program 117 East Dunklin Street P.O. Box 1368 Jefferson City, MO 65102 MONTANA Department of Health and Environmental Sciences Solid and Hazardous Waste Bureau Cogswell Building Helena, MT 59620 32 ------- NEBRASKA Department of Environmental Control Hazardous Waste Management Section State House Station P.O. Box 94877 Lincoln, NE 68509 NEVADA Department of Conservation and Natural Resources Division of Environmental Protection Waste Management Program Capitol Complex 201 South Fall Street Carson City, NV 89710 NEW HAMPSHIRE Department of Health and Welfare Division of Public Health Services Office of Waste Management Health and Welfare Building Hazen Drive Concord, NH 03301 NEWJERSEY Department of Environmental Protection Division of Waste Management 32 E. Hanover Street, CN-027 Trenton, NJ 08625 NEW MEXICO Health and Environment Department Environmental Improvement Division Groundwater and Hazardous Waste Bureau P.O. Box 968 Santa Fe, NM 87504-0968 NEW YORK Department of Environmental Conservation Division of Solid and Hazardous Waste 50 Wolf Road Albany, NY 12233 NORTH CAROLINA Department of Human Resources Division of Health Services Solid and Hazardous Waste Management Branch P.O. Box 2091 Raleigh, NC 27602 NORTH DAKOTA Department of Health Division of Hazardous Waste Management and Special Studies 1200 Missouri Avenue Box 5520 Bismarck, ND 58502-5520 OHIO Ohio EPA Division of Solid and Hazardous Waste Management 361 East Broad Street Columbus, OH 43215 OKLAHOMA Oklahoma State Department of Health Waste Management Service P.O. Box 53551 1000 N.E. 10th Street Oklahoma City, OK 73152 OREGON Department of Environmental Quality Hazardous and Solid Waste Division P.O. Box 1760 Portland, OR 97207 PENNSYLVANIA Pennsylvania Department of Environmental Resources Bureau of Solid Waste Management P.O. Box 2063 Harrisburg, PA 17120 PUERTO RICO Environmental Quality Board P.O. Box 11488 Santurce, Puerto Rico 00910-1488 RHODE ISLAND Department of Environmental Management Solid Waste Management Program 204 Cannon Building 75 Davis Street Providence, RI 02908 SOUTH CAROLINA Department of Health and Environmental Control Bureau of Solid and Hazardous Waste Management 2600 Bull Street Columbia, SC 29201 33 ------- SOUTH DAKOTA Department of Water and Natural Resources Office of Air Quality and Solid Waste Foss Building Pierre, SD 57501 TENNESSEE Tennessee Department of Public Health Division of Solid Waste Management 701 Broadway Customs House Nashville, TN 37219-5403 TEXAS 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 UTAH Department of Health Bureau of Solid and Hazardous Waste Management P.O. Box 45500 State Office Building Salt Lake City, UT 84140 VERMONT Agency of Environmental Conservation Waste Management Division State Office Building Montpelier, VT 05602 VIRGIN ISLANDS Department of Conservation and Cultural Affairs P.O. Box 4399, Charlotte Amalie St. Thomas, Virgin Islands 00801 VIRGINIA Virginia Department of Health Division of Solid and Hazardous Waste Management 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 WEST VIRGINIA Division of Water Resources Solid and Hazardous Waste/Ground Water Branch 1201 Greenbrier Street Charleston, WV 25311 West Virginia Department of Natural Resources 1800 Washington Street, East Charleston, WV 25305 WISCONSIN Department of Natural Resources Bureau of Solid Waste Management P.O. Box 7921 Madison, WI 53707 WYOMING Department of Environmental Quality Solid Waste Management Program 122 West 25th Street Herschler Building Cheyenne, WY 82002 34 ------- |