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Census of State and
Territorial Subtitle D
Non-Hazardous Waste Programs
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ACKNOWLEDGMENTS
This report was submitted to the U.S. Environmental
Protection Agency by Westat, Inc. under Contract No. 68-01-7047.
The primary authors of the report are Gary Brown, Scotty Fallah,
and Cassie Thompson. The authors gratefully acknowledge the
following individuals at Westat for their contribution to this
study and to the production of this report on the Census of State
and Territorial Subtitle D Programs.
Daniel Tuttle Editorial review
David Horowitz Telephone survey
Pam Wisor Response coding
Pat Leydig Data processing
Nita Lemanski Word processing
Sandy Gallagher Word processing
Lori Kitt Graphics development
USEPA's Office of Solid Waste, Special Wastes Branch was the
lead office for this project. USEPA's Project Manager for the
Subtitle D study is Michael Flynn. Allen Geswein is the Project
Officer for this report. James Craig participated in earlier
phases of the project.
The contribution of the Association of State and Territorial
Solid Waste Management Officials is greatly appreciated. In
particular, the ASTSWMO members that contributed to this project
included:
Kerry Callahan ASTSWMO Staff
Sue Moreland ASTSWMO Staff
Jim Bearden Arkansas
Keith Amundsen California
Alan Oldall California
Jim Dziuba Connecticut
John England Connecticut
Charles Kurker Connecticut
Jim Dunbar Georgia
Bernie Bigham Maryland
Douglas John Maryland
Madeleine Kolb Massachusetts
Tom Easterly New York
David O'Toole New York
Wiley Osborne Texas
Finally, we wish to acknowledge the other individuals
associated with Westat, PEI Associates, Inc. and Development
Planning and Research Associates, Inc. who contributed to this
project.
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TABLE OF CONTENTS
Section Page
Part I INTRODUCTION
1. Background 1
1.1 RCRA Subtitle D Non-Hazardous Waste
Program 5
1.2 Need for the Survey of States and
Territories 5
1.3 Scope and Focus of the Subtitle D
Census 7
2 . Study Methodology 11
2 .1 Data Collection Technigue 11
2 . 2 Data Collection Instrument 11
2.3 Pretest of Instruments and Procedures 13
2.4 Quality Control 13
3 . Statistical Reliability 19
3.1 Overview of Statistical Reliability.. 19
3 . 2 Types of Non-Sampling Error . . . 20
3.3 Indicators of Non-Sampling Error 21
Part II STATE ORGANIZATION AND RESOURCES 27
4. State Organization and Resources 31
4.1 Agencies Involved in Subtitle D
Activities 31
4.2 Total Dollars Spent on Subtitle D
Activities 34
4.3 Sources of Funding for Subtitle D
Activities 35
4.4 Total Hours Expended on Subtitle D
Activities 37
4.5 Types of Subtitle D Activities
Engaged In 38
4.6 Importance Rankings for Subtitle D
Activities 38
IV
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TABLE OF CONTENTS (Continued)
Section Page
Part III NUMBER AND CHARACTERISTICS OF SUBTITLE D
WASTE FACILITIES 43
5. Landfills 47
5.1 Assessment of Data Quality 48
5.2 Estimated Number of Active
Subtitle D Landfills in 1984 49
5.3 Estimated Number of Landfills by
State and EPA Region 49
5.4 Basic Characteristics of Subtitle D
Landfills 53
6. Land Application Units 65
6.1 Assessment of Data Quality 66
6.1 Estimated Number of Active Subtitle
D Land Application Units in 1984... 67
6.3 Estimated Number of Land Application
Units by State and EPA Region 67
6.4 Basic Characteristics of Subtitle D
Land Application Units 70
7 . Surface Impoundments 81
7 .1 Assessment of Data Quality 83
7.2 Estimated Number of Active Subtitle D
Surface Impoundments in 1984 84
7.3 Estimated Number of Surface Impound-
ments by State and EPA Region 86
7.4 Basic Characteristics of Subtitle D
Surface Impoundments 91
8. Landfills 103
8.1 Subtitle D Landfill Regulations 103
8.2 Landfill Permitting/Licensing
Requirements 107
8.3 State Enforcement Programs for
Subtitle D Landfills 107
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TABLE OF CONTENTS (Continued)
Section Page
Part IV SUBTITLE D PROGRAM ASSESSMENT 99
9. Land Application Units 115
9.1 Subtitle D Land Application Unit
Regulations 115
9.2 Land Application Unit Permitting/
Licensing Requirements 120
9.3 Enforcement Programs for Subtitle D
Land Application Units 120
10. Surface Impoundments 127
10.1 Subtitle D Surface Impoundment
Regulations 127
10.2 Surface Impoundment Permitting/
Licensing Requirements 132
10.3 State Enforcement Programs for
Subtitle D Surface Impoundments.... 135
Part V SMALL QUANTITY GENERATOR WASTE ' 139
11. Small Quantity Generator Waste 143
11.1 Quality of Exempted Non-Household
Hazardous Waste Receipt Data 143
11.2 Estimated Percentage and Number of
Subtitle D Facilities Receiving
Non-Household Hazardous Waste 144
Part VI SUMMARY AND CONCLUSIONS 149
12. Results 153
12.1 Methodological Results 153
12.2 Substantive Findings 154
13. Conclusions 173
Appendices
A LANDFILL CAPACITY PROBLEMS A-l
B LANDFILL TIPPING FEES B-l
C EXHIBITS (EPA COVER LETTER/ASTSWMO COVER LETTER) C-l
D STATE SUBTITLE D PROGRAM QUESTIONNAIRE D-l
(Numbering system of original questionnaire
retained)
VI
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List of Figures
Figure
5.1 Number of Subtitle D Landfills by Type 50
5.2 Number of Subtitle D Landfills by State/
Territory 51
5.3 Percentage Accounted for by the Five States with
the Largest Number of Landfills by Type 52
5.4 Estimated Number of Subtitle D Landfills by
EPA Region 54
6.1 Number of Subtitle D Land Application Units by
Type 68
6.2 Number of Land Appplication Units by State/
Territory 69
6.3 Percentage Accounted for by the Five States
with the Largest Number of Land Application
Unit by Type 71
6.4 Number of Subtitle D Land Application Units
by EPA Region 72
7.1 Number of Subtitle D Surface Impoundments by
Type 85
7.2 Number of Subtitle D Surface Impoundments by
State/Territory 87
7.3 Percentage Accounted for by the Five States
With the Largest Number of Surface
Impoundments by Type 88
7.4 Number of Subtitle D Oil and Gas Waste Surface
Impoundments by State/Territory 89
7.5 Number of Subtitle D Surface Impoundments
by EPA Region 90
12.1 Number of Agencies with Subtitle D
Responsibilities Reported in Each State 156
12.2 Percentage Accounted for by the Five States
with the Largest Number of Subtitle D
Facilities by Type 159
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List of Tables
Table Page
4 .1 Sources of Subtitle D Funding 36
4.2 Percentage of Hours Engaged in Subtitle D
Activities 39
4.3 Importance Rankings for Subtitle D Activities.. 41
5.1 Number of Subtitle D Landfills by Ownership
Category 55
5.2 Number of Subtitle D Landfills by Acreage
Category 57
5.3 Number of Subtitle D Landfills by Amount of
Waste 58
5.4 Number of Subtitle D Landfills Having
Monitoring Systems 60
5.5 Number of Subtitle D Landfills Having Design
and Operational Controls 61
6.1 Number of Subtitle D Land Application Units by
Ownership Category 73
6.2 Number of Subtitle D Land Application Units by
Acreage Category 75
6.3 Number of Subtitle D Land Application Units by
Amount of Waste 76
6.4 Number of Subtitle D Land Application Units
Having Monitoring Systems 77
6.5 Number of Subtitle D Land Application Units
Having Design and Operational Controls 79
7.1 Number of Subtitle D Surface Impoundments by
Ownership Category 92
7.2 Number of Subtitle D Surface Impoundments by
Acreage Category 93
7.3 Number of Subtitle D Surface Impoundments by
Amount of Waste 94
7.4 Number of Subtitle D Surface Impoundments
Having Monitoring Systems 97
7.5 Number of Subtitle D Surface Impoundments
Having Design and Operational Controls 98
8 .1 Subtitle D Landfill Regulations 104
8.2 Subtitle D Permitting/Licensing Requirements:
Landfills 108
8.3 Number of Subtitle D Landfills with Permits
and Licenses 109
8.4 Frequency of Inspection of Subtitle D
Landfills 110
x
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List of Tables (Continued)
Table Page
8.5 Number of Inspections of Subtitle D Landfills
in 1984 112
8.6 Number of Landfills by Type of Violation in
1984 113
9.1 Subtitle D Land Application Unit Regulations.. 116
9.2 Subtitle D Permitting/Licensing Requirements:
Land Application Units ; 121
9.3 Number of Subtitle D Land Application Units
with Permits/Licenses. 122
9.4 Frequency of Inspections of Subtitle D Land
Application Units 123
9.5 Number of Inspections of Subtitle D Land
Application Units in 1984 124
9.6 Number of Land Application Units by Type of
Violation in 1984 126
10.1 Subtitle D Surface Impoundment Regulations.... 128
10.2 Subtitle D Permitting/Licensing Requirements:
Surface Impoundments 133
10.3 Number of Subtitle D Surface Impoundments with
Permits/Licenses 134
10.4 Frequency of Inspections of Subtitle D Surface
Impoundments 136
10.5 Number of Inspections of Subtitle D Surface
Impoundments in 1984 137
10.6 Number of Surface Impoundments by Type of
Violation in 1984 138
11.1 Number and Percent of Landfills that Receive
Exempted Non-Household Hazardous Waste 146
11.2 Number and Percent of Land Application Units
that Receive Exempted Non-Household
Hazardous Waste 147
11.3 Number and Percent of Surface Impoundments
that Receive Exempted Non-Household
Hazardous Waste 148
12.1 Reported Number of Subtitle D Facilities
by Type 158
12.2 Ownership of Subtitle D Facilities 160
12.3 Number of Subtitle D Facilities by Acreage
Category 161
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List of Tables (Continued)
Table Page
12.4 Percent of Subtitle D Facilities Having
Monitoring Systems 163
12.5 Number and Percent of Permitted Facilities 165
12.6 Number and Percent of State/Territory
Inspections in 1984 166
12.7 Frequency of Inspections of Subtitle D
Facilities 168
12.8 Groundwater, Surface Water, and Air
Contamination Violations in 1984 169
12.9 Groundwater Monitoring Systems/Violations 171
12.10 Percent of Subtitle D Facilities Receiving
Exempted Non-Household Hazardous Waste 172
XI1
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PART I
INTRODUCTION
Section 1. Introduction
Section 2. Study Methodology
Section 3. Statistical Reliability
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PART I
INTRODUCTION
This report summarizes the findings of a census of
State and Territorial Subtitle D non-hazardous waste programs.
The census was conducted by mail, with extensive telephone
followup, during the fall and winter of 1985-86. The census was
sponsored by the United States Environmental Protection Agency's
Office of Solid Waste, in cooperation with the Association of
State and Territorial Solid Waste Management Officials (ASTSWMO),
and was administered by Westat, Inc., a national survey firm
based in Rockville, Maryland. Westat provided technical
assistance in designing the census, implementing it, and
analyzing its results.
The census of Subtitle D non-hazardous waste programs
included all 50 States, the Commonwealth of Puerto Rico, the
Virgin Islands, Guam, American Samoa, and the Commonwealth of the
Northern Marianas. The District of Columbia is not included in
the results of the study because it reported no Subtitle D
facilities and no Subtitle D program.
This report, developed by Westat for the Office of
Solid Waste, describes the background, objectives, methods,
results, and conclusions of the census of State and Territorial
Subtitle D non-hazardous waste programs.
The body of the report is organized in six major parts
composed of twelve sections in all. Part I (Sections 1-3)
contains the introduction to the report, the study methodology,
and a description of the statistical reliability of the data.
Part II (Section 4) describes State organizational structures and
resources for Subtitle D programs. Part III (Sections 5-7)
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provides information on the total number and basic
characteristics (ownership, acreage, amount of waste received,
monitoring systems,design and operational controls) of Subtitle D
waste facilities. Part IV (Sections 8-10) provides data on
Subtitle D regulatory programs, including information on
regulations and enforcement patterns. Part V (Section 11)
contains information with respect to the number and quantity of
Subtitle D facilities that receive exempted non-household
hazardous waste. Part VI (Sections 12 and 13) provides a summary
and conclusions of the report.
There are four appendices to this report. Appendix A
provides the responses to a question on the survey concerning
landfill capacity problems. Appendix B contains data tables with
estimates of landfill tipping fees. The cover letters that
accompanied the questionnaire are in Appendix C. Appendix D is a
copy of the State Subtitle D Program Questionnaire.
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1. BACKGROUND
The background of this study, including a summary of
pertinent Subtitle D legislation, a description of the need for
the study, and a review of the scope and focus of the study are
presented in this section.
1.1 RCRA Subtitle D Non-Hazardous Waste Program
Congress enacted the Resource Conservation and Recovery
Act (RCRA) in 1976 to protect human health and the environment
from improper waste management practices. In 1979, under
authority of Sections 1008(a) and 4004(a) of Subtitle D of RCRA,
EPA promulgated "Criteria for Classification of Solid Waste
Disposal Facilities and Practices" for determining what solid
waste disposal practices pose a reasonable probability of adverse
effects on health and the environment (40 CFR Part 257) . States
were encouraged to use the "Criteria" to classify facilities as
either open dumps or sanitary landfills. Those facilities that
violated the "Criteria" were to be classified as open dumps.
In 1979, EPA also promulgated guidelines for the
development of State Solid Waste Management Plans (40 CFR Part
256). These guidelines reguired that States seeking EPA Subtitle
D grant funds have the authority to prohibit, close, and upgrade
open dumps. Grant funds were available from 1977 to 1981.
Outside of approval of State plans and the disbursement of grant
funds, EPA had no direct implementation authority. State
participation in this program was voluntary.
EPA's funding of State Subtitle D activities was
terminated after 1981. Since then the focus of EPA's efforts has
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been on the Subtitle C (hazardous waste) program. As a result of
terminating Subtitle D activities in 1981, little information was
available to EPA on the status of State non-hazardous waste
programs and on the facilities themselves.
The RCRA Amendments (signed into law on November 8,
1984) require EPA, by November 8, 1987, to submit a report to
Congress addressing:
o whether the RCRA 1008(a) and 4004 criteria (40 CFR
257) are adequate to protect human health and the
environment from ground-water contamination, and
o whether additional authorities are needed to
enforce the "Criteria".
Further, EPA must revise the "Criteria" by March 31, 1988, for
facilities that may receive hazardous waste or small quantity
generator waste. These revisions are to include ground-water
monitoring, location restrictions, and corrective action, as
appropriate. '
Within 18 months of the promulgation of the revised
"Criteria", each State must develop a permit program or other
system of prior approval and conditions to ensure that each
facility that may receive hazardous household waste or small
quantity generator waste is in compliance with the "Criteria".
The 1984 Amendments envision Subtitle D to continue to be a
State-implemented program. If States fail to enforce the
"Criteria", however, EPA may do so.
1.2 Need for the Survey of States and Territories
In order to determine whether the present Subtitle D
Criteria are adequate and to assess whether additional
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authorities are needed to enforce the criteria, EPA developed a
plan for the completion of a major Subtitle D study. The census
of State and Territorial Subtitle D non-hazardous waste programs
described in this report is a major component of the overall EPA
Subtitle D study plan. The primary objectives of the overall EPA
Subtitle D study are to;
1. Evaluate the extent and causes of human health and
environmental impacts at Subtitle D facilities;
2. Evaluate management practices and control tech-
nologies, including siting, liners, monitoring,
and corrective action;
3. Evaluate State programs (status, effectiveness,
needs); and
4. Determine whether the RCRA 1008(a) and 4004
criteria are adequate to protect human health and
the environment.
Data from the State/Territorial census were required to
determine the effectiveness of current Subtitle D guidelines and
regulations, to examine the extent of any program deficiencies,
and to recommend measures to Congress that would improve the
effectiveness of the Subtitle D program. These data were also to
be used in EPA's regulatory analyses and decision making
processes. More specific information regarding the objectives of
the census of State and Territorial non-hazardous waste programs
is provided in the next section.
1.3 Scope and Focus of the Subtitle D Census
The mail questionnaire Subtitle D census included all
50 States, the Commonwealth of Puerto Rico, the Virgin Islands,
Guam, American Samoa, and the Commonwealth of the Northern
Marianas. The District of Columbia was included in the mailing,
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but no results are given in this study because it reported no
Subtitle D facilities and no Subtitle D program.
The mail questionnaire used in the Subtitle D census
was designed to collect data in the following areas: (1) State
organization and resources; (2) State regulations and
enforcement; (3) numbers of Subtitle D facilities and
establishments; (4) unit design and operating characteristics;
(5) data availability; and (6) contact persons for Subtitle D
programs.
The survey questionnaire included the following
sections: General Instructions, State Organization and
Resources, Landfills, Land Application Units, and Surface
Impoundments. The sections for the latter three categories
(facility types) were each further broken down into the following
subsections:
o Regulations;
o Enforcement;
o Numbers of units and establishments;
o Design and operating characteristics;
o Availability of additional data; and
o Contact persons.
Data on regulations were sought to help evaluate the
status of each State's Subtitle D program. Enforcement data were
requested to help determine the level of implementation of the
regulations.
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Data on the numbers of facilities and establishments
were sought to define the potential universe of affected
Subtitle D units for use in the analyses of regulatory and
nonregulatory options and the revision of the "Criteria."
Design and operating characteristics were requested to
determine how frequently various Subtitle D facility designs and
operating methods are used. These data were necessary for the
completion of a regulatory impact analysis.
Questions on the availability of data were designed to
identify States and Territories with monitoring data and case
study data that could be used for detailed evaluations of
specific technologies.
The information on State contact persons was requested
to allow EPA to clarify responses in the study.
The questionnaire included responses concerning
municipal wastewater surface impoundments. Information on these
facilities was collected to be used by EPA's Office of Water
Programs in a separate regulatory effort. These facilities are
specifically exempted from Subtitle D regulations but are
regulated under the Clean Water Act. Municipal wastewater
surface impoundments are not included in the data reported here,
with the exception that the total number of such facilities is
reported in Section 7.2. Also, waste piles, while regulated
under Subtitle D, were not included in this survey because of the
difficulty in defining waste piles across States. Data
concerning these Subtitle D facilities will be collected in the
future using a different methodology.
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2. STUDY METHODOLOGY
In this section the study methodology is described,
including the basic data collection technique, data collection
instrument, and the many varied quality control procedures that
were used in the study.
2.1 Data Collection Technique
A census of all States and Territories was selected as
the basic study methodology rather than a sampling of States and
Territories because of the small number of total units in the
population and their great variability with respect to the study
estimates.
A mail questionnaire data collection approach was
selected rather than in-person interviews or telephone interviews
as the primary data collection approach. In-person reviews of
State and Territorial records would have been desirable, but the
large amount of information desired and the fact that in many
cases this information was not easily accessible would have
resulted in far too great a financial cost to perform the study
using in-person visits. Telephone interviews were not suitable
as the primary data collection approach because they would not
allow time for the respondents to consult records, files, and
other individuals when answering the questions.
The basic mail packet sent out to each State and
Territory included the following:
1. A cover letter from EPA (shown in Exhibit C.I,
Appendix C);
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2. A cover letter from the Association of State and
Territorial Solid Waste Management Officials
(ASTSWMO) (shown in Exhibit C.2, Appendix C);
3. Multiple copies of the study questionnaire (shown
in Appendix D); and
4. Self-Addressed, postage-paid return envelopes.
2.2 Data Collection Instrument
The questionnaire used in the Census of State and
Territorial Subtitle D Programs was developed in successive
stages, incorporating inputs from EPA personnel, contractor
personnel, and representatives from ASTSWMO. An initial list of
information requirements based upon an assessment of data needs
was developed by EPA and circulated to a number of EPA offices
for comment. Contractor personnel then translated this list of
information needs into specific questions for the study. The
initial draft of questions was then circulated once again within
EPA for additional comment. Revisions were then made to the
questionnaire and a series of discussions between EPA, contractor
personnel, and representatives from ASTSWMO were then held to
revise and finalize the questionnaire.
The major conclusions of these discussions were that:
1. Subtitle D programs and definitions of basic terms
vary widely from State to State;
2. Previous data collection efforts suffered from the
fact that they were incomplete;
3. Detailed information, in certain instances, would
be easier for respondents to provide than
aggregated information; and
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4. Structuring the questionnaire into four major
section would allow more than one individual to
complete the questionnaire, enabling specialists
to work together on questionnaire completion,
while reducing overall respondent burden.
Based upon the above conclusions a number of questionnaire
changes relating to quality control were incorporated into the
data collection instrument. These changes are described in
Section 2.4, Quality Control Procedures.
2.3 Pretest of Instruments and Procedures
A pretest of the data collection instrument was
conducted in nine States. The conditions of the pretest
simulated the full survey, except that:
o respondents were asked to complete the data
collection form in less time than was to be
allotted in the study;
o respondents were precontacted and urged to supply
a swift response for pretesting purposes; and
o contractors actively solicited comments by
telephone on respondent suggestions for improving
the questionnaire.
The results of the pretest indicated that the
definitions, instructions, sample questions, and diagrams were
understood by the respondents, but that significant amounts of
time would be required for completion of the questionnaires.
2.4 Quality Control
Numerous quality control (QC) techniques were used in
the Census of State and Territorial Subtitle D Programs. These
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techniques were applied in the design of the data collection
instrument, in the visual editing of all mail returns, in the
telephone followups conducted to resolve inconsistencies in
responses, and in the computer editing of all data. In addition,
the "Subtitle D Specialist" was available through a toll-free
telephone number if respondents needed clarification of any items
on the questionnaire.
2.4.1 Questionnaire Design QC Techniques
To help ensure that respondents understood the
questions and were responding to the same question in a
consistent fashion, the questionnaire was designed to include the
following:
o Definitions of all facility types included in the
study;
o Diagrams of each facility type indicating the
specific facility types that would and would not
be included in the responses;
o Instructions built into the questionnaire to
standardize the dimensions on which responses were
being made (e.g., calendar year 1984, Fiscal Year
ending in 1984); and
o Sample questions indicating how responses were to
be recorded for each major question/response
format used in the questionnaire.
Whenever possible, the questionnaire was also designed to
indicate cases in which responses to one question were to match
responses to another question. These served as cross-checks for
the respondents while they were completing the questionnaire.
As a further quality control technique the
questionnaire included a respondent rating system. This rating
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system allowed respondents the opportunity to indicate that they
believed the quality of one of their responses was good, fair,
poor, or very poor. The rating system thus allowed for the
determination of data quality as a whole in the analysis of the
study data. The instructions provided in the questionnaire for
the data quality rating system are provided in Appendix D, on
page 7 of the questionnaire.
2.4.2 Visual Editing QC Techniques
Each returned questionnaire was immediately logged in
and reviewed as another quality control technique. These visual
edits included, for the most part, the same basic checks the
computer data editing programs were set up to accomplish. The
following is a partial list of the types of visual edits made:
o checks on the completeness of the data,
(identification of specific questionnaire items
with missing responses);
checks on the consistency of the data (review of
responses from one question to another to
determine if answers were consistent); and
o checks on the accuracy of the data (determination
as to whether or not a particular response was
accurate based on comparisons with other data,
including reviews of secondary data, lists
supplied by the States, results of other research
studies conducted in the past, etc.);
2.4.3 Telephone Followup QC Techniques
Telephone callbacks to the key contact persons listed
for each major section of the questionnaire represented a major
quality control technique in the Subtitle D census. Telephone
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callbacks were made to resolve each item identified in the visual
edit as requiring explanation. Approximately 50 of the 55 States
and Territories were recontacted by telephone. On the average it
was necessary to contact four people in each State/Territory
during the telephone followup QC attempts. In one State,
however, it was necessary to speak with 11 individuals regarding
various responses in the questionnaire. Numerous recontacts were
often required as records, files, and other individuals within
the State were often consulted by the State and Territorial
contacts in the process of resolving the questionnaire responses.
In all, data quality callbacks were made over a three and one-
half month period. On the average, over two and one-half hours
of actual telephone connect time was required to resolve
questionnaire data issues in each of the 50 States and
Territories which were recontacted by phone.
2.4.4 Computer Editing QC Techniques
A very large number of computer editing checks,
corresponding to all of the visual edit checks, plus additional
checks which were more difficult to observe, were conducted in
the Subtitle D Census. Computer range checks, error checks,
logic checks, and other editing procedures were applied after the
visual editing and primary round of telephone followups were
completed. Each inconsistency in questionnaire data was then
flagged and a second round of recontacts with State/Territorial
personnel were accomplished in an attempt to resolve all possible
errors, omissions, and inconsistencies in the questionnaire data
set before analyzing the data.
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2.4.5 Data Entry QC Techniques
All data entered on the Subtitle D census data tape
were 100 percent key verified. In addition, a number of key
questionnaire items were analyzed separately and compared with
the data on the data tape to ensure the accuracy of data entry.
2.4.6 Toll-Free Telephone Number
The toll-free number to reach the Subtitle D Specialist
was used quite frequently. The respondents usually wanted
clarification of the definitions of various types of facilities.
Several calls concerned the fact that the questionnaire had not
reached the appropriate office or agency and the person receiving
the questionnaire was unsure where to send it.
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3. STATISTICAL RELIABILITY
In this section the quality of the data obtained in the
Census of State and Territorial Subtitle D Non-Hazardous Waste
Programs is addressed. This section has been prepared to help
the reader answer the following types of questions:
o How much confidence can one place in the estimates
presented in this report;
o What are the limitations of the study data;
o Are some estimates inaccurate; and
o Which estimates appear to be the most (and least)
reliable?
3.1 Overview of Statistical Reliability
Statistical reliability is a function of the objectives
of the study, the particular research techniques one elects to
apply in the study, and the many varied methods and procedures
used to carry out the study.
A principal objective of the study described here was
to estimate the total number of elements in a predefined
population. Estimates of the total number of dollars and hours
expended on Subtitle D activities, the total number of permitted
and unpermitted Subtitle D facilities, and the total number of
facilities by type (e.g., municipal landfills, oil or gas waste
surface impoundments) were required.
The primary research approach for the estimation of
total numbers in this study was a mail questionnaire census of
all State and Territorial Subtitle D programs. A census was
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selected as the research methodology, rather than a sample of
States and Territories, due to the small number of total elements
in the predefined population (50 States and five Territories) and
due to the great variability expected within States and
Territories with respect to the estimates to be generated. Also,
a census would provide one additional advantage over a sample
survey no sampling error would be associated with the study
estimates. That is, no inherent error would be encountered due
to the fact that a sample was taken rather than a complete census
of the population. Any errors that would be associated with the
study would thus fall under the general category of non-sampling
errors. Non-sampling errors are discussed below.
3.2 Types of Non-Sampling Errors
Non-sampling errors refer to all of those errors in a
study that are not attributable to sampling. Although such
potential errors are generally difficult to quantify, it is
important to acknowledge these sources so that users of study
data may be aware of their possible effects.
Potential sources of non-sampling errors include:
o difficulty in locating information;
o misinterpretation of questions;
o inadequate definitions of terms;
o inappropriate assumptions in the questions;
o rounding errors;
o conversion errors (e.g., gallons to tons);
o biased or ambiguous questions;
o transcription errors;
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o undetected data entry errors;
o nonresponse errors; and
o estimation errors.
These and other sources of errors produce an overall non-sampling
error in a study. While, in general, the overall non-sampling
error cannot be measured precisely from the data collected in a
study, it is nonetheless possible to assess the likely overall
impact of such errors on various survey estimates. Indicators of
non-sampling error in this study are presented below.
3.3 Indicators of Non-Sampling Errors
There were three primary indicators of the existence of
non-sampling errors in the Census of State and Territorial
Subtitle D Non-Hazardous Waste Programs. First, was the response
rate to the study as a whole and to each of the individual
questions asked in the study. Second, were reports of the
quality of data from the respondents themselves. Third, were the
visual and computer edit checks made on the completed
questionnaires. Each of these is treated individually below.
3.3.1 Nonresponse
Ideally, one would obtain estimates from each
population element for each estimate to be produced in a study.
Seldom, however, is such an ideal situation actually encountered,
Some amount of nonresponse is almost always encountered.
Generally, adjustments to study data are required to account for
this nonresponse and to reduce its potential impact.
21
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There are a wide variety of techniques available for
making adjustments due to nonresponse. None of these techniques
were applied in the present study, however, for the following
reasons.
1. First, great variability was observed from one
State and Territory to another with respect to the
actual values of the estimates. A very small
number of States and Territories often accounted
for a very large portion of the total 'for many
variables being studied. The very small number of
total elements in the population, their great
variability and the importance of a very small
number of States and Territories all combined to
make indirect estimations or extrapolations for
the nonrespondents potentially subject to an
unknown amount of error.
2. Second, it was determined that a large percentage
of the nonresponse in this study was directly
attributable to the inability of States and
Territories to compile existing information.
Thus, it would be possible through further data
collection efforts, if necessary, to fill in many
of the gaps in the data by additional research
efforts.
3. Third, a very important underlying objective of
this study was to identify where gaps exist in the
data. For example, extensive regulations covering
particular types of Subtitle D facilities might be
one indicator of the potential effectiveness of
Subtitle D programs. If the number of Subtitle D
facilities to which these regulations were to be
applied were unknown, however, a somewhat
different conclusion regarding Subtitle D program
effectiveness might be reached. Nonresponse due
to the inability of States and Territories to
provide information was thus a type of conclusion
in and of itself.
4. Fourth, and most importantly, it was decided that
the most accurate projections of estimates for
nonresponse would involve additional data
collection efforts that would not be within the
scope of this study.
22
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Obviously, if one wishes to estimate totals for a
population as a whole, and gaps due to nonresponse are present
for some of the units in the population, an underestimate is
encountered. This is the case with many of the estimates
presented in this report. Because this is so, the reader is
advised to review the information on response rates presented
with each study estimate.
In general, nonresponse is an important factor to be
considered with respect to most estimates presented in this
report. Nonresponse is especially important, however, with
respect to the following:
o estimates of the total number of dollars and hours
spent on Subtitle D activities;
o estimates of the total number of surface
impoundments; and
o estimates of the total'number of industrial
Subtitle D facilities.
Once again, however, the reader is advised to take the
potential effects of nonresponse into consideration when
reviewing each estimate in this report. To aid in this
assessment, there are entries labelled "Response rate" on most of
the tables in this report. Response rate is calculated as the
number of facilities for which responses were obtained divided by
the total number of facilities reported of a given type. Thus,
the higher the response rate, the more reliable are the estimates
to which the response rate applies.
23
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3.3.2 Respondent Data Quality Ratings
Respondent ratings of the quality of the data they
reported in this study were obtained in two ways. First, as •
described in Section 2.4.1, a respondent data quality rating
system was built into the questionnaire. Second, perceptions of
the quality of the study data were requested of respondents in
followup telephone conversations.
In general, with respect to the total number and types
of Subtitle D facilities, the quality of the data regarding
municipal waste landfills is the highest. Most States and
Territories have comparatively up to date record-keeping systems
with regard to municipal waste landfills and most estimates
provided in the study appear to be rather reliable for these
types of Subtitle D facilities.
In general, with respect to the total number and types
of Subtitle D facilities, the quality of the data regarding
surface impoundments is the lowest. Only a very small number of
States appear to have up-to-date information with respect to the
number and types of surface impoundments within their
jurisdictions. Respondent data quality ratings for estimates on
surface impoundments were frequently in the poor to very poor
range. Telephone conversations with the respondents indicated
further that little information regarding surface impoundments is
readily available. In some cases information exists in State
files regarding surface impoundments, but this information has
never been compiled and is not in a format that is usable for
management purposes. In many other cases, the most recent
information available to States on the total number of surface
impoundments was obtained as part of an EPA-sponsored study that
was conducted during the 1979-1980 time period.
24
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In general, the quality of the data regarding the
number and types of land application units and the number and
types of industrial waste Subtitle D facilities is somewhere
between the high quality of the municipal waste landfills and the
low quality of the surface impoundments. Ratings for land
application units and industrial facilities types were frequently
in the fair, poor, or very poor range.
In general, data with respect to the number of
permitted and licensed facilities, the number of inspections, and
the number of violations were estimated using available State and
Territorial records and thus these data may be somewhat more
reliable than other estimates for which no records were
available. While some States and Territories may not have been
able to consult their records to the extent they wished when
answering these questions, most respondents reported that
attempts were made to consult existing information with respect
to permitted facilities, inspections, and violations.
In general, information with respect to the number of
Subtitle D facilities having monitoring systems and release
prevention/management methods was estimated without the benefit
of existing records. The quality of these estimates is likely to
parallel somewhat the quality of the estimates of the specific
facility types mentioned earlier (e.g., highest for municipal
waste landfills, lowest for surface impoundments, etc.).
3.3.3 Visual and Computer Editing
A third and final indication of the statistical
reliability of the data and the extent of non-sampling errors
encountered in the study was obtained as a result of the visual
and computer editing of the questionnaire data. Visual and
25
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computer editing approaches are described in Section 2.4, Quality
Control.
A very large number of errors, inconsistencies, and
omissions were observed when initial visual edits were made of
the returned questionnaire data. Cross-checks built into the
questionnaire for quality control purposes were first used to
identify respondent errors and inconsistencies. All missing data
elements were then listed. Telephone followup calls were then
made in an attempt to resolve all issues.
The vast majority of the errors, inconsistencies, and
omissions found in the original questionnaire data were resolved
through these extensive telephone followups. Whenever it was
impossible to resolve an error, inconsistency, or omission in the
questionnaire data, the standard practice was to treat the
information as missing for purposes of final study estimates.
Computer edit checks were then made to identify any
issues overlooked during the visual editing checks. Additional
telephone followups were then conducted until all non-sampling
errors due to misinterpretation of questions, inappropriate
assumptions, transcription errors, etc., that could be identified
were resolved.
In general, while there were many non-sampling errors
encountered in the visual and computer editing stages of the
project, the vast majority of these were resolved through
telephone followup contacts. Those which could not be resolved
were treated as missing data for purposes of this report.
26
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PART II
STATE ORGANIZATION AND RESOURCES
Section 4. State Organization and Resources
27
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PART II
STATE ORGANIZATION AND RESOURCES
Part II provides information with respect to State
organizational structures and financial resources for Subtitle D
activities. The following study findings are presented in
Part II:
o types of State agencies involved in developing,
regulating, enforcing, overseeing, and otherwise
administering any part of the Subtitle D program;
o total dollar amount budgeted and/or spent by State
agencies for Subtitle D related work for the
fiscal year ending in 1984;
o sources of Subtitle D related funding in fiscal
years ending in 1984 and 1985;
o total number of person hours expended by State
agencies on work directly related to Subtitle D
establishments, issues, and activities during the
fiscal year ending in 1984;
o types of Subtitle D activities engaged in by State
agencies; and
o rankings with respect to the overall improvement
expected in a variety of activities assuming
additional resources were available for Subtitle D
programs.
To properly interpret the findings provided in this
part of the report, the reader is advised to review Part I,
Section 3, "Statistical Reliability" and the complete discussion
within each section below.
29
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4. STATE ORGANIZATION AND RESOURCES
4.1 Agencies Involved in Subtitle D Activities
As part of this study, each State and Territory was
asked to list all agencies having separate budgets that were
responsible for developing, regulating, enforcing, overseeing,
and otherwise administering any part of the Subtitle D program.
A total of 141 agencies (an average of 2.6 agencies per State/
Territory) were listed. Responses were obtained in all cases
with the exception of one U.S. Territory.
A wide variety of agency types are reported to become
involved in Subtitle D activities. Solid waste and water related
agencies were listed most frequently. In many cases, departments
of environmental protection, natural resources, public works, and
health were listed as overseeing agencies. Numerous other
agencies were reported as well to be involved in administering
programs for specific Subtitle D facility types. Such agencies
included oil and gas commissions, mining and reclamation bureaus,
soil conservation commissions, bureaus of energy or geology, and
air compliance, agriculture, livestock, and other offices.
Subtitle D programs for landfills were most frequently
reported to be administered by solid waste agencies. Subtitle D
programs for surface impoundments were most frequently reported
to be administered by water agencies. Subtitle D land
application programs were generally administered, depending upon
the State involved, by either a solid waste agency or a water
agency.
In general, the organization of Subtitle D activities
varied greatly from one State or Territory to the next.
31
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It is likely that not all agencies involved in
Subtitle D related activities were listed by States and
Territories. With the possible exception of most Solid Waste
Agencies, the activities of other State agencies are not
generally perceived to be related to Subtitle D programs. This
is true even though agency activities may involve direct
enforcement efforts for particular types of Subtitle D
facilities. Many water agencies, for example, do not view their
own activities as involving Subtitle D legislation, nor do others
view them as such. This finding was repeated time and again in
the telephone followups to the mail questionnaire data. In one
State, the key contact person for two sections of the
questionnaire (Part III. Land Application Units and Part IV.
Surface Impoundments) was the director of that State's water
group, and yet the water group was not listed as an agency
involved in Subtitle D activities. Subsequent telephone calls
indicated that the State water agency was inadvertently omitted
from the original mail questionnaire list and that the water
agency, in fact, spent considerably more money on Subtitle D
facilities than did all other agencies in that State, combined.
It is possible that other water agencies were unintentionally
omitted from the list as well because water agencies are not
generally perceived to have activities related to Subtitle D
programs.
Other agencies that are responsible for only one
particular type of Subtitle D facility may also have been omitted
from the lists. Oil and gas commissions, mining offices and
other offices that are responsible for oil or gas waste or mining
waste surface impoundments only may also have been omitted.
Based on mail questionnaire returns it was often necessary to
recontact some States and Territories by telephone to obtain
further information regarding a survey response. In numerous
32
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cases, telephone followup personnel were directed to agencies,
such as oil or gas commissions for further information on numbers
of inspections conducted, violations reported, etc., even though
these agencies were not reported on the list of agencies involved
in Subtitle D activities.
Another important point is that few agencies are
perceived to have a specific budget for Subtitle D activities.
In numerous cases State agencies were not initially listed in the
questionnaires because they were not perceived to have Subtitle D
budget monies. This was the case even though these agencies may
have spent considerable sums in inspecting Subtitle D facilities.
In some cases it appears that money is redirected from other
agency programs to help offset the lack of money for Subtitle D
programs. In these and other cases respondents were reluctant to
list an agency "with a separate budget that is responsible for
developing, regulating...any part of the Subtitle D program," as
the question was Stated in the mail survey. Telephone followup
contacts were attempted with each State and Territory to
encourage respondents to list State agencies involved in
Subtitle D programs, even though they may not have had a
predetermined budget specifically for Subtitle D programs.
As a result of all telephone followup contacts a total
of 25 State agencies involved in Subtitle D activities were added
to the original mail questionnaire returns. It is likely that a
number of additional agencies were not discovered by telephone.
In addition to the above factors, the list of State
agencies may also be incomplete with respect to the inclusion of
regional or district offices of major State agencies responsible
for Subtitle D activities. Only a small number of States elected
to include regional or district offices on their lists, even
though State organizational structures are such that these
33
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offices may be heavily involved in Subtitle D inspection/
enforcement programs.
4.2 Total Dollars Spent on Subtitle D Activities
Respondents were asked to provide budget information
for each agency identified as being involved in developing, .
regulating, enforcing, overseeing, and otherwise administering
any part of the Subtitle D program. Dollars spent on Subtitle D
related activities were reported for 104 out of 141 agencies
listed. The total dollar amount reported for these agencies was
$39,282,445. California reported spending the most on Subtitle D
related activities ($9,476,255). The average number of dollars
reported per State/Territory was $785,649.
The total dollar amount reported above is likely to be
a large underestimate of the total dollars spent in FY 1984 on
Subtitle D related activities. No estimates of dollars spent
were provided for 39 of 141 agencies listed. Water agencies
accounted for one-third of these cases (13) with missing dollar
information. As Stated in Section 4.1, many water agencies do
not perceive their activities to be Subtitle D related and many
do not consider themselves to have a Subtitle D budget. In
telephone followup reg^iests to obtain even very rough estimates
of the amount of money spent on Subtitle D activities by these
agencies, no information could be provided. This was often
because the agencies were not certain as to what would be a
Subtitle D related activity or how they would attempt to separate
out such activities in their overall budget. It should also be
noted that dollars directed towards municipal wastewater surface
impoundments are not technically Subtitle D funds but may have
been included in the amounts reported by the States. Those
34
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facilities were included in the survey, but are not included in
this report.
In general, water agency expenditures were somewhat
larger on the average ($631,389 per State/Territory), than were
solid waste agency expenditures ($427,184 per State/Territory).
This indicates further that the above estimate is indeed an
underestimate as no budget information was provided for 13 water
agencies.
In addition to the 39 agencies having unknown budgets,
an underestimate was also likely to result because not all
agencies were likely to have been listed in the first place as
described in Section 4.1. One State noted that budget did not
include county expenditures, although the counties in that State
may have spent more on Subtitle D than did the State.
4.3 Sources of Funding for Subtitle D Activities
Each State was asked to provide the percentage of its
total Subtitle D budget for fiscal years 1984 and 1985 that came
from State, federal, license or user fees, and other funding
sources. Study estimates on sources of Subtitle D funding are
presented in Table 4.1.
State funding sources were said to account for 84.6
percent of all Subtitle D funding in fiscal year 1984 and 85.1
percent in fiscal year 1985. Federal funding sources were said
to account for only 7.5 percent of all Subtitle D funding in
FY 1984 and only 7.1 percent in FY 1985; federal funding sources
were almost exclusively for the funding of water programs.
License or user fees programs were reported in nine States during
35
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Table 4.1. Sources of Subtitle D funding
Funding Source
Fiscal year
ending in
1984
Fiscal year
ending in
1985
State sources
84.6%
85.1%
Federal sources
7.5%
7.1%
License or user fees
3.5%
6.0%
Other
4.4%
1.9%
TOTAL
100%
100%
36
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FY 1984 (3.5% of funding) and ten States during FY 1985 (6.0% of
funding).
Nebraska indicated that 42 percent of its Subtitle D
funds came from a license or user fees program both in FY 1984
and FY 1985. Other States reporting funding from licenses or
user fees in FY 1984 were New Jersey (20%), Arkansas (16%),
Wisconsin (15%), Minnesota (5%), Alabama (5%), Oregon (3%),
Colorado (3%), and New Hampshire (1%). Significant increases in
the percentage of Subtitle D funding from license or user fees
were reported from FY 1984 to FY 1985 in New Jersey (FY84 - 20%;
FY 85 - 33%), Oregon (FY84 - 3%; FY85 - 21%), and Wisconsin (FY84
- 15%; FY85 - 22%). The State of Louisiana reported that a
license or user fee program would be initiated in FY 1985 that
would account for approximately 18 percent of its total funding
for Subtitle D activities.
District funding sources in Idaho and an Environmental
License Plate Fund in California were reported as "other" sources
of funding, accounting for 4.4 percent of all Subtitle D funding
in the U.S. in FY 1984 and 1.9 percent in FY 1985. A significant
decrease in the percentage of Subtitle D funding was anticipated
in the State of California from FY 1984 to FY 1985 from the
Environmental License Plate Fund (from 17% in FY 1984 to only 7%
in FY 1985).
4-4 Total Hours Expended on Subtitle D Activities
Each State and Territory was asked to estimate the
total number of person hours each agency expended on work
directly related to Subtitle D establishments, issues, and
activities during the fiscal year ending in 1984. Estimates of
hours expended were reported for 103 of the 141 agencies
37
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identified by States/Territories as being involved in Subtitle D
activities.
A total of 1,814,439 hours were reported to have been
expended in fiscal year 1984 by the 103 agencies for Subtitle D
related activities. This total may be a large underestimate for
the same reasons cited in Section 4.1 and Section 4.2 (e.g., not
all agencies were listed, not all agencies provided information,
etc.)
4.5 Types of Subtitle D Activities Engaged In
Each State and Territory was asked to estimate the
percent of total hours that were expended in a variety of
Subtitle D preceded activity categories. Estimates of time spent
on these activities are presented in Table 4.2.
The two types of activities most frequently engaged in
were surveillance and enforcement and permitting and licensing.
These two activities together accounted for almost 70 percent of
all hours expended on Subtitle D activities. Technical
assistance activities ranked third, with about 9 percent of the
total number of hours expended.
4.6 Importance Rankings for Subtitle D Activities
As an indication of additional needs, each State and
Territory was asked to rank the same preceded activity categories
described in Section 4.5 (Table 4.2) with respect to those
activities that would most improve Subtitle D program
effectiveness, assuming additional resources were available.
Separate activity rankings were requested for landfills, land
application units, and surface impoundments. Study data are
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Table 4.2. Percentage of Hours Engaged in Subtitle D Activities
Subtitle D activity
Number of states
% of Hours reporting
1. Surveillance and enforcement
41.1%
46
2. Permitting and licensing
27.8%
46
3. Technical assistance
9.1%
46
4. Planning
5.8%
42
5. Regulation development
4.5%
40
6. Training given
2.8%
30
7. Research
1.5%
16
39
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provided in Table 4.3. The activities in this table are listed
in order of overall importance across all three Subtitle D
facility types. The rankings of categories for each type of
Subtitle D facility appear in the last three columns.
Surveillance and enforcement activities were ranked
highest overall, and for each of the three landfill types. Thus,
the States and Territories perceive that Subtitle D program
effectiveness would be improved most by further expanding the
activity that is now most frequently engaged in — surveillance
and enforcement.
Program effectiveness rankings differ somewhat between
facility types. Planning is seen as more important and
regulation development is seen as less important for landfills
than for other facility types. Whereas, regulation development
is seen as a higher priority need for surface impoundments than
for landfills and land application units.
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Table 4.3. Importance Rankings for Subtitle D Activities
Overall
Ranking
1
2
3
4
5
6
7
Land
Subtitle D Landfills Application
Activity Ranking Ranking
Surveillance and
enforcement 1 1
Technical assistance 2 3
Permitting or
licensing 3 2
Regulation development 5 4
Training given 6 5
Planning 4 6
Research 7 7
Surface
Impoundment
Ranking
1
2
4
3
5
6
7
41
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PART III
NUMBER AND CHARACTERISTICS OF
SUBTITLE D WASTE FACILITIES
Section 5. Landfills
Section 6. Land Application Units
Section 7. Surface Impoundments
43
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PART III
NUMBER AND CHARACTERISTICS OF
SUBTITLE D WASTE FACILITIES
Part III provides estimates of the number and
characteristics of Subtitle D landfills, land application units,
and surface impoundments in Sections 5, 6, and 7, respectively.
A parallel structure has been used to present data in each of
these sections. Each section begins with the definition of
facility types. Estimates are then presented with respect to the
total number of Subtitle D facilities within each facility type.
To properly interpret estimates provided in Sections 5, 6, and 7,
the reader is advised to review Part I, Section 2, "Survey
Methodology" and Part I, Section 3, "Statistical Reliability," as
well as the footnotes presented at the bottom of each figure and
table. For some facility types, no estimates of total numbers
were available for specific States and Territories. These gaps
must be taken into consideration when reviewing estimates of
totals for the entire United States.
Following the presentation of estimates of total
numbers of facilities by type, each section then contains
information regarding the States or Territories that account for
a large proportion of all facilities within each facility type.
Distributions of facilities on the bases of ownership, acreage,
amount of waste, monitoring systems, and design and operational
controls are then provided.
The 55 States or Territories in this survey reported a
total of 227,127 Subtitle D facilities. Respondents were also
asked to report the number of establishments that received
Subtitle D wastes. An "establishment" is a single physical
45
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location where business is conducted or where services or
industrial operations are performed by a municipality,
corporation, or other public or private entity. An establishment
may have one or more landfills, land applications units, and/or
surface impoundments (i.e., one or more facilities).
Approximately 120,000 establishments were reported by 46 of the
States/Territories. The remaining nine States/Territories did
not know how many establishments there were. An additional
32,941 establishments were reported (by 46 States/Territories)
that had only closed or inactive Subtitle D facilities in 1984.
46
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5. LANDFILLS
The following estimates are provided in this section:
o An estimate of the total number of Subtitle D
landfills in the United States;
o Estimates of the total number of Subtitle D
landfills by type;
o Estimates of the total number of Subtitle D
landfills by State and EPA region;
o Distributions of the total number of Subtitle D
landfills by ownership, acreage, amount of waste,
monitoring systems, and design and operational
controls; and.
o Landfill capacity problems.
The reader is advised to review the definitions of facility types
provided below as well as Section 5.1, "Assessment of Data
Quality" when attempting to interpret the estimates provided in
this Section.
Definitions;
SUBTITLE D LANDFILL - A part of an establishment at which
waste is placed in or on land and which is not a land
application unit, a surface impoundment, an injection
well, or compost pile.
MUNICIPAL WASTE SUBTITLE D LANDFILL - A landfill that
primarily receives household refuse and commercial
waste. It may also receive a limited amount of
other types of Subtitle D wastes, such as
municipal sewage sludge and industrial wastes.
INDUSTRIAL WASTE SUBTITLE D LANDFILL - A landfill that
primarily receives waste from factories,
processing plants, and other manufacturing
activities.
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DEMOLITION DEBRIS SUBTITLE D LANDFILL - A landfill that
receives only construction or demolition debris
(e.g., debris from the construction of or
demolition of bridges, highways, or buildings),
brush, stumps, and rubble.
OTHER SUBTITLE D LANDFILL - A landfill receiving
Subtitle D wastes that does not fall into any of
the above categories (e.g., a landfill that
receives only municipal sewage sludge).
5.1 Assessment of Data Quality
The estimated numbers of active Subtitle D landfills in
1984 that are presented below do not include the following:
o Estimates of industrial waste landfills in
Massachusetts or Montana; or
o Estimates of the total number of demolition debris
landfills in Ohio.
Overall, the quality of the data regarding municipal
waste landfills appears to be good. Industrial waste estimates
were more difficult to provide by the States/Territories for a
number of reasons: some States do not have permitting
requirements for industrial waste landfills if the waste is
generated on-site and disposed of on-site; record-keeping and
monitoring systems suffer from a lack of staff or manpower, etc.
In general, the estimate of industrial waste landfills is likely
to be an underestimate to an unknown degree. Demolition debris
landfill estimates are likely to fall somewhere between the high
quality of the municipal waste landfill estimates and the lower
quality of the industrial waste estimates.
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5.2 Estimated Number of Active Subtitle D Landfills in 1984
The total estimated number of active Subtitle D
landfills in 1984 produced as a result of this study is 16,416
(55 States/Territories reporting). A breakdown of the total
number of landfills by type is presented in Figure 5.1. The
number of establishments that had at least one landfill is 15,719
(52 States/Territories reporting).
There were an estimated 9,284 active municipal waste
landfills in 1984, accounting for 56.6 percent of the total.
There were an estimated 3,511 industrial waste landfills,
representing 21.4 percent of the total. There were an estimated
2,591 demolition debris landfills, representing 15.8 percent of
the total. There were also 1,030 landfills reported as "other",
accounting for 6.3 percent of the total number of active
Subtitle D landfills in 1984. The "other" category was made up
of 838 open dumps and 192 miscellaneous landfills (yard trash,
junk cars, animal carcasses, and water treatment sludges).
5.3 Estimated Number of Landfills by State and EPA Region
The total estimated number of active Subtitle D
landfills in 1984 for each State and Territory is shown in the
map presented in Figure 5.2. West Virginia (1,209) has the
highest number of reported Subtitle D landfills, followed by
Pennsylvania (1,204), Texas (1,201), Wisconsin (1,033), Alabama
(800), Alaska (740), and California (720). The total number of
landfills in the State of West Virginia includes 550 "open dumps"
included in the "other" category.
Figure 5.3 presents the five States that account for
the largest percentage of the total number of landfills in each
49
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10000T
9000-
8000-
7000--
6000--
5000--
4000--
3000--
2000-
1000--
Flgura 5.1
NUMBER OF SUBTITLE D LANDFILLS BY TYPE
Total Estimated Number of Subtitle D Landfills = 16,416*
9284
3511
2591
1030
Municipal Waste Industrial Waste* Demolition Debris* Other Types
* No estimates of industrial waste landfills were obtained for Massachusetts or Montana;
and no estimates of demolition debris landfills were obtained for Ohio.
"50
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Figure 5.3
PERCENTAGE ACCOUNTED FOR BY THE FIVE STATES WITH THE LARGEST
NUMBER OF LANDFILLS BY TYPE
100T
90-
80-
70-
60-
0
0.
58%
b(J-
4U
in •
°o •
1 A .
I U
34%
CA4%
NY 4%
LA 6%
WI 10%
TX 10%
TX4%
AL5%
AK8%
WV10%
PA 30%
51%
SD6%
UT8%
CA8%
KS 10%
AL 19%
Municipal Waste
Industrial Waste
Demolition Debris
52
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landfill type. Texas (949), Wisconsin (916), Louisiana (520),
New York (399), and California (382) account for a total of 34
percent of all municipal waste landfills. Pennsylvania (1,062),
alone, accounts for 30 percent of all industrial waste landfills,
while West Virginia (358), Alaska (268), Alabama (176), and Texas
(157) account for an additional 28 percent of all industrial
waste landfills. Alabama (500), Kansas (267), California (200) ,
Utah (200), and South Dakota (150) account for 51 percent of all
demolition debris landfills.
The total estimated number of Subtitle D landfills by
EPA Region is presented in Figure 5.4. EPA Region III (2,790)
contains the largest number of landfills, followed by Region IV
and Region VI.
5.4 Basic Characteristics of Subtitle D Landfills
5.4.1 Ownership
Ownership was reported for 15,578 (95%) of the 16,416
Subtitle D landfills as shown in Table 5.1. Ownership could not
be determined for 838 landfills. It should be noted that
ownership is often difficult to determine because of leasing/
contractual arrangements. In total, local governments own
approximately 54 percent of all Subtitle D landfills. Private
owners account for 40.5 percent, while federal (4.0%) and State
governments (1.7%) account for only a small portion of the total.
Federal ownership was reported primarily when land owned by the
federal government (e.g., Bureau of Land Management) was leased
for the operation of a landfill. The "other" ownership category
included only 10 landfills or 0.1 percent of the total.
53
-------
Figure 5.4
NUMBER OF SUBTITLE D LANDFILLS BY EPA REGION
un
-------
Table 5.1. Number of Subtitle D landfills by ownership category
On
Ul
Landfill type
Municipal
waste
Industrial
waste
Demolition
debris only
Other
TOTAL
Number and
Owned by
Response State
rate government
96% 126
d-4%)
97% 17
(0.5%)
91% 33
(1.4%)
93% 89
(9.3%)
95% 265
(1.7%)
percent of active individual Subtitle D landfills
Owned by
local
governments
6,908
(77.9%)
74
(2.2%)
1,190
(50.5%)
203
(21.3%)
8,375
(53.8%)
Owned by
Federal
government
348
(3.9%)
126
(3.7%)
82
(3.5%)
60
(6.3%)
616
(4.0%)
Privately
owned
1,482
(16.7%)
3,177
(93.6%)
'1,050
(44.6%)
603
(63.1%)
6,312
(40.5%)
Other
8
(0.1%)
2
(0.1%)
0
0
10
(0.1%)
TOTAL
8,872
(100%)
3,396
(100%)
2,355
(100%)
955
(100%)
15,578
(100%)
Note: Percentages may not sum to 100 percent due to independent rounding.
-------
Local governments owned the majority of municipal waste
landfills (77.9%), although a total of 1,482 municipal waste
landfills (16.7%) were reported to be privately owned. The next
majority (94%) of all industrial waste landfills were reported to
be privately owned. Demolition debris landfills were split
somewhat equally between local government owners (50.5%) and
private owners (44.6%). The majority of landfills in the "other"
category were said to be privately owned (63.1%).
5.4.2 Acreage
Acreage was reported for 13,143 (80%) of the 16,416
Subtitle D landfills as shown in Table 5.2. Acreage categories
could not be determined for 3,273 landfills. In total, 7,284
landfills (55.4%) were reported to be less than 10 acres; 5,273
landfills (40.1%) were reported to be between 10 and 100 acres;
586 landfills (4.5%) were reported to be over 100 acres.
Industrial waste landfills were generally smaller than municipal
waste and demolition debris landfills. The vast majority (92.1%)
of the landfills in the "other" category were reported to be less
than 10 acres.
5.4.3 Amount of Waste
Amount of waste was reported for 13,818 (84%) of the
16,416 Subtitle D landfills as shown in Table 5.3. The amount of
waste category could not be determined for 2,598 landfills. In
total, 9,996 landfills (72.3%) were said to have received less
than 30,000 cubic yards of waste; 3,253 landfills (23.5%) were
said to have received between 30,000 and 600,000 cubic yards of
waste; 569 landfills (4.1%) were said to have received more than
600,000 cubic yards of waste. Industrial waste and demolition
56
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Table 5.2. Number of Subtitle D landfills by acreage category
Number and percent of active
individual Subtitle D landfills with:
Response
Landfill type rate
Municipal 75%
waste
Industrial 88%
waste
Demolition 84%
debris only
Other 88%
TOTAL ' 80%
Less than
10 acres
2,944
(42.3%)
2,182
(70.7%)
1,327
(60.6%)
831
(92.1%)
7,284
(55.4%)
10-100
acres
3,572
(51.3%)
834
(27.0%)
797
(36.4%)
70
(7.8%)
5,273
(40.1%)
More than
100 acres
449
(6.4%)
72
(2.3%)
64
(2.9%)
1
(1.1%)
586
(4.5%)
TOTAL
6,965
(100%)
3,088
(100%)
2,188
(100%)
902
(100%)
13,143
(100%)
Note: Percentages may not sum to 100 percent due to independent rounding.
57
-------
Table 5.3. Number of Subtitle D landfills by amount of waste
Number and percent of active individual Subtitle D
landfills by amount of waste received in 1984:
Landfill type
Municipal
waste
Industrial
waste
Demolition
debris only
Other
TOTAL
Received less than
30,000 cubic yards
Response in 1984 (30 tons
rate per day)
85% 5,309
(67.0%)
82% 2,289
(79.4%)
83% 1,608
(74.7%)
83% 790
(92.7%)
84% 9,996
(72.3%)
Received
30,000-600,000
cubic yards in
1984 (30-500
tons per day)
2,211
(27.9%)
523
(18.1%)
468
(21.7%)
51
(6.0%)
3,253
(23.5%)
Received more than
600,000 cubic yards
in 1984 (500 tons
per day)
408
(5.1%)
72
(2.5%)
78
(3.6%)
11
(1.3%)
569
(4.1%)
TOTAL
7,928
(100%)
2,884
(100%)
2,154
(100%)
852
(100%)
13,818
(100%)
Note: Percentages may not sum to 100 percent due to independent rounding.
-------
debris landfills generally received somewhat less waste than
municipal waste landfills. The vast majority (92.7%) of the
landfills in the "other" category were reported to have received
less than 30,000 cubic yards of waste in 1984.
5.4.4. Landfill Monitoring Systems
The number of Subtitle D landfills that had
groundwater, surface water, air emissions, and methane monitoring
systems is presented in Table 5.4. The percentages given in this
table represent the total number of landfills having a monitoring
system divided by the total number of landfills reported above
(e.g., 2,160 municipal landfills were reported to have
groundwater monitoring systems out of a total of 9,284 municipal
landfills. Thus, 25.1 percent of all municipal landfills are
estimated to have groundwater monitoring systems).
In total, approximately 19 percent of all Subtitle D
landfills had groundwater monitoring systems, about 9 percent had
surface water monitoring systems, and about 3 percent had air
emissions and methane monitoring systems. Demolition debris
landfills, as expected because of the types of waste which they
contain, generally have many fewer monitoring systems than do
municipal and industrial waste landfills.
5.4.5 Landfill Design and Operational Controls
The number of Subtitle D landfills that had various
design and operational controls is presented in Table 5.5. Only
119 landfills or 0.7 percent of all Subtitle D landfills were
known to have synthetic liners in 1984. Approximately 11 percent
were known to have natural liners. Approximately 39 percent of
59
-------
Table 5.A. Number of Subtitle D landfills having monitoring systems
Number and percent of active individual
Subtitle D landfills that had:
Landfill type
Municipal waste
Industrial waste
Demolition debris only
Other
TOTAL
Groundwater
monitoring
2,331
(25.1%)
626
(17.8%)
135
(5.2%)
42
(4.1%)
3,134
(19.1%)
Surface
water
monitoring
1,100
(11.8%)
230
(6.6%)
69
(2.7%)
16
(1.6%)
1,415
(8.6%)
Air
emissions
monitoring
348
(3.7%)
80
(2.3%)
7
(0.3%)
0
445
(2.7%)
Methane
monitoring
427
(4.6%)
63
(1.8%)
8
(0.3%)
0
498
(3.0%)
-------
Table 5.5. Number of Subtitle D landfills having design and operational controls
Number and percent of active individual
Subtitle D landfills:
Design or
operational control
Synthetic liners
Natural liners (e.g., clay),
including slurry walls
Natural renovation (i.e.,
leachate attenuation)
Leachate collection systems
Leachate treatment (except
leachate recirculation)
Leachate recirculation
Run-on/run-off controls
Methane controls (vents,
recovery)
Restrictions on receipt of
liquid waste (e.g., bulk
Municipal
waste
71
(0.8%)
1,353
(14.6%)
3,627
(39.1%)
481
(5.2%)
245
(2.6%)
205
(2.2%)
4,240
(45.7%)
1,539
(16.6%)
4,436
(47.8%)
Industrial
waste
45
(1.3%)
392
(11.2%)
657
(18.7%)
112
(3.2%)
69
(2.0%)
27
(0.8%)
1,150
(32.8%)
98
(2.8%)
1,200
(34.2%)
Demolition
debris only
1
«.!%)
117
(4.5%)
541
(20.9%)
3
(0.1%)
1
«.!%)
0
685
(26.4%)
107
(4.1%)
818
(31.6%)
Other
2
(0.2%)
5
(0.5%)
52
(5.0%)
6
(0.6%)
2
(0.2%)
0
78
(7.6%)
3
(0.3%)
128
(12.4%)
TOTAL
119
(0.7%)
1,867
(11.4%)
4,877
(29.7%)
602
(3.7%)
317
(1.9%)
232
(1.4%)
6,153
(37.5%)
1,747
(10.6%)
6,582
(40.1%)
liquid restrictions)
-------
municipal waste landfills and 30 percent of all Subtitle D
landfills were known to have natural renovation or leachate
attenuation in 1984. Only very small percentages of landfills
were said to have leachate collection, leachate treatment, and
leachate recirculation systems. The most frequently reported
design and operational controls were restrictions on receipt of
liquid wastes and run-on/run-off controls. Methane controls
(vents, recovery) were known to exist in approximately 11 percent
of all Subtitle D landfills in 1984.
5.4.6 Landfill Capacity Problems
Each respondent was asked to describe any local,
regional, or Statewide landfill capacity problems that existed in
their State or Territory. This question was asked in a somewhat
different way during the pretest of the questionnaire. In the
pretest, respondents were asked to provide an estimate of the
landfill capacity in their State. This was difficult to provide
and the question was rewritten as an open-ended question. Based
on telephone conversations with the respondents, many perceived
the question as pertaining to municipal landfills only. The
actual responses received from the States are listed in
Appendix A.
In general, many States reported that some landfills in
their jurisdictions were either reaching capacity, at capacity,
or beyond capacity at the present time. A few States and
Territories reported that they had no landfill capacity problems.
A majority of the responses mentioned that there were
difficulties in siting new landfills. Some States described
public opposition to the siting of new landfills as a significant
obstacle. Some States reported that finding suitable land on
62
-------
which to place the landfill was also a severe roadblock to the
siting of new landfill facilities. Tougher permitting
requirements and rising costs were mentioned as a difficulty in
siting new landfills. Difficulties in developing alternatives to
landfills because of the time, cost and technology involved were
also mentioned.
In general, a landfill capacity problem was reported to
exist within certain regions of many States and Territories. New
sites for landfills were said to be difficult to obtain, highly
opposed by the public, and costly. Some States said that
incinerators and resource recovery plants represent promising
future alternatives to landfills, but not viable alternatives for
solving immediate capacity problems.
63
-------
6. LAND APPLICATION UNITS
The following estimates are provided in this section:
o An estimate of the total number of Subtitle D land
application units in the United States;
o Estimates of the total number of Subtitle D land
application units by type;
o Estimates of the total number of Subtitle D land
application units by State and EPA region; and
o Distributions of the total number of Subtitle D
land application units by ownership, acreage,
amount of waste, monitoring systems, and design
and operational controls.
The reader is advised to review the definitions of facility types
provided below as well as Section 6.1, "Assessment of Data
Quality" when attempting to interpret the estimates provided in
this section.
Definitions:
SUBTITLE D LAND APPLICATION UNIT - A part of an
establishment at which waste is applied onto or
incorporated into the soil surface for the purpose of
beneficial use or waste treatment and disposal. Land
application is often referred to as landfarming or
landspreading. Specifically excluded from this
definition are manure spreading operations.
MUNICIPAL SEWAGE SLUDGE SUBTITLE D LAND APPLICATION
UNIT - A land application unit that primarily
receives sewage sludge from publicly-owned or
privately-owned domestic sewage treatment
facilities, including sludge from domestic septic
tanks. (Note: do not include municipal
wastewater land application units in this category
- these are not included in the scope of this
survey.)
65
-------
HIGH APPLICATION RATE UNITS - Municipal sewage
sludge land application units where the
application rate exceeds the nutrient needs
of crops, for reclamation of disturbed lands,
waste treatment or disposal.
LOW APPLICATION RATE UNITS - Municipal sewage
sludge land application units where the
application rate is based on crop nutrient
needs.
INDUSTRIAL WASTE LAND APPLICATION UNIT - A land
application unit that primarily receives waste
(including sludge or wastewater) from factories,
processing plants, and other manufacturing or
commercial activities.
OIL OR GAS LAND APPLICATION UNIT - A land application
unit that receives waste, such as drilling muds,
generated by oil or gas exploration and extraction
operations.
OTHER LAND APPLICATION UNIT - A land application unit
receiving Subtitle D wastes that does not fall
into any of the above categories (e.g., a drinking
water treatment waste land application unit).
6.1 Assessment of Data Quality
The estimated numbers of active Subtitle D land
application units in 1984 that are presented below do not include
the following:
o Estimates of the total number of municipal sewage
sludge LAU's in Illinois, Louisiana, Missouri,
Utah, or West Virginia;
o Estimates of industrial waste LAU's in Illinois,
Louisiana, Missouri, or Montana; or
o Estimates of oil or gas waste LAU's in Illinois,
Missouri, or Montana.
66
-------
Respondent ratings of the quality of data and land application
unit total numbers were frequently in the fair, poor, or very
poor range.
6.2 Estimated Number of Active Subtitle D Land Application
Units in 1984
The total estimated number of active Subtitle D land
application units (LAU's) in 1984 produced as a result of this
study is 18,889 (51 States/Territories reporting). A breakdown
of the total number of LAU's by type is presented in Figure 6.1.
The number of establishments that had at least one land
application unit is 12,312 (47 States/Territories reporting).
There were an estimated 11,937 municipal sewage sludge
LAU's, accounting for 63.2 percent of all LAU's reported. Only
242 municipal sewage sludge LAU's were said to have high
application rates exceeding the nutrient needs of crops. The
vast majority of these sludges were applied for the reclamation
of disturbed lands. There were an estimated 5,605 active
industrial waste LAU's in 1984, representing 29.7 percent of all
LAU's reported. A relatively small number of oil or gas waste
LAU's (726; 3.8% of the total) and "other" LAU's (621; 3.3% of
the total) were also reported. The "other" category contains 451
animal waste and 170 water treatment sludge LAU's.
6.3 Estimated Number of Land Application Units by State and
EPA Region
The total estimated number of active Subtitle D land
application units in 1984 for each State and Territory is shown
on the map presented in Figure 6.2. Wisconsin (4,181) has the
67
-------
Figure 6.1
NUMBER OF SUBTITLE D APPLICATION UNITS BY TYPE
Total Estimated Number of Subtitle D Land Application Units = 18,889*
15000--
14000--
13000--
12000--
11000--
10000--
9000-"
8000--
7000-•
6000-•
5000- -
4000-•
3000-•
2000--
1000--
0--
11937
5605
726
621
Municipal Sewage Sludge* Industrial Waste* Oil or Gas Waste* Other Misc. Types
* No estimates of municipal sewage sludge land application units obtained for Illinois,
Louisiana, Missouri, or West Virginia; no estimates of industrial waste land application
units obtained for ll_ LA, MO, or MT; no estimates of oil or gas waste land application
units obtained for ll_ MO, or MT.
63
-------
Figure 6.2
NUMBER OF LAND APPLICATION UNITS BY STATE/TERRITORY
Y7/////A No Data
en '
AMERICAN SAMOA 0
GUAM 3
NORTH MARIANAS 1
PUERTO RICO NO DATA
VIRGIN ISLANDS NO DATA
-------
highest number of reported Subtitle D LAU's, followed by Michigan
(2,501), Pennsylvania (2,400), Indiana (1,300), and Minnesota
(850).
Figure 6.3 presents the five States that account for
the largest percentage of the total number of LAU's within each
LAU type. Pennsylvania (2,229), Michigan (1,601), Indiana
(1,042), Wisconsin (940), and Minnesota (800) account for 55
percent of all municipal sewage sludge LAU's. The majority of
industrial waste LAU's are found in Wisconsin (3,241), accounting
for 58 percent of the total, while Michigan (900), Indiana (225),
North Carolina (215), and Maryland (125) account for another 26
percent. The majority of oil or gas waste LAU's are found in
Nebraska, accounting for 59 percent of the total, while
California (100) and Texas (75) account for another 24 percent.
The total estimated number of Subtitle D land
application units is presented by EPA Region in Figure 6.4.
Almost half (9,344) of all LAU's were reported to be in EPA
Region V, followed by Region III (3,456) and Region VII (1,687).
6.4 Basic Characteristics of Subtitle D Land Application
Units
6.4.1 Ownership
Ownership was reported for 18,782 (99%) of the 18,889
land application units as shown in Table 6.1. The vast majority
of all types of LAU's are privately owned. Local governments own
approximately 13 percent of all total municipal sewage sludge
LAU's.
70
-------
100T
Figure 6.3
PERCENTAGE ACCOUNTED FOR BY THE FIVE STATES WITH THE LARGEST
NUMBER OF UNO APPLICATION UNITS BY TYPE
90--
80-•
70--
60--
c
o 50--
o
a.
40--
30--
20--
10--
55%
MN7%
WI8%
IN 9%
MI 13%
PA 19%
84%
IN, &
NC, &
MD 10%
MI 16%
WI58%
83%*
TX 10%
CA 14%
NE 59%
Municipal Sewage Sludge Industrial Waste
Oil or Gas Waste
71
-------
Figure 6.4
NUMBER OF SUBTITLE D LAND APPLICATION UNITS BY EPA REGION
-------
Table 6.1. Number of Subtitle D land application units by ownership category
u>
Number and percent of active individual Subtitle
land application units
Land application Response
unit type rate
Municipal sewage 98%
sludge at high
application rate*
Municipal sewage 99%
sludge at low
application rate*
Total municipal 99%
sewage sludge*
Industrial waste 99%
Oil or gas waste 100%
Other 100%
TOTAL 99%
Owned by
State
government
2
(0.8%)
72
(0.7%)
104
(0.9%)
1
(0.1%)
1
(0.1%)
10
(1.6%)
116
(0.3%)
Owned by
local
governments
48
(20.3%)
1,028
(10.6%)
1,524
(12.9%)
18
(0.3%)
6
(0.8%)
26
(4.2%)
1,574
(8.4%)
Owned by
Federal
government
0
17
(0.2%)
72
(0.6%)
13
(0.2%)
16
(2.2%)
9
(1.4%)
110
(0.6%)
Privately
owned
187
(78.9%)
8,570
(88.5%)
10,145
(85.6%)
5,558
(99.4%)
703
(96.8%)
576
(92.8%)
16,982
(90.4%)
D
Other TOTAL
0 237
(100%)
0 9,687
(100%)
0 11,845
(100%)
0 5,590
(100%)
0 726
(100%)
0 621
(100%)
0 18,782
(100%)
*High rate application and low rate application do not equal the total municipal sewage sludge figures because
some states do not distinquish between high and low application rates.
Note: Percentages may not sum to 100 percent due to independent rounding.
-------
6.4.2 Acreage
Acreage was reported for 15,576 (82%) of the 18,889
land application units as shown in Table 6.2. In total, there
were 2,347 LAU's of 100 acres or more; 3,301 LAU's of 50-99
acres; 6,448 LAU's of 10-49 acres; and 3,480 LAU's of less than
10 acres. Oil or gas waste LAU's were generally small, while
LAU's classified as "other" were generally large.
6.4.3 Amount of Waste
Amount of waste was reported for 12,020 (63%) of the
18,889 land application units as shown in Table 6.3. The
majority of the LAU's (70.0%) received less than 50 tons of waste
(dry weight) in 1984, although a high percentage of oil or gas
waste LAU's (79.8%) received 100-999 tons of waste. Over 90
percent of industrial waste LAU's received less than 50 tons of
waste in 1984.
6.4.4 Land Application Unit Monitoring Systems
The number of Subtitle D land application units that
had groundwater, surface water, air, and soil monitoring systems
is presented in Table 6.4. The percentages given in this table
represent the total number of land application units having a
monitoring system divided by the total number of land application
units reported above (e.g., 43 high application rate municipal
sewage sludge LAU's were reported to have groundwater monitoring
systems out of a total of 242 high application municipal sewage
sludge LAU's. Thus, 17.8 percent of all high rate LAU's are
estimated to have groundwater monitoring systems).
74
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Table 6.2. Number of Subtitle D land application units by acreage category
Ul
Number and percent of active individual
Subtitle D land application units with:
Land application
unit type
Municipal sewage
sludge at high
application rate
Municipal sewage
sludge at low
application rate
Total municipal
sewage sludge*
Industrial waste
Oil or gas waste
Other
TOTAL
Response Less than
rate 10 acres
98% 96
(40.7%)
78% 1,503
(19.6%)
82% 2,077
(21.2%)
96% 681
(15.4%)
100% 568
(78.2%)
100% 154
(24.8%)
82% 3,480
(22.3%)
10 - 49
acres
57
(24.2%)
3,339
(43.6%)
4,567
(46.5%)
1,805
(40.9%)
69
(9.5%)
7
(1.1%)
6,448
(41.4%)
50 - 99
acres
64
(27.1%)
1,476
(19.3%)
1,789
(18.2%)
1,462
(33.1%)
44
(6.1%)
6
(1.0%)
3,301
(21.1%)
100 acres
or more
19
(8.0%)
1,336
(17.5%)
1,378
(14.0%)
470
(10.6%)
45
(6.2%)
454
(73.1%)
2,347
(15.1%)
TOTAL
236
(100%)
7,654
(100%)
9,811
(100%)
4,418
(100%)
726
(100%)
621
(100%)
15,576
(100%)
TOTAL
ACREAGE
5,370
210,154
262,184
152,869
9,078
68,703
492,834
*High rate application and low rate application do not equal the total municipal sewage sludge figures
because some states do not distinquish between high and low application rates.
Note: Percentages may not sum to 100 percent due to independent rounding. The response rate for the total
acreage question was somewhat lower than for the rest of the questions and may be an underestimate.
-------
Table 6.3. Number of Subtitle D land application units by amount of waste
CT>
Number of active individual Subtitle D land application units
by amount of waste received in 1984:
Land application Response
unit type rate
Municipal sewage 32%
sludge at high
application rate
Municipal sewage 52%
sludge at low
application rate
Total municipal 57%
,sewage sludge*
Industrial waste 81%
Oil or gas waste 76%
Other 100%
TOTAL 64%
Received
less than 50
tons per year
(dry weight)
20
(26.0%)
2,727
(53.9%)
4,276
(63.3%)
3,740
(91.3%)
81
(14.7%)
319
(51.4%)
8,416
(70.0%)
Received
50 - 99
tons per year
(dry weight)
24
(31.2%)
958
(18.9%)
1,043
(15.4%)
174
(4.2%)
22
(4.0%)
151
(24.3%)
1,390
(11.6%)
Received
100 - 999
tons per year
(dry weight)
5
(6.5%)
1,050
(20.8%)
1,080
(16.0%)
151
(3.7%)
439
(79.8%)
151
(24.3%)
1,821
(15.1%)
Received
1,000 or more
tons per year
(dry weight)
28
(36.4%)
321
(6.3%)
355
(5.3%)
30
(0.7%)
8
(1.5%)
0
393
(3.3%)
TOTAL
77
(100%)
5,056
(100%)
6,754
(100%)
4,095
(100%)
550
(100%)
621
(100%)
12,020
(100%)
*High rate application and low rate application do not equal the total municipal sludge figures because some states
do not distinguish between high and low application rates.
Note: Percentages may not sum to 100 percent due to indeoendent roundinp
-------
Table 6.4. Number of Subtitle D land application units having monitoring systems
Number and percent of active individual Subtitle D
land application units that had:
Land application unit type
Municipal sewage sludge at high
application rate
Municipal sewage sludge at low
application rate
Total municipal sewage sludge*
Industrial waste
Oil or gas waste
Other
TOTAL
Groundwater
monitoring
A3
(17.8%)
170
(1.7%)
337
(2.8%)
592
(10.6%)
247
(34.0%)
3
(0.5%)
1,179
(6.2%)
Surface water
monitoring
16
(6.6%)
74
(0.8%)
265
(2.2%)
137
(2.4%)
230
(31.7%)
0
632
(3.3%)
Air
monitoring
0
0
100
(0.8%)
31
(0.6%)
37
(5.1%)
0
168
(0.9%)
Soil
monitoring
206
(85.1%)
4,517
(46.2%)
4,804
(40.2%)
204
(3.6%)
42
(5.8%)
3
(0.5%)
5,053
(26.8%)
"High rate application and low rate application may not equal the total municipal sewage sludge
figures because some states do not distinguish between high and low rate land application units.
-------
In total, about 27 percent of all land application
units had soil monitoring; approximately 46 percent of the
municipal sewage sludge at low application rate had soil
monitoring, while only about 4 percent of the industrial waste
LAU's and 6 percent of the oil or gas waste LAU's had soil
monitoring. Groundwater monitoring systems were reported for
only 6.2 percent of the total number of LAU's, however; more than
10 percent of the industrial waste LAU'S and 34 percent of the
oil or gas waste LAU's had groundwater monitoring. Approximately
32 percent of the oil or gas waste LAU's also had surface water
monitoring, while in total, surface water monitoring was reported
for only 3.3 percent of all LAU's. Air monitoring was reported
for less than 1 percent of all LAU's.
6.4.5 Land Application Unit Design and Operational Controls
The number of Subtitle D land application units that
had various design and operational controls is presented in Table
6.5. In total, 75 percent of all LAU's were reported to have
waste application rate limits, although this was true for only
about 13 percent of the oil or gas waste LAU's. Approximately 60
percent of all LAU's were reported to have restrictions on the
growing of food chain crops, while this was true for only about
43 percent of the industrial LAU's and about 3 percent of the oil
or gas waste LAU's. Slightly more than 50 percent of all LAU's
were reported to have run-on/run-off controls, although about 78
percent of the oil or gas waste LAU's and about 69 percent of the
industrial waste LAU's had such controls. About 54 percent of
all LAU's had waste restrictions or a ban on certain Subtitle D
waste types, with about 65 percent of the industrial LAU's and
only about 17 percent of the oil or gas waste LAU's having such
restrictions.
-------
Table 6.5. Number of Subtitle D land application units having design and operational controls
Number and percent of active individual Subtitle D land
application units having release prevention methods
•
Management method
Run-on/run-off controls
Waste restrictions (ban
on certain Subtitle D
waste types)
Waste application rate
limits
Restrictions on the
. growing of food chain
crops
Municipal
sewage
sludge at
high appli-
cation rate
59
(24.4%)
185
(76.4%)
195
(80.6%)
198
(81.8%)
Municipal
sewage
sludge at
low appli-
cation rate
4,090
(41.8%)
5,698
(58.3%)
8,164
(83.5%)
7,672
(78.5%)
Total
municipal
sewage
sludge*
5,075
(42.5%
5,932
(49.7%)
9,437
(79.1%)
8,401
(70.4%)
Industrial
waste
3,837
(68.5%)
3,633
(64.8%)
4,085
(72.9%)
2,395
(42.7%)
Oil or gas
waste
569
(78.4%)
122
(16.8%)
93
(12.8%)
23
(3.2%)
Other
164
(26.4%)
554
(89.2%)
475
(76.5%)
576
(92.8%)
TOTAL
9,645
(51.1%)
10,241
(54.2%)
14,090
(74.6%)
11,395
(60.3%)
*High rate application and low rate application may not equal the total municipal sewage sludge figures because some states
do not distinguish between high and low application rate land application units.
-------
7. SURFACE IMPOUNDMENTS
The following estimates are provided in this section:
o An estimate of the total number of Subtitle D
surface impoundments in the United States;
o Estimates of the total number of Subtitle D
surface impoundments by type;
o Estimates of the total numbers of Subtitle D
surface impoundments by State and EPA region; and
o Distributions of the total number of Subtitle D
surface impoundments by ownership, acreage, amount
of waste, monitoring systems, and design and
operational controls.
The reader is advised to review the definitions of facility types
provided below as well as Section 7.1, "Assessment of Data
Quality" when attempting to interpret the estimates provided in
this section. Although not Subtitle D facilities, questions on
municipal wastewater surface impoundments were included in this
study to avoid sending a separate study concerning these
facilities. The total number of municipal wastewater surface
impoundments, which are regulated under the Clean Water Act, is
presented in Section 7.2, but are not included elsewhere.
Definitions;
SURFACE IMPOUNDMENT - A part of an establishment which is a
natural topographic depression, man-made excavation, or
diked area formed primarily of earthen materials
(although it may be lined with man-made materials) that
is designed to hold an accumulation of liquid wastes or
wastes containing free liquids. Treatment, storage,
and disposal surface impoundments are included.
Surface impoundments are often referred to as pits,
ponds, or lagoons. This definition does not include
any type of tank, including concrete, fiberglass or
steel tanks.
81
-------
MUNICIPAL WASTEWATER SURFACE IMPOUNDMENT - A publicly
owned surface impoundment, commonly known as a
sewage lagoon or sewage pond, designed to provide
partial or total treatment for domestic sewage or
a mixture of domestic and industrial wastewater.
MUNICIPAL SEWAGE SLUDGE SURFACE IMPOUNDMENT - A surface
impoundment that receives sewage sludge from
publicly-owned or privately-owned domestic sewage
treatment establishments, including septic tanks.
MUNICIPAL RUN-OFF SURFACE IMPOUNDMENT - A surface
impoundment that is used for the collection of
run-off or leachate from municipal waste landfills
or municipal waste land application units.
INDUSTRIAL WASTE SURFACE IMPOUNDMENT - A surface
impoundment that primarily receives wastes from
factories, processing plants (including food
processing), and other manufacturing or commercial
activities. Also included in this category are
surface impoundments used for the collection of
run-off or leachate from industrial or demolition
landfills and industrial land application units.
AGRICULTURAL WASTE SURFACE IMPOUNDMENT - A surface
impoundment that only receives waste from
agricultural operations, including farming, crop
production, and animal husbandry (including
feedlots). Specifically excluded from this
category are surface impoundments that are used
for wastes from slaughter houses, other animal
processing, and food processing, which are
included in the "industrial" category.
MINING WASTE SURFACE IMPOUNDMENT - A surface
impoundment associated with mineral extraction and
beneficiation activities such as crushing,
screening, washing, floatation, etc. These
minerals include metallic and non-metallic ores,
coal, sand and gravel, but exclude oil and gas.
Specifically excluded are impoundments used for
processing wastes from manufacturing
establishments which are included in the
"industrial" category.
OIL OR GAS WASTE SURFACE IMPOUNDMENT - A surface
impoundment that receives waste from oil or gas
exploration and extraction, commonly known as
brine pits. Both disposal and emergency brine
82
-------
pits are included. Specifically excluded are
impoundments used for petroleum refinery wastes,
which are included in the "industrial" category.
OTHER SURFACE IMPOUNDMENT - A surface impoundment
receiving Subtitle D wastes that does not fall
into any of the above categories (e.g., a drinking
water treatment waste impoundment).
7.1 Assessment of Data Quality
The estimated numbers of active Subtitle D surface
impoundments in 1984 that are presented below do not include
estimated totals for a large number of States/Territories. Nine
States and Territories did not provide any estimates of numbers
of surface impoundments (CA, KY, MN, MO, UT, VT, WY, Puerto Rico,
and Virgin Islands). One State (SD) provided an estimate of the
total number, but could not break down the estimate into
categories. The number of surface impoundments may be an
underestimate for an additional reason. Some States did not
include facilities that did not require permits. Texas, among
other States, did not include temporary surface impoundments
located next to drilling rigs receiving oil or gas waste. In
addition, the States listed below could not provide estimates of
impoundments in the categories given:
o municipal sewage sludge - IL, LA, RI;
o municipal run-off - IL, LA, RI;
o industrial waste - LA;
o agricultural waste - LA, NY;
o mining waste - NY; and
o oil or gas waste - IN, MT, NY, and RI.
83
-------
7.2 Estimated Number of Active Subtitle D Surface
Impoundments in 1984
The total estimated number of active Subtitle D surface
impoundments in 1984 produced as a result of this study is
191,822 (46 States/Territories reporting). A breakdown of the
total number of surface impoundments by type is presented in
Figure 7.1. The number of establishments that had at least one
surface impoundment is 108,383 (40 States/Territories reporting).
An estimated 125,074 active oil or gas waste surface
impoundments in 1984 were reported. Oil or gas waste surface
impoundments accounted for 59.0 percent of the total number of
impoundments reported. The next largest category which had a
significantly smaller number of impoundments than oil or gas
waste was mining waste, with 19,813 impoundments. Agricultural
waste (17,159), industrial waste (16,232) and other miscellaneous
impoundments (11,118) were also reported in relatively large
numbers. Less than 2,000 municipal sewage sludge impoundments
and less than 500 municipal run-off impoundments were reported.
The "other" category of surface impoundments includes 5,366
miscellaneous impoundments, 4,600 single family lagoons, 692
water treatment sludge impoundments, 50 stormwater run-off
impoundments, and 20 fish hatcheries.
An estimated 20,199 municipal wastewater surface
impoundments were reported. In general, the characteristics of
these facilities differed somewhat from those of the Subtitle D
facilities described in this report and will be presented in a
separate report.
84
-------
Figure 7.1
NUMBER OF SUBTITLE D SURFACE IMPOUNDMENTS BY TYPE
Total Estimated Number of Subtitle D Surface Impoundments = 191,822*
126)000
125000
124POO
124000
122000
125,074
20POO
19000
18000
17000
16000
14,000
13,000
12,000
1 1,000
iqooo
gpoo
spoo
7;000
6)000
spoo
4/500'
2POO'
1000'
o-
19,813
17159
16232
11,118
1,938
438
Oil/Gas Waste Agricul. Waste Other Misc. Municipal Runoff
Mining Waste . Indust. Waste Municipal Sewage Sludge
85
-------
7.3 Estimated Number of Surface Impoundments by State and
EPA Region
The total estimated number of active Subtitle D surface
impoundments in 1984 for each State and Territory is shown on the
map presented in Figure 7.2. Pennsylvania (32,653) reported the
largest number of surface impoundments, followed by Arkansas
(25,705), Louisiana (20,010), West Virginia (18,705), and New
Mexico (17,044).
Figure 7.3 presents the five States that account for
the largest percentage of the total number of surface
impoundments of a given impoundment type. Pennsylvania (5,600,
West Virginia (5,000), Alabama (2,500), Tennessee (1,317), and
New Mexico (858) account for 77 percent of all mining waste
surface impoundments. Wisconsin (3,090, Kansas (1,729), Alabama
(1,200), Nebraska (1,157), and Mississippi (1,050) account for 48
percent of all agricultural waste impoundments. Ohio (1,697) and
Pennsylvania (1,645) account for 21 percent of all industrial
waste impoundments.
Arizona (25,000), Louisiana (20,000), Pennslyvania
(19,702), New Mexico (15,761), and West Virginia (13,000) account
for 75 percent of all oil or gas waste surface impoundments.
Estimates of total numbers of oil or gas waste impoundments are
provided for each State/Territory on the map in Figure 7.4. As
shown on this map there is great variation between States in
terms of estimated numbers of oil or gas waste impoundments.
Twenty-one States and Territories reported having no oil or gas
waste impoundments, while twelve States reported having over
1,000 oil or gas waste impoundments.
The total estimated number of Subtitle D surface
impoundments by EPA Region is presented in Figure 7.5. EPA
86
-------
Figure 7 . 2
NUMBER OF SUBTITLE D SURFACE IMPOUNDMENTS BY STATE/TERRITORY
Y//////A No Data
XI
OH
IL \ IN \7227
5157 U191
AMERICAN SAMOA 0
GUAM 0
NORTH MARIANAS 1
PUERTO RICO NO DATA
VIRGIN ISLANDS NO DATA
-------
Percent
o
•H-
K)
O
in
O
O>
O
O
00
o
(O
o
o
o
c
3
ol
Q_
in
M
#
c >
r o
O) O
m o
oo
oo
4
O.
I
o.
o
a
"
>
M
§
f
00
I
z
w
it*
"5
#
m to
la
r*~
a
10
•o
>•
to
to
r
I-*
CO
•z,
S
-4
#
m
r
S
M
CO
O
m
53-
-------
Figure 7 . 4
NUMBER OF SUBTITLE D OIL AND GAS WASTE SURFACE IMPOUNDMENTS BY STATE/TERRITORY
Y7/////A No Data
00
AMERICAN SAMOA 0
GUAM 0
NORTH MARIANAS 0
PUERTO RICO NO DATA
VIRGIN ISLANDS NO DATA
-------
Figure 7.5
NUMBER OF SUBTITLE D SURFACE IMPOUNDMENTS BY EPA REGION
-------
Region VI (77,752) contains the largest number of surface
impoundments, followed by Region III, Region IV, and Region V, in
that order.
7.4 Basic Characteristics of Subtitle D Surface
Impoundments
7.4.1 Ownership
Ownership was reported for 149,711 (78%) of the 191,822
surface impoundments as shown in Table 7.1. The vast majority
(98.2%) of surface impoundments are privately owned, although
local governments own, as might be expected, the majority of
municipal sewage sludge and municipal run-off surface
impoundments.
7.4.2 Acreage
Acreage was reported for 123,412 (64%) of the 191,822
surface impoundments as shown in Table 7.2. In total, 90 percent
of the surface impoundments were reported to be less than one
acre. Ninety-eight percent of the oil or gas waste impoundments
were reported to be less than one acre, while over 30 percent of
mining impoundments were reported to be six acres or larger.
7.4.3 Amount of Waste
Amount of waste was reported for 124,038 (65%) of the
191,822 surface impoundments, as shown in Table 7.3. In total,
•
approximately 82 percent of the surface impoundments were
91
-------
Table 7.1. Number of Subtitle D surface impoundments by ownership category
Number and percent of active individual
Subtitle D surface impoundments
Surface
impoundment
type
Municipal
sewage sludge
Municipal
run- off
Industrial
waste
Agricultural
waste
Mining waste
Oil or gas
waste
Other
TOTAL
Owned by
Response State
rate government
95% 19
(1.0%)
100% 0
66% 94
(0.9%)
92% 25
(0.2%)
69% 0
69% 0
48% 20
(0.4%)
7-8-% 158
(0.1%)
Owned by
local
governments
1,327
(72.4%)
368
(75.4%)
71
(0.7%)
0
5
(0.04%)
0
663
(12.4%)
2,434
(1.6%)
Owned by
Federal
government
42
(2.3%)
5
(1.0%)
74
(0.7%)
3
(0.02%)
0
0
11
(0.2%)
135
(0.1%)
Privately
owned
446
(24.3%)
115
(23.6%)
10,519
(97.8%)
15,733
(99.8%)
13,625
(99.96%)
101,884
(100%)
4,662
(87.0%)
146,984
(98.2%)
TOTAL
1,834
(100%)
448
(100%)
10,758
(100%)
15,761
(100%)
13,630
(100%)
101,884
(100%)
5,356
(100%)
149,711
(100%)
-------
Table 7.2. Number of Subtitle D surface impoundments by acreage category
Number and percent of active individual Subtitle D
surface impoundments with:
Surface
impoundment
type
Municipal
sewage sludge
Municipal
run-off
Industrial
waste
Agricultural
waste
Mining waste
Oil or gas
waste
Other
TOTAL
Response
rate
68%
71%
40%
69%
33%
73%
47%
64%
<0.1 acre
138
(11.1%)
43
(12.4%)
705
(10.8%)
560
(4.7%)
320
(5.0%)
36,575
(39.9%)
4,833
(91.7%)
43,174
(35.0%)
0.1-0.4
acres
524
(42.0%)
123
(35.5%)
1,627
(24.8%)
5,843
(49.5%)
439
(6.9%)
48,318
(42.7%)
241
(4.6%)
57,115
(46.3%)
0.5-0.9
acres
405
(32.5%)
92
(26.6%)
2,205
(33.6%)
2,445
(20.7%)
927
(14.4%)
5,316
(5.8%)
137
(2.6%)
11,527
(9.3%)
1-5
acres
155
(12.4%)
67
(19.4%)
1,113
(17.0%)
2,791
(23.6%)
2,679
(41.6%)
1,244
(1.4%)
42
(0.8%)
8,091
(6.6%)
6-10
acres
16
(1.3%)
16
(4.6%)
458
(7.0%)
68
(0.6%)
1,801
(28.0%)
237
(0.3%)
15
(0.3%)
2,611
(2.1%)
11-100
acres
4
(0.3%)
5
(1.4%)
380
(5.8%)
102
(0.9%)
257
(4.0%)
27
(0.03%)
2
(0.04%)
111
(0.6%)
>100 acres
5
(0.4%)
0
70
(1.1%)
0
17
(0.3%)
25
(0.03%)
0
117
(0.1%)
TOTAL
1,247
(100%)
346
(100%)
6,558
(100%)
11,809
(100%)
6,440
(100%)
91,742
(100%)
5,270
(100%)
123,412
(100%)
-------
Table 7.3. Number of Subtitle D surface impoundments by amount of waste
i-D '
Number and percent of active individual Subtitle D surface impoundments
by amount of waste received per day (in 1,000's of gallons):
Surface
impoundment
type
Municipal
sewage sludge
Municipal
run -off
Industrial
waste
Agricultural
waste
Mining waste""
Oil or gas
waste
Other
TOTAL
Response <50
rate gal/day
79% 1,392
(95.7%)
58% 215
(75.7%)
40% 2,998
(46.1%)
70% 11,074
(92.9%)
31% 2,372
(39.2%)
74% 79,096
(85.3%)
46% 5,013
(97.8%)
65% 102,160
(82.4%)
50-99
gal/day
50
(3.4%)
58
(20.4%)
1,202
(18.5%)
831
(7.0%)
619
(10.2%)
266
(0.3%)
71
(1.4%)
3,097
(2.5%)
100-499
gal/day
14
d-0%)
0
935
(14.4%)
21
(0.2%)
1,136
(18.8%)
13,316
(14.4%)
36
(0.7%)
15,458
(12.5%)
500-999
gal/day
2
(0.2%)
3
(1.1%)
817
(12.6%)
0
630
(10.4%)
0
5
(0.1%)
1,457
(1.2%)
1,000-9,999
gal/day
0
8
(2.8%)
470
(7.2%)
0
946
(15.6%)
0
7
(0.1%)
1,431
(1.2%)
>10,000
gal/day
0
0
85
(1.3%)
0
350
(5.8%)
0
0
435
(0.4%)
TOTAL
1,455
(100%)
284
(100%)
6,507
(100%)
11,926
(100%)
6,053
(100%)
92,678
(100%)
5,125
(100%)
124,038
(100%)
Note: Percentages may not sum to 100 percent due to rounding.
-------
reported to receive less than 50,000 gallons per day, while
13 percent were reported to receive between 100,000 and 499,999
gallons per day. A total of 435 surface impoundments (Oil/gas -
350 and Industrial - 85) were reported to receive 10,000,000 or
more gallons per day.
7.4.4 Surface Impoundment Monitoring Systems
The number of Subtitle D surface impoundments that had
groundwater, surface water, and air emissions monitoring systems
in 1984 are presented in Table 7.4. The percentages given in
this table represent the -total number of surface impoundments
having a monitoring system divided by the total number of surface
impoundments reported above (e.g., 1,396 industrial waste surface
impoundments were reported to have groundwater monitoring systems
out of a total of 16,232 industrial waste surface impoundments.
Thus, 8.6 percent of the industrial waste surface impoundments
are estimated to have groundwater monitoring systems).
Approximately 17 percent of all Subtitle D surface
impoundments had surface water monitoring systems, about
4 percent had groundwater monitoring systems, and less than
1 percent had air emissions monitoring systems.
7.4.5 Surface Impoundment Design and Operational Controls
The numbers of Subtitle D surface impoundments that had
various design and operational controls are presented in
Table 7.5. Only 2.1 percent of all surface impoundments had
synthetic liners; about 27 percent had natural liners. Leak
detection systems were reported for about 1 percent of all
surface impoundments; discharge permits were reported for 31
95
-------
percent; overtopping controls for about 25 percent; and waste
restrictions for about 27 percent.
96
-------
Table 7.4. Number of Subtitle D surface impoundments having monitoring
systems
Surface impoundment type
Muncipal sewage sludge
Municipal run-off
Industrial waste
Agricultural waste
Mining waste
Oil or gas waste
Other
TOTAL
Groundwater
monitoring
131
(6.8%)
192
(39.3%)
1,396
(8.6%)
44
(0.3%)
5,399
(27.2%)
165
(0.1%)
7
(0.1%)
7,334
(3.8%)
Surface
water
monitoring
50
(2.6%)
57
(11.7%)
3,151
(19.4%)
135
(0.8%)
8,679
(43.8%)
20,030
(16.0%)
133
(1.2%)
32,235
(16.8%)
Air
emissions
monitoring
10
(0.5%)
0
73
(0.4%)
1
(<0.1%)
15
(0.1%)
25
(<0.1/0
0
124
(0.1%)
97
-------
Table 7.5. Number of Subtitle D surface impoundments having design and operational controls
CO
Management method
Synthetic liners
Natural liners
(e.g., clay)
Leak detection systems
Overtopping controls
Waste restrictions (ban on
certain Subtitle D waste
types)
Discharge permit
Municipal
sewage
sludge
76
(3.9%)
508
(26.2%)
32
(1.7%)
589
(30.4%)
634
(32.7%)
522
(26.9%)
Municipal
run-off
23
(4.7%)
140
(28.7%)
37
(7.6%)
269
(55.1%)
71
(14.5%)
16
(3.3%)
Indus-
trial
waste
756
(4.7%)
2,818
(17.4%)
896
(5.5%)
3,672
(22.6%)
2,685
(16.5%)
4,738
(29.2%)
Agricul-
tural
waste
60
(0.3%)
9,299
(54.2%)
26
(0.2%)
6,713
(39.1%)
8,371
(48.8%)
2,018
(11.8%)
Mining
waste
200
(1.0%)
868
(4.4%)
335
(1.7%)
4,144
(20.9%)
4,358
(22.0%)
4,970
(25.1%)
Oil
or gas
waste
2,950
(2.4%)
33,768
(27.0%)
1,406
(1.1%)
28,541
(22.8%)
30,509
(24.4%)
46,491
(37.2%)
Other
6
(0.1%)
4,835
(43.5%)
0
4,733
(42.6%)
4,736
(42.6%)
171
(1.5%)
TOTAL
4,071
(2.1%)
52,236
(27.2%)
2,732
(1.4%)
48,661
(25.4%)
51,364
(26.8%)
58,926
(30.7%)
-------
PART IV
STATE SUBTITLE D REGULATORY PROGRAMS
Section 8. Landfills
Section 9. Land Application Units
Section 10. Surface Impoundments
99
-------
PART IV
STATE SUBTITLE D REGULATORY PROGRAMS
Part IV provides data on State/Territorial regulatory
programs for Subtitle D landfills, land application units, and
surface impoundments in Sections 8, 9, and 10, respectively. A
parallel structure has been used to present data in each of these
sections. Each section begins with data regarding regulations
for Subtitle D requirements. Licensing/permitting requirements
and enforcement programs are then described in that order within
each section.
To properly interpret estimates provided in Sections 8,
9, and 10, the reader is advised to review Part I, Section 2,
"Survey Methodology", Part I, Section 3, "Statistical
Reliability", and the definitions of facility types presented in
the introductions to Sections 5, 6, and 7.
In addition to the above, each State and Territory was
also asked to submit copies of its regulations to EPA. An EPA
contractor (PEI) was then asked to review and submit a separate
report on these regulations.
'101
-------
8. LANDFILLS
The following estimates are provided in this section:
o number of States/Territories that have regulations
pertaining to specific Subtitle D landfill
requirements;
o number of States/Territories that have landfill
permitting and licensing requirements;
o number of individual Subtitle D landfills that
have permits and licenses;
o frequency of inspection of Subtitle D landfills;
o number of inspections of Subtitle D landfills in
1984;and
o number of violations of Subtitle D landfills in
1984.
8.1 Subtitle D Landfill Regulations
As part of this study all States and Territories were
asked to review a list of Subtitle D requirements and indicate
whether or not each of these requirements was: specifically
included in State/Territory regulations; enforced under general
standards and policies; or not enforceable under any
State/Territory regulations, standards, or policies. Data from
all responding States and Territories are reported in Table 8.1.
Most requirements were more likely to be enforced under
general standards and policies rather than specifically included
in current Subtitle D programs. .
103
-------
Table 8.1
SUBTITLE D LANDFILL REGULATIONS
Number of states with requirements included
in current State Subtitle D program
a.
b.
c.
d.
e.
f.
g-
h.
i.
j-
k.
1.
m.
n.
0.
P-
q-
r.
s.
t.
u.
V.
w.
X.
y-
z.
aa.
bb.
cc.
dd.
ee.
Natural (e.g., clay) liners
Synthetic liners
Location standards (e.g.,
floodplains)
Leachate collection and
removal
Leachate characterization/
analysis
Leachate treatment
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air protection standard
Air emissions monitoring
Methane monitoring
Methane controls
Corrective action for off-
site methane migration
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Run-off collection
and removal
Run-off characterization/
analysis
Run-off treatment
Run-on controls
Restrictions on receipt
of liquid waste
Restrictions on types
of Subtitle D wastes
received
Daily cover
Endangered species criteria
Disease vectors criteria
Safety criteria:
Bird hazards
Safety criteria:
Uncontrolled access
Closure standards
(e.g., caps)
Postclosure monitoring
Financial responsibility
Municipal waste
Specifically
included
in the
regulations
14
10
37
19
9
15
30
37
21
25
4
15
27
17
35
15
18
20
8
6
26
25
33
50
25
39
31
41
39
29
20
Enforced
under
general
standards
and
policies
29
23
12
22
30
22
16
12
22
18
26
3
15
18
15
31
27
25
28
27
19
18
13
2
13
10
13
8
13
13
11
No en-
forceable
require-
ments
11
19
3
11
13
15
6
3
9
9
21
14
10
17
2
6
7
7
16
19
7
9
6
0
14
3
8
3
0
10
20
Industrial waste
Specifically
included
in the
regulations
12
8
34
15
8
14
27
32
17
22
5
14
22
14
33
14
15
19
7
6
25
22
31
41
23
34
26
40
37
28
19
Enforced
under
general
standards
and
policies
27
24
13
24
29
23
18
14
25
21
24
20
15
19
15
30
28
23
28
26
19
20
12
8
15
10
16
9
11
14
10
iNo en-
forceable
require-
ments
10
17
3
11
13
13
5
3
8
7
21
16
13
17
2
6
7
8
15
18
6
8
7
1
13
5
8
4
2
8
21
(continued)
104
-------
Table 8.1 (Cont.)
SUBTITLE D LANDFILL REGULATIONS
a.
b.
c.
d.
e .
f.
g-
h.
i .
j-
k.
1.
m.
n .
a .
P-
q.
r .
s.
t.
u.
V.
w.
X.
y-
z.
aa.
bb.
cc.
dd.
ee.
Natural (e.g., clay) liners
Synthetic liners
Location standards (e.g.,
floodplains)
Leachate collection and
removal
Leachate characterization/
analysis
Leachate treatment
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air protection standard
Air emissions monitoring
Methane monitoring
Methane controls
Corrective action for off-
site methane migration
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Run-off collection
and removal
Run-off characterization/
analysis
Run-off treatment
Run-on controls
Restrictions on receipt
of liquid waste
Restrictions on types
of Subtitle D wastes
received
Daily cover
Endangered species criteria
Disease vectors criteria
Safety criteria:
Bird hazards
Safety criteria:
Uncontrolled access
Closure standards
(e.g., caps)
Postclosure monitoring
Financial responsibility
Number of
requirements
included in current State
Demolition debris only
Specifically
included
in the
regulations
5
3
28
10
4
7
23
21
14
22
4
11
16
11
26
10
13
14
4
3
18
21
27
30
19
33
24
32
30
20
14
Enforced
under
general
standards
and
policies
25
20
15
18
23
22
14
18
21
18
22
17
15
16
17
28
27
24
26
24
21
22
18
13
13
8
15
10
15
14
11
No en-
forceable
require-
ments
19
26
7
21
21
20
12
10
14
10
23
21
19
23
6
11
10
12
20
23
10
6
5
6
17
8
11
8
5
15
24
Subtitle D
proqram
Other
Specifically
included
in the
regulations
5
3
13
6
4
7
12
13
6
7
1
7
11
7
14
5
6
8
5
3
12
9
13
12
10
16
13
15
15
13
9
Enforced
under
general
standards
and
policies
10
6
4
8
8
6
5
5
8
7
7
6
4
4
5
13
10
8
8
10
4
9
4
7
4
3
3
4
5
4
5
No en-
forceable
require-
ments
6
12
4
7
9
a
4
3
7
7
13
8
6
10
2
3
5
5
8
8
5
3
4
2
7
2
5
2
1
4
7
105
-------
Those requirements most often included specifically in
State/Territory regulations, in descending order were:
o Daily cover;
o Safety: uncontrolled access
o Closure standards;
o Disease vectors criteria;
o Groundwater monitoring; and
o Surface water protection standards.
These requirements were the most frequently named as being
sp e c i f ic a11y included in State/Territory regulations for all four
landfill types.
Those requirements for which States/Territories were
the least likely to have any regulations were:
o Air emissions;
o Financial responsibility;
o Run-off treatment;
o Synthetic liners;
o Corrective action for off-site methane migration;
and
o Run-off characterization/analysis.
Once again, this was true, in general, for all four landfill
types.
106
-------
8.2 Landfill Permitting/Licensing Requirements
The number of States/Territories requiring landfill
permits/plan approval and landfill licenses/registrations are
provided in Table 8.2. For municipal waste landfills, New Mexico
does not require a permit or approved plan, but does, however,
require each municipal waste landfill to obtain a license to
operate. Three States do not require permits for industrial
waste landfills: New Mexico (which requires neither permitting
nor licensing for industrial waste landfills), Hawaii (where no
industrial landfills exist), and Montana (where "on-site
industrial and commercial waste disposal is excluded from permit
requirements under most conditions"). Five States and the Virgin
Islands do not require permits for demolition debris landfills.
The five States are Florida, New Mexico, Ohio, Nebraska, and
Utah.
The number of Subtitle D landfills that have permits
and licenses are presented in Table 8.3. The number of permitted
landfills provided in this table are significantly smaller than
the total number of Subtitle D landfills reported in Section 5.
This is due to the fact that some States/Territories require
permits for some, but not all types of landfills within a
specific category. As examples, in the State of Florida on-site
disposal of on-site generated industrial waste is exempt from
permit requirements, and in the State of Nebraska no license,
plan, or approval is needed for landfill sites operated by or
under contract to municipalities of less than 5,000 population.
8.3 State Enforcement Programs for Subtitle D Landfills
The frequency with which Subtitle D landfills are
inspected by States/Territories is presented in Table 8.4. About
107
-------
Table 8.2. Subtitle D permitting/licensing requirements: Landfills
Landfill type
Number of states with:
Permit or
plan approval
required
Yes No
License or
registration
required
Yes No
Municipal waste
53 1
11 42
Industrial waste
50 3
8 44
Demolition debris only
47 6
8 44
Other
16 4
3 16
108
-------
Table 8.3. Number of Subtitle D landfills with permits and licenses
Have permits Are licenced
Landfill type or approved plans or registered
Municipal waste 5,444 2,206
Industrial waste 1,392 319
Demolition debris only 1,377 150
Other 209 11
TOTAL 8,422 2,686
109
-------
Table 8.4. Frequency of inspection of Subtitle D landfills
Response Rate
Never inspected
Less than once
every two years
Once every
two years
Once a year
Twice a year
Four times
a year
More than four
times a year
Other
TOTAL
Municipal
waste
90%
431
(5.1%)
347
(4.1%)
776
(9.3%)
2,609
(31.1%)
1,272
(15.2%)
1,548
(18.5%)
1,279
(15.3%)
122
(1.5%)
8,384
(100%)
Industrial
waste
94%
157
(4.8%)
376
(11.4%)
87
(2.6%)
512
(15.3%)
482
(14.6%)
416
(12.6%)
1,243
(37.7%)
24
(0.7%)
3,297
(100%)
Demolition
debris
92%
212
(9.2%)
202
(8.8%)
308
(13.4%)
580
(25.2%)
733
(31.9%)
142
(6.2%)
93
(4.0%)
30
(1.3%)
2,300
(100%)
Other
98%
64
(6.4%)
10
(1.0%)
301
(30.0%)
513
(51.0%)
100
(9.9%)
15
(1.5%)
3
(0.2%)
0
1,006
(100%)
TOTAL
91%
864
(5.8%)
935
(6.2%)
1,472
(9.8%)
4,214
(28.1%)
2,587
(17.3%)
2,121
(14.2%)
2,618
(17.5%)
176
(1.2%)
14,987
(100%)
110
-------
22 percent of all Subtitle D landfills are inspected once every
two years or less and about 6 percent of all Subtitle D landfills
are never inspected, according to study respondents. The total
number of landfill inspections for compliance with Subtitle D
regulations made during 1984 is provided in Table 8.5. Estimates
in Table 8.5 represent the total number of inspections made,
rather than the number of landfills inspected (e.g., ten
inspections may have been made of the same landfill).
The total number and types of violations that were
found in 1984 landfill inspections is presented in Table 8.6.
These numbers are a reflection of the following:
o the number of inspections conducted by
States/Territories in 1984;
o the types of violations for which the 1984
inspections were made; and
o the availability of monitoring systems at the
landfills, as described in Section 5.4.4.
Ill
-------
Table 8.5. Number of inspections of Subtitle D
landfills in 1984
Landfill type
Number of
inspections
during 1984
Municipal waste
24,865
Industrial waste
4,354
Demolition debris only
2,834
Other
799
TOTAL
32,852
112
-------
Table 8.6. Number of Subtitle D landfills by type of violation in 1984
Number and percent of active individual Subtitle D
landfills in violation in 1984:
Violation type
Groundwater contamination
Groundwater monitoring
program deficiencies
Surface water contamination
Air contamination
Methane control deficiencies
Operational deficiencies
(e.g., daily cover violation,
or blowing litter) and other
minor violations
Other
Municipal
waste.
586
(6.3%)
834
(9.0%)
660
(7.1%)
845
(9.1%)
180
d-9%)
4,784
(51.5%)
222
(2.4%)
Industrial
waste
111
(3.2%)
117
(3.3%)
50
d-4%)
18
(0.5%)
8
(0.2%)
433
(12.3%)
13
(0.4%)
Demolition
debris only
16
(0.6%)
82
(3.2%)
42
(1.6%)
33
(1.3%)
0
531
(20.4%)
7
(0.3%)
Other
7
(0.7%)
108
(10.5%)
6
(0.6%)
54
(5.2%)
1
(0.1%)
225
(21.8%)
0
TOTAL
720
(4.4%)
1,141
(7.0%)
758
(4.6%)
950
(5.8%)
189
(1-2%)
5,973
(36.4%)
242
(1-5%)
-------
-------
9. LAND APPLICATION UNITS
The following estimates are provided in this section:
o number of States/Territories that have regulations
pertaining to specific Subtitle D land application
unit requirements;
o number of States/Territories that have land
application unit permitting and licensing
requirements;
o number of individual Subtitle D land application
units that have permits and licenses;
o frequency of inspection of Subtitle D land
application units;
o number of inspections of Subtitle D land
application units in 1984;and
o number of violations of Subtitle D land
application units in 1984.
9.1 Subtitle D Land Application Unit Regulations
As part of this study all States and Territories were
asked to review a list of Subtitle D requirements and indicate
whether each of these requirements was: specifically included in
State/Territory regulations; enforced under general standards and
policies; or not enforceable under any State/Territory
regulations, standards, or policies. Data from all responding
States and Territories are summarized in Table 9.1.
As with Subtitle D landfill regulations, the
requirements for land application units we're more likely to be
enforced under general standards and policies than specifically
included in current Subtitle D programs.
115
-------
Table 9.1
SUBTITLE D LAND APPLICATION UNIT REGULATIONS
Number of states with requirements included
in current State Subtitle D program
a.
b.
c.
d.
e.
f.
g-
h.
i.
j-
k.
1.
m.
n.
a .
P-
q-
r.
s.
t.
u.
V .
w.
X.
y-
Location standards (e.g.,
floodplains
Waste application limits
Restrictions on growing
food chain crops
Restrictions on types of
Subtitle D wastes received
Sludge quality criteria
Waste disinfection prior
to application
Soil monitoring
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air emission monitoring
Air protection standards
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contaminat'' i
Run-off collection
and removal
Run-off characterization/
analysis
Run-off treatment
Run-on controls
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
Postclosure monitoring
Financial responsibility
Municipal
sewage sludge at
high application rate
Specifically
included
in the
regulations
14
11
18
14
12
12
9
20
13
4
0
7
20
9
4
7
5
5
10
6
12
17
8
7
7
Enforced
under
general
standards
and
policies
24
25
18
23
25
20
26
17
24
29
23
20
18
26
31
27
28
27
26
16
17
21
24
23
14
No en-
fo rceab le
require-
ments
2
4
4
3
3
8
5
2
3
_
7
16
12
2
5
5
6
7
8
4
18
8
2
8
10
19
Municipal
sewage sludge at
low application rate
Specifically
inc luded
in the
regulations
23
23
27
21
22
20
16
26
15
8
3
8
28
12
10
10
8
7
13
5
15
21
10
9
8
Enforced
under
general
standards
and
policies
24
23
17
25
24
22
29
20
27
34
21
21
19
30
35
29
30
33
29
21
22
24
27
25
15
No en-
forceable
require-
ments
2
3
5
3
3
7
4
2
7
7
24
19
2
7
3
9
11
9
7
22
12
4
12
15
26
(continued)
116
-------
Table 9.1 (Cont.)
SUBTITLE D LAND APPLICATION UNIT REGULATIONS
a.
b.
c.
d.
e.
f.
g-
h.
i .
j.
k.
1.
m.
n .
0.
p.
q.
r .
s.
t.
u.
V.
w.
X.
y-
Location standards (e.g.,
floodplains)
Waste application limits
Restrictions on growing
food chain crops
Restrictions on types of
Subtitle D wastes received
Sludge quality criteria
Waste disinfection prior
to application
Soil monitoring
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air emission monitoring
Air protection standards
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Run-off collection
and removal
Run-off characterization/
analysis
Run-off treatment
Run-on controls
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
Postclosure monitoring
Financial responsibility
Number of
in current
Industrial waste
Specifically
included
in the
regulations
16
15
15
15
12
11
13
22
14
6
4
10
24
11
9
13
6
5
10
5
13
18
10
9
7
Enforced
under
general
standards
and
policies
27
29
25
26
31
27
30
22
28
35
24
21
20
32
33
27
31
34
32
20
19
23
27
27
20
states with requirements included
State Subtitle D program
No en-
forceable
require-
ments
4
3
7
6
4
9
4
3
5
6
18
15
3
4
5
7
10
8
5
22
14
6
10
11
20
Oil
Specifically
included
in the
regulations
5
4
4
4
3
3
3
13
5
4
1
3
14
4
6
7
3
5
5
2
3
6
3
2
3
or gas waste
Enforced
under
general
standards
and
policies
22
23
19
23
23
20
23
17
23
24
14
13
14
24
22
20
23
22
23
10
13
15
20
18
15
No en-
forceable
require-
ments
6
6
10
6
7
11
a
4
' 6
6
18
17
5
5
5
7
a
7
5
22
17
11
10
13
15
(continued)
117
-------
Table 9.1 (Cont.)
SUBTITLE D LAND APPLICATION UNIT REGULATIONS
Number of states with requirements
included in current State Subtitle D
program
a.
b.
c.
d.
e.
f.
g-
h.
i.
j.
k.
1.
m.
n.
o.
P-
q.
r.
s.
t.
u.
V.
w.
X.
y-
Location standards (e.g.,
floodplains
Waste application limits
Restrictions on growing
food chain crops
Restrictions on types of
Subtitle D wastes received
Sludge quality criteria
Waste disinfection prior
to application
Soil monitoring
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air emission monitoring
Air protection standards
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Run-off collection
and removal
Run-off characterization/
analysis
Run-off treatment
Run-on controls
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
Postclosure monitoring
Financial responsibility
Other
Specifically
included
in the
regulations
2
2
2
2
1
2
2
2
1
0
0
1
4
1
1
2
1
2
1
1
1
2
1
1
1
Enforced
cnder
general
standards
and
policies
6
6
5
6
1
6
5
6
7
8
6
5
4
7
7
6
7
6
7
3
6
5
6
6
6
No en-
forceable
require-
ments
0
0
1
0
0
0
1
0
0
0
2
2
D
0
0
0
0
0
0
4
1
1
1
1
1
118
-------
Those requirements most often included specifically in
State/Territory regulations, in descending order were:
o Surface water protection;
o Ground water protection;
o Location standards;
o Waste application limits; and
o Restrictions on type of Subtitle D wastes
received.
For low application rates municipal sewage sludge land
application units, restrictions on the growing of food chain
crops was also frequently included in specific State/Territory
regulations.
In general, high application rate municipal sewage
sludge and oil or gas land application units were much less
likely to have any given requirement specifically included in
regulations than were high application rate municipal sewage
sludge and industrial land application units.
Those requirements for which States/Territories were
the least likely to have any regulations were:
o Endangered species criteria;
o Financial responsibility;
o Air emissions;
o Air protection standards; and
o Post closure monitoring.
119
-------
9.2 Land Application Unit Permitting/Licensing Requirements
The number of States and Territories that do and do not
require permits/approved plans and licenses/registration for land
application units is presented in Table 9.2. Responses with
respect to the number of States and Territories that do not
require permits is a reflection of the fact that these States and
Territories (with the exception of Oregon and its oil or gas
waste land application units) do not have any land application
units that require permitting. The number of land application
units having permits in those States which have permitting
programs is provided in Table 9.3.
9.3 Enforcement Programs for Subtitle D Land Application
Units
The frequency with which Subtitle D land application
units are inspected by States/Territories is presented in
Table 9.4. Seventy-two percent of all land application units are
inspected once every two years or less according to the study
returns. Approximately 24 percent of all industrial waste land
application units are never inspected, while only about 3 percent
of the municipal sewage sludge and 2 percent of the oil or gas
waste land application units are never inspected. The majority
of the oil or gas waste land application units (68.5%) are
inspected at least twice a year.
The total number of land application unit inspections
for compliance with Subtitle D requirements in 1984 is presented
in Table 9.5. Estimates in this table represent the total number
of inspections made, rather than the number of land application •
units inspected (e.g., multiple inspections may have been made of
the same facility).
120
-------
Table 9.2. Subtitle D permitting/licensing requirements:
Land application units
Number of states with:
Land application unit type
Permit or
plan approval
required
Yes No
License or
registration
required
Yes No
Municipal sewage sludge at high 36 14
application rate
• Municipal sewage sludge at low 44 6
application rate
Industrial waste 46 4
Oil or gas waste 32 14
6 44
5 45
5 45
4 43
Other
121
-------
Table 9.3. Number of Subtitle D land application units with permits
and licenses
Land application unit type
Municipal sewage sludge at high
application rate
Municipal sewage sludge at low
application rate
Total municipal sewage sludge*
Industrial waste
Oil or gas waste
Other
TOTAL
Have permits
or approved plans
242
6,893
7,955
3,331
697
519
12,502
Are licenced
or registered
1
296
297
113
0
0
410
*High rate application and low rate application may not equal the total
municipal sewage sludge figures because some states do not distinguish
between high and low rate land application units.
122
-------
Table 9.4. Frequency of inspection of Subtitle D land application units
Response rate
Never inspected
Less than once
every two years
Once every
two years
Once a year
Twice a year
Four times
a year
More than four
times a year
Other
TOTAL
Total
municipal
sewage
sludge
95%
388
(3.4%)
6,489
(57.2%)
1,403
(12.4%)
1,787
(15.8%)
254
(2.2%)
98
(0.9%)
182
(1.6%)
743
(6.5%)
11,344
(100%)
Industrial
waste
99%
1,308
(23.7%)
2,487
(45.0%)
845
(15.3%)
639
(11.6%)
126
(2.3%)
21
(0.4%)
10
(0.2%)
94
(1.7%)
5,530
(100%)
Oil and gas
waste
100%
15
(2.1%)
6
(0.8%)
33
(4.5%)
175 •
(24.1%)
465
(64.0%)
4
(0.6%)
8
(1.1%)
20
(2.8%)
726
(100%)
Other
100%
71
(11.4%)
46
(7.4%)
28
(4.5%)
26
(4.2%)
0
0
0
450
(72.5%)
621
(100%)
TOTAL
97%
1,782
(9.8%)
9,028
(49.5%)
2,309
(12.7%)
2,627
(14.4%)
845
(4.6%)
123
(0.7%)
200
(1.1%)
1,307
(7.2%)
18,221
(100%)
123
-------
Table 9.5. Number of inspections of Subtitle D land
application units in 1984
Number of
inspections
Land application unit type during 1984
Municipal sewage sludge at high
application rate
Municipal sewage sludge at low
application rate
Total municipal sewage sludge*
Industrial waste
Oil or gas waste
Other
TOTAL
174
4,089
5,326
1,601
1,124
34
8,085
*High rate application and low rate application may not
equal the total municipal sewage sludge figures because
some states do not distinguish between high and low
rate land application units.
124
-------
The total number and types of violations that were
found in 1984 LAU inspections is presented in Table 9.6. These
numbers are a reflection of the following:
o the number of inspections conducted by States/
Territories in 1984;
o the types of violations for which the 1984
inspections were made; and
o the availability of monitoring systems at the land
application units, as described in Section 6.4.4.
125
-------
Table 9.6. Number of Subtitle D land application units by type of violation in 1984
Number and percent of active individual Subtitle D land
application units in violation in 1984:
Violation type
Groundwater
contamination
Groundwater
monitoring program
deficiencies
H- '
cr.
Surface water
contamination
; Air contamination
Operational defi-
ciencies and other
minor violations
Other
Municipal
sewage
sludge at
high appli-
cation rate
4
(1.7%)
4
(1.7%)
1
(0.4%)
0
6
(2.5%)
0
Municipal
sewage
sludge at
low appli-
cation rate
13
(0.1%)
6
(0.1%)
15
(0.2%)
12
(0.1%)
102
(1.0%)
10
(0.1%)
Total
municipal
sewage
sludge*
17
(0.1%)
14
(0.1%)
17
(0.1%)
12
(0.1%)
115
(1.0%)
10
(0.1%)
Industrial
waste
45
(0.8%)
41
(0.7%)
-
60
(1.1%)
10
(0.2%)
88
(1.6%)
0
Oil or gas
waste
2
(0.3%)
8
(1.1%)
25
(3.4%)
0
82
(11.3%)
0
Other
2
(0.3%)
1
(0.2%)
24
(3.9%)
0
8
(1.3%)
0
TOTAL
66
(0.3%)
64
(0.3%)
126
(0.7%)
22
(0.1%)
293
(1.6%)
10
(0.1%)
''"High rate and low rate application may not equal the total municipal sewage sludge figures because some states do
not distinguish between high and low rate application units.
-------
10. SURFACE IMPOUNDMENTS
The following estimates are provided in this section:
o number of States/Territories that have regulations
pertaining to specific Subtitle D surface
impoundment regulations;
o number of States/Territories that have surface
impoundment permitting and licensing requirements;
o number of individual Subtitle D surface
impoundments that have permits and licenses;
o frequency of inspection of Subtitle D surface
impoundments;
o number of inspections of Subtitle D surface
impoundments in 1984;
o number of violations of Subtitle D surface
impoundments in 1984; and
o number of Subtitle D surface impoundments having
various monitoring and release prevention
management methods.
10.1 Subtitle D Surface Impoundment Regulations
As part of this study all States and Territories were
asked to review a list of Subtitle D requirements and indicate
whether or not each of these requirements was: specifically
included in State/Territory regulations; enforced under general
standards and policies; or not enforceable under any
State/Territory regulations, standards, or policies. Data from
all responding States and Territories are reported in Table 10.1,
As with the other types of Subtitle D facility
regulations, the requirements for surface impoundments were more
127
-------
Table 10.1
SUBTITLE D SURFACE IMPOUNDMENT REGULATIONS
a.
b.
c.
d.
e.
f.
g-
h.
i.
j-
k.
1.
m.
n.
o.
P-
q-
r .
s.
t.
u.
Location standards (e.g. ,
floodplains)
Natural liners (e.g.,
clay)
Synthetic liners
Leak detection system
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air protection standard
Air emission monitoring
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Overtopping controls
( freeboard)
Dike stability criteria
Restrictions on types of
Subtitle D wastes received
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
(example: caps)
Postclosure monitoring
Financial responsibility
Number of
in current
states with requirements
State Subtitle D program
Municipal sewage sludge
Specifically
included
in the
regulations
17
9
7
5
19
13
13
4
1
24
10
14
11
7
10
4
10
14
8
7
6
Enforced
under
general
standards
and
policies
22
29
29
23
17
22
18
15
14
16
28
25
28
31
25
14
17
22
21
21
15
No en-
forceable
require-
ments
3
3
5
13
5
6
10
22
26
1
3
2
2
3
6
22
14
5
12
13
20
included
Municipal run-off
Specifically
included
in the
regulations
11
6
6
6
17
11
10
7
2
14
6
7
7
4
8
4
7
10
8
9
7
Enforced
under
general
standards
and
policies
19
21
19
19
12
17
18
11
14
18
24
22
23
24
18
13
18
17
14
15
11
No en-
forceabl
require-
ments
9
11
13
13
8
10
11
21
21
6
8
9
8
10
12
21
14
12
16
14
20
(continued)
"128
-------
Table 10.1 (Cont.)
SUBTITLE D SURFACE IMPOUNDMENT REGULATIONS
a.
b.
c .
d.
e.
f.
g-
h.
i .
j-
k.
1.
m.
n.
0.
P-
q-
r.
s.
t.
u.
Location standards (e.g.,
floodplains)
Natural liners (e.g.,
clay)
Synthetic liners
Leak detection system
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air protection standard
Air emission monitoring
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Overtopping controls
(freeboard)
Dike stability criteria
Restrictions on types of
Subtitle D wastes received
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
(example: caps)
Postclosure monitoring
Financial responsibility
Number of
in current
Industrial waste
Specifically
included
in the
regulations
13
7
5
5
19
13
14
6
2
26
13
15
9
7
8
4
8
10
7
6
6
Enforced
under
general
standards
and
policies
26
30
29
26
18
24
21
13
15
16
27
25
31
31
29
17
21
25
24
23
15
states with requirements
State Subtitle D jjrogram
No en-
forceable
require-
ments
4
5
8
11
5
5
7
23
25
0
2
2
2
4
5
21
13
7
10
13
21
included
Agricultural waste
Specifically
included
in the
regulations
10
4
3
4
13
7
12
5
2
24
7
14
10
6
4
3
3
7
5
4
2
Enforced
under
general
standards
and
policies
24
27
26
19
19
21
18
11
11
13
28
21
25
28
26
13
17
19
17
17
13
No en-
forceable
require-
ments
9
11
13
19
10
14
10
26
29
5
7
6
7
8
12
25
21
16
19
21
27
(continued)
129
-------
Table 10.1 (Cont.)
SUBTITLE D SURFACE IMPOUNDMENT REGULATIONS
a.
b.
c.
d.
e.
f.
g-
h.
i.
j-
k.
1.
m.
n.
o.
P-
q-
r.
s.
t.
u.
Location standards (e.g.,
floodplains)
Natural liners (e.g.,
clay)
Synthetic liners
Leak detection system
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air protection standard
Air emission monitoring
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Overtopping controls
(freeboard)
Dike stability criteria
Restrictions on types of
Subtitle D wastes received
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
(example: caps)
Postclosure monitoring
Financial responsibility
Number of
in current
states with requirements
State Subtitle D program
Mining waste
Specifically
included
in the
regulations
11
6
5
6
17
13
14
8
4
22
13
15
13
12
10
8
4
11
10
8
10
Enforced
under
general
standards
and
policies
23
25
25
22
18
21
16
11
12
15
22
20
21
22
20
15
16
18
18
19
11
No en-
forceable
require-
ments
7
9
10
12
6
7
9
21
24
3
5
5
6
6
10
18
20
11
12
13
20
Oil
Specifically
included
in the
regulations
9
4
4
2
9
4
8
4
1
17
4
7
9
6
5
10
2
4
3
1
30
included
or gas waste
Enforced
under
general
standards
and
policies
18
24
23
21
22
23
19
a
9
16
23
22
18
20
17
25
12
15
18
17
13
No en-
forceab]
require-
ments
10
8
9
13
5
9
9
24
26
3
9
7
9
10
13
3
22
17
15
18
20
(continued)
130
-------
Table 10.1 (Cont.)
SUBTITLE D SURFACE IMPOUNDMENT REGULATIONS
a.
b.
c.
d.
e.
f.
g-
h.
i.
j.
k.
1.
m.
n.
0.
P-
q-
r.
s.
t.
u.
Number of
in current
Location standards (e.g.,
floodplains)
Natural liners (e.g.,
clay)
Synthetic liners
Leak detection system
Groundwater protection
standard
Groundwater monitoring
Corrective action for
groundwater contamination
Air protection standard
Air emission monitoring
Surface water protection
standards
Surface water monitoring
Corrective action for sur-
face water contamination
Overtopping controls
( freeboard)
Dike stability criteria
Restrictions on types of
Subtitle D wastes received
Endangered species criteria
Disease vectors criteria
Safety criteria:
Uncontrolled access
Closure standards
(example: caps)
Postclosure monitoring
Financial responsibility
states with
requirements included
State Subtitle D program
Other
Specifically
included
in the
regulations
8
5
4
4
7
6
8
5
3
13
5
7
7
6
6
2
4
5
3
3
1
Enforced
under
general
standards
and
policies
7
8
8
7
7
7
7
2
4
4
11
10
8
9
9
5
7
9
8
a
7
No en-
forceable
require-
ments
2
4
5
6
3
4
2
10
10
0
1
0
2
2
2
10
6
3
6
6
9
131
-------
likely to be enforced under general standards and policies than
specifically included in current Subtitle D programs.
Those requirements most often included specifically in
State/Territory regulations, in descending order were:
o Surface water protection standard;
o Groundwater protection standard;
o Corrective action for surface water contamination;
o Location standards; and
o Safety criteria; uncontrolled access.
Those requirements for which States/Territories were
the least likely to have any regulations were:
o Air emissions monitoring;
o Air protection standards;
o Financial responsibility;
o Closure standards; and
o Post closure monitoring.
10.2 Surface Impoundment Permitting/Licensing' Requirements
The number of States and Territories requiring surface
impoundment permits/plan approval and licenses/registration are
presented in Table 10.2. The number of Subtitle D surface
impoundments that have permits and licenses are presented in
Table 10.3.
132
-------
Table 10.2. Subtitle D permitting/licensing requirements: Surface
impoundments
Number of states with:
Surface impoundment type
Muncipal sewage sludge
Municipal run-off
Industrial waste
Agricultural waste
Mining waste
Oil or gas waste
Other
Licenses or
Permit or plan registration
approval required required
Yes No Yes No
39 5 1 42
26 18 1 42
42 2 2 41
37 7 3 40
40 4 3 ' 40
33 11 1 42
18 0 1 17
133
-------
Table 10.3. Number of Subtitle D surface impoundments with permits/licenses
Surface impoundment type
Muncipal sewage sludge
Municipal run-off
Industrial waste
Agricultural waste
Mining waste
Oil or gas waste
Other
TOTAL
Number of individual
Subtitle D surface
impoundments that
have permits or
plan approval
1,121
365
7,747
10,505
11,218
59,295
5,227
95,478
Number of individual
Subtitle D surface
impoundments
licensed or
registered
0
0
354
210
77
0
0
641
134
-------
10.3 State Enforcement Programs for Subtitle D Surface
Impoundments
The frequency with which Subtitle D surface
impoundments are inspected by States/Territories is presented in
Table 10.4. Approximately 41 percent of all Subtitle D surface
impoundments are inspected once every two years or less and about
12 percent of all Subtitle D surface impoundments are never
inspected, according to study respondents. The total number of
surface impoundment inspections made during 1984 for compliance
with Subtitle D requirements is presented in Table 10.5.
Estimates in Table 10.5 represent the total number of inspections
made, rather than the number of surface impoundments inspected
(e.g., multiple inspections may have been made at the same
facility).
The total number and types of violations that were
found in 1984 surface impoundment inspections is presented in
Table 10.6. These estimates are a reflection of the following:
o the number of inspections conducted by States/
Territories in 1984;
o the types of violations for which the 1984
inspections were made; and
o the availability of monitoring systems at the
surface impoundments, as described in Section
7.4.4.
135
-------
Table 10.A. Frequency of inspections of Subtitle D surface impoundments
CTl
Never inspected
Less than once
every two years
Once every two
years
Once a year
Twice a year
Four times
a year
More than four
times a year
Other
TOTAL
Municipal
sewage
sludge
37
(2.1%)
401
(22.4%)
208
(11.6%)
851
(47.4%)
234
(13.0%)
61
(3.4%)
2
(0.1%)
0
1,794
(100%)
Municipal
run-
off
34
(7.1%)
59
(12.3%)
30
(6.3%)
106
(22.1%)
24
(5.0%)
82
(17.1%)
138
(28.8%)
6
(1.3%)
479
(100%)
Indus-
trial
waste
191
(1.6%)
2,981
(25.2%)
2,835
(24.0%)
4,645
(39.3%)
498
(4.2%)
234
(2.0%)
164
(1.4%)
275
(2.3%)
11,823
(100%)
Agricul-
tural
waste
3,634
(24.2%)
5,568
(37.1%)
1,013
(6.7%)
2,918
(19.4%)
413
(2.8%)
3
(<0.1%)
0
1,465
(9.8%)
15,014
(100%)
Mining
waste
658
(8.8%)
927
(12.4%)
3,294
(44.0%)
2,009
(26.8%)
100
(1.3%)
51
(0.7%)
206
(2.7%)
249
(3.3%)
7,494
(100%)
Oil or
Gas
waste
11,478
(11.9%)
15,239
(15.7%)
7,344
(7.6%)
60,152
(62.2%)
1,426
(1.5%)
406
(0.4%)
740
(0.8%)
0
96,785
(100%)
Other
3
(0.06%)
104
(2.0%)
108
(2.1%)
425
(8.2%)
27
(0.5%)
222
(4.3%)
0
4,324
(82.9%)
5,213
(100%)
TOTAL
16,035
(11.6%)
25,279
(18.2%)
14,832
(10.7%)
71,106
(51.3%)
2,722
(2.0%)
1,059
(0.8%)
1,250
(0.9%)
6,319
(4.6%)
138,602
(100%)
Response rate
93%
98%
73%
88%
38%
77%
47%
72%
-------
Table 10.5. Number of inspections of Subtitle D surface impoundments in 198A
Surface impoundment type
Muncipal sewage sludge
Municipal run-off
Industrial waste
Agricultural waste
Mining waste
Oil or gas waste
Other
TOTAL
Number of inspections
during 1984
1,079
1,768
6,164
3,765
7,674
26,340
1,313
48,103
137
-------
Table 10.6. Number of surface impoundments by type of violation in 1984
UO
Number and percent of
Violation type
Groundwater contamination
Groundwater monitoring
program deficiencies
Surface water contamination
Air contamination
Operational deficiencies
and other minor violations
Municipal
sewage
sludge
35
(1.8%)
28
(1.4%)
24
(1.2%)
20
(1.0%)
137
(7.1%)
Municipal
run-off
32
(6.6%)
12
(2.5%)
18
(3.7%)
12
(2.5%)
37
(7.6%)
active individual Subtitle D surface impoundments in violation
in 1984:
Indus-
trial
waste
416
(2.6%)
317
(2.0%)
279
(1.7%)
145
(0.9%)
616
(3.8%)
Agricul-
tural
waste
29
(0.2%)
34
(0.2%)
189
(1.1%)
21
(0.1%)
672
(3.9%)
Mining
waste
48
(0.2%)
137
(0.7%)
249
(1.3%)
5
534
(2.7%)
Oil
or gas
waste
111
(0.1%)
110
(0.1%)
128
(0.1%)
10
2,893
(2.3%)
Other
6
(0.1%)
5
22
(0.2%)
0
18
(0.2%)
TOTAL
677
(0.4%)
643
(0.3%)
909
(0.5%)
213
(0.1%)
4,907
(2.6%)
Other violations
-------
PART V
SMALL QUANTITY GENERATOR WASTE
Section 11. Small Quantity Generator Waste
139
-------
PART V
SMALL QUANTITY GENERATOR WASTE
As pointed out in Section 1.1, Congress specifically
directed the Administrator of the Environmental Protection Agency
to evaluate and revise the "Criteria" for Subtitle D facilities
that may receive hazardous waste or small quantity generator
waste. These revisions are to include groundwater monitoring,
location restrictions, and other corrective action, as
appropriate. Also, within 18 months of the promulgation of the
revised criteria, each State must develop a permit program or
other system of prior approval and conditions to ensure that each
facility that may receive hazardous household waste or small
quantity generator waste is in compliance with the criteria.
Because of these requirements the census of State and
Territorial Subtitle D non-hazardous waste programs included
questions regarding the percentage of Subtitle D facilities (by
type) that receive exempted non-household hazardous waste. A
decision was made to use the term "non-household hazardous waste"
in place of "small quantity generator hazardous waste" in the
questionnaire because of varying definitions of what constitutes
a "small quantity." The EPA criterion for small quantity
generator waste changed while the survey was being conducted,
from 1,000 kilograms per month to 100 kilograms per month.
141
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11. SMALL QUANTITY GENERATOR WASTE
11.1 Quality of Exempted Non-household Hazardous Waste
Receipt Data
Anecdotal evidence suggests that the estimates reported
in this chapter are highly unreliable. The response rates for
these estimates ranged from as low as 28 percent to as high as
100 percent. A bimodal distribution of responses clustered
around the extremes — no facility received exempted non-
household hazardous waste, or all facilities received it. One
-State official initially refused to answer the question on
exempted non-household hazardous waste, but then said that the
answer should be zero because disposal of these wastes in
Subtitle D facilities was not permitted by law in their State.
Upon further reflection, this official Stated that probably all
facilities had some exempted non-household hazardous waste since
there was no mechanism to track this waste, or prevent it from
entering the Subtitle D facilities. Most States admitted that
they really did not know the extent of exempted non-household
hazardous wastes being received by Subtitle D facilities.
In a telephone followup, many of these States mentioned
household wastes when questioned about the type of small quantity
generator wastes included in their estimates. When it was
pointed out in the telephone editing procedures that household
wastes were specifically excluded from the survey, their
estimates did not change.
143
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11.2 Estimated Percentage and Number of Subtitle D
Facilities Receiving Non-Household Hazardous Waste
The percentage and number of landfills that were
reported to receive exempted non-household hazardous waste is
presented in Table 11.1. Over one-half of the municipal waste
landfills, about 12 percent of the industrial waste landfills,
and about 14 percent of the demolition debris landfills were said
to receive such wastes. Twenty-seven percent of the landfills
falling in the "other" category (primarily open dumps) were
estimated to contain such wastes. Altogether, more than 5,000
landfills were estimated to receive exempted non-household
hazardous waste.
The percentage and number of land application units
that were reported to receive exempted non-household hazardous
waste is presented in Table 11.2. Oil or gas waste land
application units were said to have the highest percentage
receiving such wastes (38.1%) but this category also had the
lowest response rate (57%). Industrial waste land applications
were reported to have the lowest percentage (3.1%) receiving such
wastes. About 13 percent of the municipal sewage sludge land
application units were reported to receive non-household
hazardous waste, with about 16 percent of the high rate
application units and about 11 percent of the low rate land
application units receiving such wastes. Altogether, more than
1,600 land application units were estimated to receive exempted
non-household hazardous waste.
The percentage and number of surface impoundments that
receive exempted non-household hazardous waste is presented in
Table 11.3. The estimates range from a high of almost 42 percent
for the municipal run-off surface impoundments to a low of less
than 1 percent for agricultural waste surface impoundments.
144
-------
Altogether, more than 25,500 surface impoundments were estimated
to receive exempted non-household hazardous waste.
145
-------
Table 11.1 Number and percent of landfills that receive exempted non-
household hazardous wastes
Landfill type
Response Number of Percent of
rate landfills landfills
Municipal waste
88%
4,327
52.9%
Industrial waste
83%
360
12.3%
Demolition debris only
89%
312
13.5%
Other
28%
76
26.7%
TOTAL
83%
5,075
37.1%
146
-------
Table 11.2 Number and percent of land application units that receive exempted
non-household hazardous wastes
Land application unit type
Municipal sewage sludge
at high application rate
Municipal sewage sludge
at low application rate
Total municipal sewage
sludge *
Industrial waste
Oil or gas waste
Other
TOTAL
Response Number of land
rate application units
33
1,050
92% 1,382
95% 164
57% 101
100% 0
91% 1,647
Percent of land
application units
16.4%
11.2%
12.6%
3.1%
38.1%
0%
9.6%
•ff
High rate application and low rate application may not equal the total
municipal sewage figures because some states do not distinguish between high
and low rate land application units.
147
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Table 11.3 Number and percent of surface impoundments that receive exempted
non-household hazardous wastes
Surface impoundment type
Municipal sewage sludge
Municipal run-off
Industrial waste
Agricultural waste
Mining waste
Oil or gas waste
Other
TOTAL
Response Number of surface
rate impoundments
75% 548
77% 157
65% 1,541
79% 88
59% 824
77% 17,746
99% 5
75% 20,909
Percent of surface
imp oundmen t s
37.6%
41.5%
14.7%
0.7%
7.0%
18.5%
<0 . 1%
14.5%
148
-------
PART VI
SUMMARY AND CONCLUSIONS
Section 12. Results
Section 13. Conclusions
149
-------
PART VI
SUMMARY AND CONCLUSIONS
Part VI summarizes the results and conclusions of the
Census of State and Territorial Subtitle D Solid Waste Programs.
Results are presented in Section 12. Methodological results are
summarized in Section 12.1. Substantive results pertaining to
Subtitle D programs are summarized in Section 12.2. Conclusions
are presented in Section 13.
151
-------
12. RESULTS
12.1 Methodological Results
A mail questionnaire census was undertaken of all
States and Territories having Subtitle D solid waste programs;
all 50 States, the Commonwealth of Puerto Rico, the Virgin
Islands, Guam, American Samoa, and the Commonwealth of the
Northern Marianas participated in the study. A 100 percent
response was obtained, but the total amount of information that
was provided, and the overall quality of the information varied
greatly from one State and Territory to another. The District of
Columbia reported no Subtitle D agencies or facilities and is not
included in the results of this survey.
In general, nonresponse is an important factor to
consider with respect to most of the estimates obtained in the
Census of State and Territorial Subtitle D Nonhazardous Waste
Programs. While a great deal of effort was expended by study
respondents in the completion of study questionnaires and in
followup telephone conversations, it was simply not possible for
each State and Territory to provide estimates for each question
in the study. In some cases, information was available in files
or other records, but not in a format which could readily be
retrieved. In other cases, the information could not be provided
by States and Territories simply because no data whatsoever were
available with which to project even rough estimates. Therefore,
most estimates provided in this study are affected by
nonresponse, some estimates to a larger degree than others. It
is important to read the text when reviewing study estimates to
assess the effect of nonresponse. Nonresponse is especially
important with respect to estimates of dollars and hours expended
153
-------
on Subtitle D activities, estimates of surface impoundments, and
estimates of industrial facilities.
The quality of the data provided in the Census of State
and Territorial Subtitle D Nonhazardous Waste Programs varied
greatly from one State and Territory to another and from one
question to another within the same State or Territory. Data
quality ratings were obtained from the respondents by telephone
and through the use of a rating system built into the
questionnaire. In general, the quality of the data with regard
to municipal waste landfills is the highest of all estimates
obtained in the study and the data with respect to surface
impoundments is the lowest. Estimates which were obtained
primarily through record searches (generally, number of
inspections conducted, number of violations cited, number of
permitted and licensed facilities) are believed to be somewhat
more reliable than are data estimated without the benefit of
records (generally, number of facilities having monitoring
systems, number of facilities having release prevention
mechanisms).
More detailed information regarding methodological
results of the study can be found in Section 3, Statistical
Reliability.
12.2 Substantive Findings
The major findings regarding the Subtitle D program are
summarized in the points described below.
154
-------
State Organization and Resources
1. A wide variety of agency types are reported to be
involved in Subtitle D activities.
The types of agencies listed by the States
included, but were not limited to, solid waste and
water agencies, departments of environmental
protection or public health, oil and gas
commissions, and bureaus of energy or geology.
The States listed an average of 3 agencies. The
distribution of States by number of agencies
reported is shown in Figure 12.1.
2. The amount of money spent on Subtitle D programs
varies widely by State.
The average dollar amount reported to be spent on
Subtitle D-related programs was $785,649 per
State, with a range up to $9,476,255.
Number and Characteristics of Subtitle D Facilities
3. Approximately 227.000 Subtitle D facilities and
120.000 Subtitle D establishments were reported in
the study.
The total number of Subtitle D facilities in the
United States and its Territories is as yet
unknown due to the high level of nonresponse for
particular types of facilities. Study estimates
of the total number of surface impoundments, in
general, and oil or gas waste surface
impoundments, in particular, are likely to be
large underestimates since many States and
Territories could not even provide rough estimates
of total numbers for these facility types.
In addition, nine States that provided estimates
of the numbers of at least some facility types
were unable to provide estimates of the total
number of establishments in their State/Territory.
An "establishment" is a single physical location
where business is conducted or where services or
industrial operations are performed by a
municipality, corporation, or other public or
private entity. An establishment may have one or
more landfills, land application units, and
surface impoundments (i.e., one or more
facilities).
155
-------
Figure 12.1
NUMBER OF AGENCIES WITH SUBTITLE D RESPONSIBILITIES
REPORTED IN EACH STATE
Number 20 -
of
States
15
o •
•
n .
PR
AK
AR
DE*
GA
HI
IL
MD
MN
MS
Rl
SO
WA
AS
GU
NMR
AL
IN
IA
KS
ME
MA
NE
NH
Nj
NM
NY
NC
NO
OK
TN
UT
VT
Wl
WY
CA
CT
FL
KY
OR
TX
VA
CO
Ml
MO
MT
NV
sc
VI
wv
OH
LA PA ID AZ
Not Reported 1
3456
Number of Agencies
8
* Delaware also has a public corporation "Authority" engaged in
Subtitle D activities.
156
-------
The total numbers and percentages of Subtitle D
facilities by type.that were reported in this
study are provided in Table 12.1. Oil or gas
waste surface impoundments represent by far the
single largest category of Subtitle D facilities.
They account for about 55 percent of all
Subtitle D facilities. Municipal waste landfills,
account for about 4 percent of all Subtitle D
facilities.
4. Many of the Subtitle D facilities, within a given
typef are highly concentrated in a few States.
Figure 12.2 displays the percentage of facilities
accounted for by the States with the largest
number of facilities of each type. In most cases,
more than half of the facilities were found in
five or fewer States. Industrial and oil or gas
land application units appear to be the most
concentrated, with the top five States containing
more than 80 percent of the facilities. Municipal
waste landfills appear to be the least
concentrated, with 34 percent of the facilities
located in the top five States.
5. Most Subtitle D facilities are privately owned.
Ownership was reported for about 184,000 of the
227,000 facilities reported in this study. Type
of owner for each of the three major subcategories
of Subtitle D facilities is presented in
Table 12.2. Over 88 percent of all Subtitle D
facilities are privately owned. Exceptions are
municipal and demolition debris landfills,
municipal sewage sludge, and municipal run-
off/surface impoundments; these types of
facilities are owned primarily by local
governments.
6. In terms of acres of land, surface impoundments
are the smallest Subtitle D facilities.
Over 99 percent of Subtitle D surface impoundments
are less than 10 acres in size, while 44.6 percent
of landfills and 77.7 percent of land application
units are larger than 10 acres. The size
categories reported for Subtitle D facilities are
summarized in Table 12.3. It should be noted that
size category was reported for about 80 percent of
landfills and land application units and only 63
157
-------
Table 12.1. Reported number of Subtitle D facilities by type
Reported
total number
Percentage of
total facilities
Landfills
Municipal waste
Industrial waste
Demolition debris
Other
Subtotal
Land application units
Municipal sewage sludge
Industrial
Oil/gas
Other
Subtotal
Surface impoundments
Municipal sewage sludge
Municipal run-off
Industrial
Agricultural
Mining
Oil/gas
Other
Subtotal
TOTAL
9,284
3,511
2,591
1,030
16,416
11,937
5,605
726
621
18,889
1,938
488
16,232
17,159
19,813
125,074
11,118
191,822
227,127
100.0%
158
-------
Figure 12.2
PERCENTAGE ACCOUNTED FOR BY THE FIVE STATES WITH THE
LARGEST NUMBER OF SUBTITLE D FACILITIES BY TYPE
1 00 -r
9O
80
6O --
5O
-4O -
3O -
2O --
1 O
58%
34%
CA
LA
6%
Wl
10%
TX
10%
TX
4%
AL
5%
AK
8%
WV
10%
PA
30%
51%
6%
UT
8%
CA
8%
KS
10%
AL
19%
1
55%
MN
7%
WI
8%
IN
9%
MI
13%
PA
19%
1 —
84%
IN.*
NC.&
MD
10%
MI
16%
WI
58%
i
83%*
TX
10%
CA
14%
NE
59%
»—
52%
MA
8%
NV
10%
WI
10%
CO
11%
NY
14%
— I—
61%
TX
10%
MD
10%
WV
11%
FL
12%
MI
17%
— 1
77%
NM491
48%
42%
IL
7%
TX
7%
FL
8%
PA
10%
OH
10%
__1
MS
6%
NE
7%
AL
1*
KS
10%
WI
18%
1
TN
7%
AL
13%
WV
25%
PA
28%
75%
WV
10%
NM
13%
PA
16%
LA
16%
AR
20%
Municipal
Waste
Industrial Demolition Municipal
Waste Debris Sewage
Sludge
Industrial Oil/Gas
Municipal
Sewage
Sludge
Municipal
Run-off
Industrial Agricultural Mining Oil/Gas
LANDFILLS
LAND APPLICATON
UNITS
SURFACE IMPOUNDMENTS
* KS. WV Sc WY account for an additional 8?S of Oil/Gas Land Application Units
-------
Table 12.2. Ownership of Subtitle D facilities
Ownership
Land
application Surface
Landfills units impoundments
Total
State government
1.7%
0.6%
0.1%
0.3%
Local government
53.8%
8.4%
1.6%
6.7%
Federal government
4.0%
0.6%
0.1%
0.5%
Private
40.5%
90.4%
98.2%
92.5%
Other
0.1%
0.0%
0.0%
160
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Table 12.3 Number of Subtitle D Faciliites by acreage category
Landfills
Municipal waste
Industrial waste
Demolition debris
Other
Subtotal
Percent
Land application units
Municipal sewage sludge
Industrial
Oil/gas
Other
Subtotal
Percent
Surface impoundments
Municipal sewage sludge
Municipal run-off
Industrial
Agricultural
Mining
Oil/gas
Other
Subtotal
Percent
TOTAL
Percent
<10 acres
2,944
2,182
1,327
831
7,284
(54.4%)
2,077
681
568
154
3,480
(22.3%)
1,238
341
6,108
11,707
6,166
91,690
5,268
122,518
(99.3%)
133,282
(87.6%)
10 - 100 acres
3,572
834
797
70
5,273
(40.1%)
'
6,356
3,267
113
13
9,749
(62.6%)
4
5
380
102
257
27
2
111
(0.6%)
15,799
(16.47.)
100+ acres TOTAL
449
72
64
1
586
(4.5%)
1,378
470
45
454
2,347
(15.1%)
5
0
70
0
17
25
0
117
(0.1%)
3,050
(2.07.)
6,965
3,088
2,188
902
13,143
(100%)
9,811
4,418
726
621
15,576
(100%)
1,247
346
6,558
11,809
6,440
91,742
5,270
123,412
(100%)
152,131
(100%)
161
-------
percent of the surface impoundments reported in
this study.
7. Very few Subtitle D facilities have extensive
design and operational controls.
Approximately 40 percent of all Subtitle D
landfills have restrictions on the receipt of
liquid waste, and 38 percent have run-on/run-off
controls. On the other hand, only 12 percent of
landfills are reported to have liners, and less
than 4 percent have leachate collection systems.
Over 75 percent of all Subtitle D land application
units have waste application rate limits, 54
percent have waste restrictions, and 51 percent
have run-on/run-off controls.
Approximately 29 percent of all Subtitle D surface
impoundments have liners, 27 percent have waste
restrictions, and 25 percent have overtopping
controls.
8. Very few Subtitle D facilities have systems to
monitor releases.
The percentages of Subtitle D facilities reported
to have various monitoring systems are presented
in Table 12.4 by facility type. Approximately 15
percent of all Subtitle D facilities are reported
to have surface water monitoring systems, 5
percent are reported to have groundwater
monitoring systems, and less than 1 percent are
reported to have air monitoring systems.
Approximately 3 percent of all landfills are
reported to have methane monitoring systems.
About 27 percent of all land application units are
reported to have soil monitoring systems.
State Subtitle D Regulatory Programs
9. Subtitle D regulations vary by State or Territory.
Most Subtitle D requirements were likely to be
enforced under general standards and policies
rather than specifically included in current
Subtitle D programs. A detailed assessment of
State and Territorial regulations discussing how
the regulations vary will be found in the report,
"Summary of Subtitle D Regulations" (in
preparation).
162
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Table 12.4 Percent of Subtitle D facilities having monitoring systems
Percent of facilities
with monitoring systems
Landfills
Municipal waste
Industrial waste
Demolition debris
Other
Subtotal
Land application units
Municipal sewage sludge
Industrial
Oil/gas
Other
Subtotal
Surface impoundments
Municipal sewage sludge
Municipal run-off
Industrial
Agricultural
Mining
Oil/gas
Other
Subtotal
TOTAL
Ground-
water
25.1
17.8
5.2
4.1
19.1
2.8
10.6
34.0
0.5
6.2
6.8
39.3
8.6
0.3
27.2
0.1
0.1
3.8
5.1
Surface
water
11.8
6.6
2.7
1.6
8.6
2.2
2.4
31.7
0.0
3.3
2.6
11.7
19.4
0.8
43.8
16.0
1.2
16.8
15.1
Air
3.7
2.3
0.3
0.0
2.7
0.8
0.6
5.1
0.0
0.9
0.5
0.0
0.4
<0.1
0,1
<0.1
0.0
0.1
0.3
Methane
4.6
1.8
0.3
0.0
3.0
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Soil
NA
NA
NA
NA
NA
40.2
3.6
5.8
0.5
26.8
NA
NA
NA
NA
NA
NA
NA
NA
NA
163
-------
10. About 52 percent of the Subtitle D facilities have
been issued permits by State agencies, about 48
percent have not.
The number and percent of Subtitle D facilities
having permits is presented in Table 12.5.
Approximately 51 percent of all landfills, 66
percent of all land application units, and 50
percent of all surface impoundments were reported
to have permits.
In a few States, some of the facilities that have
not been permitted are licensed as part of a
separate registration program. These facilities
were, for the most part, in existence when the
current State regulations took effect. As such,
these facilities were licensed under a
"Grandfather" clause and have not been formally
evaluated and approved. These licensed facilities
are not included in Table 12.5.
11. States are concentrating their efforts on
surveillance/enforcement activities and on the
permitting of facilities.
Surveillance and enforcement efforts were reported
to account for 41 percent of the 1,814,439 hours
devoted to Subtitle D activities by States and
Territories. Permitting of facilities represented
the next most frequently engaged in activity, with
28 percent of all hours being directly related to
the review and approval of plans and the issuance
of permits to operate. An additional 9 percent of
the hours was directed towards technical
assistance. When asked to rank these areas with
respect to expected improvement with additional
resources, respondents ranked surveillance and
enforcement first, technical assistance second,
and permitting or licensing third.
12. State surveillance/enforcement efforts resulted in
approximately 89,000 inspections in 1984, while
less than one-third of all Subtitle D facilities
were inspected.
The total reported number of inspections of
Subtitle D facilities is summarized in Table 12.6.
These numbers do not indicate how many facilities
were actually inspected since a facility may have
been inspected more than once. Approximately 54
164
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Table 12.5 Number and percent of permitted facilities
Number of
facilities
with permits
Percentage
of total
facilities
Landfills
Municipal waste
Industrial waste
Demolition debris
Other
Subtotal
Land application units
Municipal sewage sludge
Industrial
Oil/gas
Other
Subtotal
Surface impoundments
Municipal sewage sludge
Municipal run-off
Industrial
Agricultural
Mining
Oil/gas
Other
Subtotal
TOTAL
7,955
3,331
697
519
12,502
1,121
365
7,747
10,505
11,218
59,295
5.227
95,478
116.402
58.6%
39.6%
53.1%
20.3%
51.3%
66.6%
59.4%
96.0%
83.6%
66.2%
51.2%
165
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Table 12.6. Number and percent of state/territory inspections in 1984
Type
Number of
inspections
Percent of
the total
number of
inspections
Landfills
Municipal waste
Industrial waste
Demolition debris
Other
Subtotal
Land application units
Municipal sewage sludge
Industrial waste
Oil/gas waste
Other
Subtotal
Surface Impoundments
24,865
4,354
2,834
799
32,852
Municipal sewage sludge
Municipal run-off
Industrial
Agricultural
Mining
Oil/gas
Other
Subtotal
Total
1,079
1,768
6,164
3,765
7,674
26,340
1,313
48,103
89.040
1.2%
2.0%
6.9%
4.2%
8.6%
29 . 6%
1.5%
54.0%
100.0%
Notes: Percentages may not sum to 100% due to independent rounding.
The numbers reported here refer to' the number of inspections made, not
the number of facilities inspected (i.e., some facilities may have
been inspected more than once in 1984).
166
-------
percent of the 89,040 reported inspections were
made of surface impoundments. Many of these
inspections were made in response to State/federal
water program regulations (e.g., NPDES) rather
than Subtitle D regulations.
The frequency of inspection of Subtitle D
facilities is summarized in Table 12.7.
Approximately 42 percent of all Subtitle D
facilities are reported to be inspected less than
once each year. If this frequency distribution is
used to estimate the number of facilities that may
have been involved in the 89,040 inspections in
1984, it shows that approximately 30 percent of
all Subtitle D facilities were inspected.
13. States report having cited 1,463 Subtitle D
facilities for qroundwater contamination, 1,793
Subtitle D facilities for surface water
contamination, and 1.185 Subtitle D facilities for
air contamination in 1984.
The numbers of violations for groundwater, surface
water, and air contamination are presented in
Table 12.8. Although landfills only accounted for
7 percent of the total number of Subtitle D
facilities, 37 percent of the inspections
conducted in 1984 were at landfills.
Consequently, approximately 49 percent of all
groundwater violations and about 80 percent of all
air contamination violations were reported to have
been cited at landfills. Surface water violations
were more likely to have have been cited at
surface impoundments, with about 51 percent of all
surface water violations occurring at surface
impoundments.
No data were requested in this study which could
be used to determine the seriousness of the
violations presented in Table 12.8. Respondents
were directed to use that definition of
contamination that applied to their own State or
Territory when answering questions regarding
groundwater, surface water, and air contamination.
In addition, the overall extent of groundwater
contamination from Subtitle D facilities cannot be
determined because not all Subtitle D facilities
have monitoring systems. Less than one-third of
all Subtitle D facilities are inspected each year,
according to reports in this study.
167
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Table 12.7. Frequency of inspection of Subtitle D facilities
Response Rate
Never inspected
Less than once
every two years
Once every
two years
Once a year
Twice a year
Four times
a year
More than four
times a year
Other
TOTAL
Landfills
91%
864
(5.8%)
935
(6.2%)
1,472
(9.8%)
4,214
(28.1%)
2,587
(17.3%)
2,121
(14.2%)
2,618
(17.5%)
176
(1.2%)
14,987
(100%)
Land
application
units
97%
1,782
(9.8%)
9,028
(49.5%)
2,309
(12.7%)
2,627
(14.4%)
845
(4.6%)
123
(0.7%)
200
(1.1%)
1,307
(7.2%)
18,221
(100%)
Note: The numbers reported here refer to the number
to be inspected at these frequencies, not the
Surface
impoundments
74%
16,035
(11.6%)
25,279
(18.2%)
14,832
(10.7%)
71,106
(51.3%)
2,722
(2.0%)
1,059
(0.8%)
1,250
(0.9%)
6,319
(4.6%)
138,602
(100%)
of facilities
TOTAL
77%
18,681
(10.9%)
35,242
(20.5%)
18,613
(10.8%)
77,947
(45.4%)
6,154
(3.6%)
3,303
(1.9%)
4,068
(2.4%)
7,802
(4.5%)
171,810
(100%)
that were
number of inspections
made.
168
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Table 12.8.
Groundwater, surface water and air contamination violations in
1984
Number of active individual Subtitle D facilities
in violation in 1984
Groundwater
contamination
Surface water
contamination
Air
contamination
Landfills
Municipal waste
Industrial waste
Demolition debris
Other
Subtotal
586
111
16
7
720
660
50
42
6
758
845
18
33
54
950
Land application units
Municipal sewage sludge 17
Industrial 45
Oil/gas 2
Other _2
Subtotal 66
Surface Impoundments
Municipal sewage sludge 35
Municipal run-off 32
Industrial 416
Agricultural 29
Mining 48
Oil/gas 111
Other 6
Subtotal 677
TOTAL 1,463
17
60
25
24
126
24
18
279
189
249
128
22
909
1,793
12
10
0
_0
22
20
12
145
21
5
10
0
213
1,185
169
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The number of facilities having groundwater
monitoring systems, the number of facilities cited
for groundwater contamination violations, and the
percent of monitored facilities cited for
groundwater contamination are reported in Table
12.9. Groundwater contamination was observed in
23 percent of the landfills that had groundwater
monitoring systems, in 6 percent of the land
application units that had groundwater monitoring
systems, and in 9 percent of the surface
impoundments that had groundwater monitoring
systems.
Small Quantity Generator Hazardous Waste
14. Approximately 16 percent of all Subtitle D
facilities are reported to receive exempted non-
household hazardous waste (i.e., small quantity
generator waste.)
The percentages of Subtitle D facilities receiving
exempted non-household hazardous waste are
summarized in Table 12.10. The reader should
treat these estimates with caution for several
reasons. First, the response rates for some
facility types are as low as 28 percent. Second,
the estimates are based on reports from the States
that were highly skewed at either 0 percent or 100
percent of the facilities. Some States do not
exempt small quantity generator waste in any
amount, and for other States, the exempt amounts
differ from the current EPA criterion.
170
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Table 12.9. Ground-water monitoring systems/violations
Facilities
cited for
ground-
water
contamination
violations
Facilities
having
ground-
water
monitoring
systems
Percent
of monitored
facilities
having
groundwater
contamination
Landfills
Municipal waste 586
Industrial waste 111
Demolition debris 16
Other 7
Subtotal 720
Land application units
Municipal sewage sludge 17 337 0.5%
Industrial 45 592 7.6%
Oil/gas 2 247 0.8%
Other __2 3 66.7%
Subtotal 66 1,179 5.6%
Surface Impoundments
Municipal sewage sludge 35 131
Municipal run-off 32 192
Industrial 416 1,396
Agricultural 29 44
Mining 48 5,399
Oil/gas 111 165
Other 6 7
Subtotal 677 7,334
TOTAL 1,463 11,647 12.6%
171
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Table 12.10. Percent of Subtitle D facilities receiving exempted non-
household hazardous waste
Response Percent receiving exempted
rate non-household hazardous waste
Landfills
Municipal waste 88% 52.9%
Industrial waste 83% 12.3%
Demolition debris 89% 13.5%
Other 28% 26.7%
Subtotal 84% 37.1%
Land application units
Municipal sewage sludge 92% 12.6%
Industrial 95% 3.1%
Oil/gas 57% 38.1%
Other 100% 0%
Subtotal 90% 9.6%
Surface impoundments
Municipal sewage sludge 75% 37.6%
Municipal run-off 78% 41.5%
Industrial 65% 14.7%
Agricultural 79% 0.7%
Mining 59% 7.0%
Oil/gas 77% 18.5%
Other 99% <0.1%
Subtotal 75% 14.5%
TOTAL 77% 15.7%
172
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13. CONCLUSIONS
The general conclusions that can be drawn from the
Census of State and Territorial Subtitle D Nonhazardous Waste
Programs are summarized in the points below. Points 1, 2, and 3
concern the extent to which this study can be relied upon as an
assessment of Subtitle D programs. Points 4, 5, and 6 represent
the primary conclusions drawn by the authors of this study
regarding the present status of State and Territorial Subtitle D
programs.
1. Due to high nonresponse rates for certain
variables in the study, study data do not
represent a complete picture of the status of
Subtitle D programs.
Estimates of total numbers presented in this report
(e.g., total number of dollars expended on Subtitle D activities,
total numbers of facilities, etc.) are likely to be
underestimates due to nonresponse. As pointed out in several
sections of this report, it was simply not possible for all
States to respond to all questions in the study. Lack of
information and/or difficulty accessing existing information
resulted in nonresponse which in turn resulted in underestimates
of total numbers.
Estimates of percentages produced as a result of this
study (e.g.,percentage of facilities that are permitted,
percentage of facilities that are inspected, percentage of
facilities having monitoring systems or release prevention
mechanisms, etc.) may be biased somewhat due to the nonresponse.
173
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2. Additional research could fill some of the gaps in
this study. One national survey of certain
facilities would be the most cost effective
technique.
Some States and Territories could not provide the
resources necessary to compile existing information to answer
study questions, even though the information was available in a
record-keeping system of some type within the State or Territory.
In the majority of these cases, significant levels of funds would
be required to identify, review, analyze, and compile existing
information. Respondents on several occasions indicated that
literally hundreds of hours of research would be required to
review existing records to provide responses.
A more cost effective approach would be to conduct one
national survey of certain facilities to obtain the necessary
estimates. An example would be attempts to fill gaps on
industrial Subtitle D facility types, for which there was great
nonresponse in this study. Rather than conduct a total of 15 to
20 different industrial studies (one for each nonrespondent
State), it would be much more cost effective (and equally
reliable) to estimate the total number of industrial facilities
in the United States through a single national survey.
3. Additional research efforts would be likely to add
to estimates of total numbers obtained in this
study, but they would not be likely to change the
direction of the general trends found in the
present data set.
With additional data collection efforts, it would be
possible to add to the total number of facilities in the United
States and to the total number of dollars and hours expended on
Subtitle D activities, and to any other totals estimated in the
study. Since this study is a census (with no projections from
174
-------
samples to the total population) every additional (non-zero)
response would represent an addition to the totals.
If, for example, from the original data set it was
estimated that 100,000 facilities of a given type existed and an
additional research effort identified 10,000 more facilities of
this type in nonrespondent State "X", the estimate could be
revised from 100,000 to 110,000 facilities. A difference in the
estimate of the true value would be produced and a change in the
data set would be observed.
Such a difference would not likely affect , however,
the original conclusions that only about half of the facilities
are permitted, or that few facilities have monitoring systems or
release prevention management systems. If anything, additional
research efforts (because of the nature of the nonresponse) would
be likely to bolster these observations. The additional 10,000
facilities from State "X", for example, are likely to include
about the same percentage of permitted facilities or an even
lower percentage (since if these facilities had permits they
probably would have been included in the original data set). The
additional 10,000 facilities are also likely to have about the
same or an even lower percentage having monitoring systems,
release prevention management systems, etc. for the same reason.
Thus, overall conclusions and observed trends (such as the fact
that few facilities have monitoring systems) are not likely to be
changed as a result of additional data collection efforts.
4. Most States and Territories are conducting
Subtitle D programs that do not address the full
spectrum of Subtitle D facilities and activities,
State programs directed the largest portion of the
total hours spent on Subtitle D activities in 1984 towards
175
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surveillance and enforcement, yet only 30 percent of the
facilities were inspected in 1984. The second most frequent
Subtitle D activity reported by the States was
permitting/licensing (with the majority of the States requiring
that Subtitle D facilities be permitted), yet only half of all
facilities were permitted. These two areas are the ones that the
States indicated would improve the most if additional resources
were available. Of the 48 States that allocated hours by
activity, only 30 directed any time to training and only 16
directed time to research.
During the telephone followup, many respondents
reported that it was difficult or impossible to inventory some
Subtitle D facilities and activities. Most States have more than
one agency with responsibility for the same facilities (e.g., one
agency responsible for permitting and another agency responsible
for inspections). At the same time, there are facilities for
which no agency has responsibility (e.g., some industrial waste
facilities on-site where generated). Attempts to coordinate
activities between agencies are difficult, with the end result
that some types of facilities (in particular, municipal
landfills) are being monitored more thoroughly than other types.
With the current array of Subtitle D programs, it would
be difficult for many of the States and Territories to develop a
complete inventory of Subtitle D facilities, carry out permitting
programs that ensure the evaluation and approval of all
facilities prior to operation, and include the inspection of each
facility on a regular basis.
176
-------
5. The frequency of occurrence of groundwater,
surface water, and air contamination in Subtitle D
facilities appears to be significant. However.
additional research efforts are required to
determine the severity of contamination at
Subtitle D facilities, since it cannot be
determined from this study.
State and Territorial inspection programs resulted in a
total of 1,463 groundwater, 1,793 surface water, and 1,185 air
contamination violations in 1984. What makes these numbers
significant is that only 5 percent of all Subtitle D facilities
had groundwater monitoring systems, only 15 percent had surface
water monitoring systems, and less than 1 percent had air
monitoring systems. Furthermore, 23 percent of all landfills
with groundwater monitoring systems were found to have
groundwater contamination, 6 percent of all land application
units with monitoring systems were found to have groundwater
contamination, and 9 percent of all surface impoundments with
monitoring systems were found to have groundwater contamination
in 1984.
The relative severity of "contamination" cannot be
determined from this study, however, as each State and Territory
was asked to use that definition of contamination that best
applied to their own State/Territorial regulations. In order to
determine the severity and potential impacts to human health and
the environment of groundwater, surface water, and air
contamination, additional research would be required.
6. Increased resources for State and Territorial
Subtitle D programs is necessary to address the
full spectrum of Subtitle D facilities and
activities.
177
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The present funding levels for State and Territorial
Subtitle D programs are not supporting comprehensive programs
encompassing the full spectrum of Subtitle D facilities and
activities. Respondents reported that if additional funds were
available, they would expect to see the most improvement in the
areas of surveillance/enforcement and permitting/licensing.
Increased funding would allow for activities such as permitting
more Subtitle D facilities prior to operation, and the inspection
of more facilities on a more frequent basis.
178
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APPENDIX A
LANDFILL CAPACITY PROBLEMS
-------
APPENDIX A
LANDFILL CAPACITY PROBLEMS
As part of the Landfill Section of the State Subtitle D
Program Questionnaire, the States were asked to respond to the
following:
"Please describe any local, regional, or statewide landfill
capacity problems in your State."
The responses are listed below, alphabetically, by State.
Alabama. Many of the landfills are reaching capacity. Very
difficult to site new landfills due to technical requirements and
public opposition.
Alaska. There is no capacity problem in Alaska as far as space,
but in most areas the soil and topography are not suitable for
landfills (wetlands and permafrost) due to the climate.
American Samoa. The existing landfill on the island of Tutuila
is rapidly approaching capacity. With limited useable land,
alternate methods of municipal waste disposal may have to be
used, e.g., incineration, waste transfer to other islands.
Arizona. It is getting more difficult to site new landfills and
this is causing a problem especially in the Phoenix Area,
Maricopa, & Mojave Counties. Also, much of the land is federally
owned and is leased on a highest bidder basis. Many of the
area's lands are going back to. private companies and this is
causing problems siting landfills.
A-l
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Arkansas. A few individual landfills are reaching capacity but
no problems are foreseen in finding new locations. This is
primarily due to a 1974 Arkansas ruling which said that landfills
can only be turned down because of physical criteria siting
problems but not public opposition. Additionally, zoning
regulations are not restrictive in siting new landfills.
California. Most urban areas have capacity for only
approximately 20 years—need to expedite planning for future
capacity.
Colorado. There are 6 landfills which service the greater Denver
metropolitan area. Within the next three years, two with a
possible four landfills may close. At the present time, there
are no new landfills proposed to replace these facilities. If no
new landfills are permitted, the Denver area may face a critical
shortage of landfill space.
Connecticut. The State of Connecticut is approaching a statewide
capacity shortage, estimated to become critical in late 1988.
Currently, 50% of the state's solid waste is going to 9 major
regional landfills. These sites will all reach their permitted
capacity at about the same time because the waste flow is easily
diverted to the few remaining landfills. No new municipal waste
fills have been permitted in Connecticut since 1978. The
permitted landfills will be used up before the planned resource
recovery projects are in operation.
Delaware. No capacity problems. Increased volume at landfills
in Kent and Sussex County would allow economic resource recovery
A-2
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facilities to be built (similar to the one presently operating in
New Castle County).
Florida. An evaluation of current and projected population
growth in Florida indicates a need for an estimated equivalent
2,700 acres of additional landfill area, annually, through year
1995.
Georgia. Gwinnet County, Fulton County, Douglas County, Cobb
County. The above counties are located in the Atlanta area and
have problems locating and zoning new sites due to public
opposition. All have limited remaining landfill capacity at
existing sites.
Guam. Single municipal landfill owned and operated by Government
of Guam will reach capacity in 1-2 years.
Hawaii. Statewide: shortage of suitable and available sites (no
community opposition) for landfills is the major concern of all
the counties. Except for the City and County of Honolulu, the
amount of refuse generated per day on each of the counties is too
small to consider refuse-to-energy as an aletrnate method of
refuse disposal. City and County of Honolulu: the three
municipal landfills are rapidly approaching their capacities; the
two smallest landfills will be closed within 18 months and the
largest within 3 years. The city is finalizing a contract with a
private firm to design, construct, and operate a refuse-to-energy
(RFD) plant.
Idaho. Approximately 12 landfills are in need of replacement due
to capacity problems, 8 of which are the major or only landfill
for the counties in which they are located.
A-3
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Indiana. Please see attached map. (Map shows estimated lifetimes
of all landfills in indiana.)
Iowa. No significant landfill capacity problems at this time
statewide. Local capacity problems usually result in landfill
expansion at nearby sites.
Louisiana. Lack of permitted disposal facilities for oil field
waste encourages illegal dumping.
Kansas. None.
Kentucky. No response.
Maine. Some small communities, particularly those in the more
remote areas not serviced by regional or commercial landfills or
resource recovery projects, are in need of regional solutions.
Many small municipal sites have little remaining capacity.
Maryland. Calculating the total disposal capacity for the state
would be misleading. Each of the 23 Maryland Counties and
Baltimore City is responsible for providing landfill capacity for
its residents. This capacity at present ranges from less than
one to more than 25 years. There is no programmatic mechanism
for moving waste from an area with a capacity shortage to an area
with a capacity surplus. The Draft State Solid Waste Plan found,
in early 1985, that eight of the 24 jurisdictions had less than
five years disposal capacity under permit.
Massachusetts. The capacity of Massachusetts' active landfills
is actively running out. [Plus an additional page of text.]
A-4
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Michigan. The capacities for solid waste disposal areas are
addressed as part of the solid waste management plans which are
required to be developed pursuant to act 641.PA1978. The plan
requires each county to identify disposal sites which will accept
solid waste generated within their political boundaries for a 5
year period. The plans are to be updated every 5 years with new
sites identified as necessary.
Minnesota. Many landfills have 5 years or less for capacity and
some disposal option will be needed. However, we are stressing
reuse of the waste and will need less capacity. Other landfills
have as much as 20-40 years left.
Mississippi. Within 5 years only about 5% of our landfills in
Mississippi will need new sites. We expect more recycling and
incineration. In general there are no landfill capacity
problems.
Missouri. No response.
Montana. Statewide many of the existing landfills are nearing
capacity. In general it is very difficult to obtain new sites
for landfills.
Nebraska. One municipality (pop 18,000) has been unable to site
a landfill and is transferring refuse 50 miles to another site.
One major landfill has less than two years remaining life with no
known effort to find a replacement at this time. Another major
landfill with about the same remaining life serves 180,000
people. The city involved is seeking a new site.
A-5
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Nevada. None at this time.
New Hampshire. Many landfills are reaching capacity. Also a
large number have shown leachate breakouts and are under closing
orders. As a result, many towns are opting for refuse-to-energy
facilities.
New Jersey. Capacity problems are very severe across the state.
Siting due to public opposition is the largest contributing
factor to the capacity problem.
New Mexico. There are currently 61 landfills on federal land and
12 on state land. Both entities have told the landfills that as
leases expire to find new land or purchase the existing land at
current market rates. Communities either do not have the funds
for purchase or no other land is available or suitable. Also the
"not in my backyard" syndrome is beginning to come forth in New
Mexico.
New York. No response.
North Carolina. The biggest issue facing landfill operators is
economic considerations needed to construct and maintain landfill
facilities. With stringent rules in place for protection of the
environment, new techniques and technologies are mandated for
protecting the environment.
North Dakota. There are no capacity problems at this time in
North Dakota.
Northern Marianas. The only solid waste facility at the present
time is an open dump and although there are no capacity problems
A-6
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we are looking for a new site for a landfill. We hope to find a
suitable site in the not too distant future.
Ohio. There are 41 counties (out of 88) that will reach landfill
capacity within four years. These are major municipal landfills
that accept general solid waste (in the 41 counties).
Oklahoma. Almost every area of the state experiences some
landfill capacity problems. The primary problem facing the
state, however, is the lack of new landfills. Rising costs of
operation, more stringent permitting requirements, and increasing
public opposition has caused many landfills to close at capacity
and not permit new sites.
Oregon. Unable to estimate. Most areas of state have at least 5
years remaining life. The Portland Metropolitan Area with over
one half of the state population has less than 4 years life with
no new site identified. The Portland Metropolitan Area landfill
that serves 4 counties is scheduled for closure in 1989. We are
looking for a new site but have not found one yet. By July 1987
they hope to find a site. Rest of state has no real capacity
problems.
Pennsylvania. Problems in landfills are especially acute in
Southeast Pennsylvania. This is primarily because of three
factors: 1) closure of "full" landfills; 2) closure of
substandard landfills; and 3) public resistance. The Delaware
and Lehigh Valleys have only a 2-3 year capacity 'and include 40%
of the state population. Overall, the state has an estimated
landfill capacity of about 6 years.
A-7
-------
Puerto Rico. The landfill capacity problem is enormous in all
Puerto Rico. Almost all of the landfills operating in the
Commonwealth are at the last portion of their useful life. Since
Puerto Rico is a small island characterized mainly by high
population densities and surface water bodies throughout all the
country, it is very difficult to obtain additional land for
landfill expansion or relocation. Therefore, this critical
problem will only be solved by looking toward other solid waste
alternatives (such as incineration).
Rhode Island. Many landfills nearing capacity. Three landfills
active in 1984 have closed.
South Carolina. Eight to 10 sites need additional acreage within
the next year and two of these sites are at capacity right now.
South Dakota. There are no existing capacity problems in South
Dakota.
Tennessee. The urban areas, due to population densities,
property of adequate acreage, and approvable geology, are
difficult to acquire. The public pressure to reject siting is
also a factor. This situation is acute in the Middle Tennessee
Area as geologically approvable sites are so difficult to locate.
Texas. Replacement landfills in most urban areas are coming
under increasing public opposition. This has significantly
increased the time required to process a permit which diverts
resources from other applications and causes an ever increasing
backlog in permit evaluation.
A-8
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Utah. Capacity is not a big problem but there are some localized
problems with siting, especially in the industrial landfills
which are in heavily populated areas and don't want to haul waste
long distances.
Vermont. The Vermont Agency of Environmental Conservation
recognizes two regional solid waste (i.e., landfill) capacity
problems. Both regions lack landfill volume to dispose of solid
waste generated within the region. Solid waste must be
transported excessive distances to approved landfills. New
landfills are not being developed due to lack of acceptable land,
lack of resources to develop landfills and/or regulations. One
region has committed to an alternative disposal method, which has
not been implemented due to regulatory and environmental issues.
A state wide capacity problem has also been identified.
"Approved" solid waste disposal capacity project for the year
1990 is estimated to be 573,000 cubic yards to dispose of a
projected 983,000 cubic yards of solid waste.
Virginia. Public resistance to siting of new facilities has
caused delays in providing new facilities. Therefore, many
landfills are near full and some are in heavily populated areas.
Some municipal governments have moved to resource recovery
facilities or contracted disposal as an alternative.
Virgin Islands. No response
Washington. There are no capacity problems now but rather siting
problems for the future for new locations especially in the
metropolitan areas of Spokane and Seattle. Lack of sites and
appropriate land to build landfills is primarily due to public
resistance and lack of necessary geographic locations. Planning
A-9
-------
is being done for other methods of disposal such as resource
recovery and burning.
West Virginia. 1) Approximately 50% of municipal solid waste
generated in west Virginia is disposed at unpermitted facilities;
2) approximately 50% of permitted sites within 3 to 5 years of
exhaustion of space/capacity; 3) northeast area of West Virginia
has had severe flood damage to solid waste disposal facilities;
4) older permitted sites were designed without adequate
consideration of capacity; 5) we believe we will have a 70%
shortfall of capacity in 3 to 5 years if something is not done to
improve conditions.
Wisconsin. Capacity problems are mostly short-term and
localized. Long-distance hauling sometimes needed on an interim
basis. Replacement (new or expanded) landfills are being sited
in state at rate of about 10-20/year. State siting process is
the same for both new and expanded landfills. It is a long
process (2-5 years), but does allow siting to take place.
Wyoming. A few areas of tHe state now have capacity problems,
mainly Teton County, near Yellowstone, which is having a problem
siting a landfill. The Federal Bureau of Land Management is no
longer leasing land cheaply and in the next ten years siting will
be a statewide problem.
A-10
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APPENDIX B
LANDFILL TIPPING FEES
-------
Appendix B
LANDFILL TIPPING FEES
Respondents were asked to report the typical landfill
tipping fees across their state. Non-sludge typical tipping fees
are presented on a per ton basis in Table B.I and on a per cubic
yard basis in Table B.2 for the same facility types. Typical
tipping fees for sludges for municipal, industrial, demolition
debris and other landfills are presented on a per ton basis in
Table B.3 and on a per cubic yard basis in Table B.4. The number
of states which provided responses to this question is low and
the averages displayed in the table below may not be
representative of most landfills.
Table B.I. Tipping^fees for non-sludge solid waste in dollars
per ton
Typical
tipping fees Range
Landfill type (per ton) (per ton)
Municipal waste $12.38(19) $2.00(16) to $45.00(20)
Industrial waste $14.96( 4) $1.00( 4) to $50.00( 4)
Demolition debris only $11.50( 7) $1.00( 5) to $50.00( 7)
Other $ 6.25( 2) $1.00( 1) to $24.00( 2)
Numbers in parentheses beside each estimate indicate the
number of states/territories responding.
B-l
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Table B.2. Tipping fees for non-sludge solid waste in dollars
per cubic yard
Landfill type
Typical
tipping fees
(per cu. yd.)
Range
(per cu. yd.)
Municipal waste $2.11(10)
Industrial waste $2.50( 3)
Demolition debris only $2.06( 4)
Other $ ( 0)
$ .50( 9) to $10.00(10)
$1.00( 3) to $10.00( 3)
$1.00( 4) to $10.00( 4)
$ ( 0) to $ ( 0)
Numbers in parentheses beside each estimate indicate the
number of states/territories responding.
Table B.3. Tipping fees for sludges in dollars per ton1
Landfill type
Typical
tipping fees
(per ton)
Range
(per ton)
Municipal waste
Industrial waste
Demolition debris only
Other
$11.98(10)
$11.82( 3)
$40.00( 1)
$ 2.50( 1)
$ 4.50(10) to $45.00(10)
$ 4.00( 3) to $25.00( 3)
$10.00( 2) to $72.00( 2)
$ 1.00( 1) to $ 3.50( 1)
Numbers in parentheses beside each estimate indicate the
number of states/territories responding.
B-2
-------
Table B.4. Tipping fees for sludges in dollars per cubic yard'
Landfill type
Typical
tipping fees
(per cu. yd.)
Range
(per cu. yd.)
Municipal waste $5.75(5)
Industrial waste $3.50(2)
Demolition debris only $1.38(1)
Other $ (0)
$1.50(5) to $12.00(5)
$1.00(2) to $ 8.00(2)
$1.00(1) to $ 1.75(1)
$ (0) to $ (0)
Numbers in parentheses beside each estimate indicate the
number of states/territories responding.
B-3
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APPENDIX C
EXHIBITS
-------
-
P
Exhibit C.I EPA Cover Letter
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
[ADR]
Dear [Name]:
The recently enacted Hazardous and Solid Waste Amendments
(HSWA) of 1984 require significant changes to our current
solid and hazardous waste regulatory program and mandate the
completion of numerous studies. Section 302 of HSWA requires
that the Environmental Protection Agency (EPA) complete a study
addressing the adequacy of the current Federal Subtitle D (i.e.,
non-hazardous waste) standards in protecting human health and
the environment from ground-water contamination. The current
standards are entitled, "Criteria for Classification of Solid
Waste Disposal Facilities and Practices" and are found in 40 CFR
Part 257. EPA must submit the results of this study in a report
to Congress by November 8, 1987. In addition, EPA must revise
these standards by March 31, 1988, for facilities that may
receive household hazardous waste or small quantity generator
hazardous waste.
Enclosed is EPA's State Subtitle D program questionnaire.
We request your cooperation in completing this survey. This State
Subtitle D Survey is one of several projects EPA has initiated
to gather the data necessary to carry out the above Congressional
mandates. This survey addresses critical data needs related to
State Subtitle D programs (e.g., resources, regulations, etc.)
and characteristics of Subtitle D landfills, surface impoundments,
and land application units.
The enclosed questionnaire has been reviewed extensively
within EPA and by an Association of State and Territorial Solid
Waste Management Officials (ASTSWMO) Subtitle D Study Work Group,
which consisted of representatives from seven States. ASTSWMO's
support is expressed in the enclosed letter. The questionnaire has
C-l
-------
Exhibit C.I EPA Cover Letter (continued)
also been reviewed and approved by the Office of Management and
Budget. Further, the questionnaire has been pretested in nine
States by having those States complete the forms. Each State was
then contacted to discuss any problems that were encountered in
providing the requested information. Our goal in using this
rigorous approach to develop the questionnaire was to include only
critical questions, eliminate wording ambiguities, and make the
instructions as clear as possible.
The enclosed questionnaire is divided into four parts:
State organization and resources, landfills, land application
units, and surface impoundments. We divided the questionnaire
in this way to make it easier to distribute to other groups in
your State that may have responsibility for the specific subject
areas addressed. For your convenience, we have enclosed a master
copy and three extra copies of the questionnaire. If you need
additional copies, please contact Westat, Inc., who is under
contract to administer the survey, toll-free at (800) 638-8985.
Please return the completed master copy of the questionnaire
in the enclosed return envelope by Friday, November 8, 1985.
We urge you to begin work on the questionnaire as soon as possible
because coordinating its completion will likely take considerable
time. If you have any specific questions when completing the
questionnaire, please do not hesitate to call the EPA Subtitle D
specialist at Westat, Inc., at the toll-free number provided
above. If you need additional time, or have general questions
on the purpose or use of the survey, please contact Mike Flynn
(202-382-4489) of my staff.
Obviously, it is very important that you complete the ques-
tionnaire to the best of your ability and describe the situation
in your State as accurately as possible. The information you
provide is critical in defining the current status of Subtitle D
facilities and State Subtitle D programs. We will provide ASTSWMO
with a copy of the raw data and work closely with them in developing
the survey report. Of course, we will provide you with a copy
of the survey report when it is completed.
Again, thank you very much for your cooperation.
Sincerely,
%'1'J
'/'/ UA
Jbhn H. Skinner
Director
/ Office of Solid Waste
Enclosures
C-2
-------
ouuno
Exhibit C.2 ASTSWMO Cover Letter
Association of State and Territorial Solid Waste Management Officials
444 North Capitol Street, N.W .Washington, D C 20001 .202-624-5828
August 30, 1985
Dear State Colleague:
As chairman of the Association of State and Territorial Solid Waste
Management Officials (ASTSMO) workgroup on the Subtitle D survey, I,
along with my fellow workgroup members, join with the U.S. Environmental
Protection Agency in providing you with the Subtitle D survey of
non-hazardous solid waste facilities.
The group was formed in order to work with USEPA in the development
of the questionnaire. Three meetings were held with USEPA staff over
the months of April and May of this year to review and discuss the draft
survey instruments. The workgroup represented a cross-section of
states. In addition to my own state of Connecticut, the states of
Arkansas, California, Georgia, Maryland, New York and Texas participated
in the survey development.
Draft surveys were evaluated on the basis of the kinds of
information available within our respective states on Subtitle D
programs. Revisions to the questionnaire were recommended so that the
data requested corresponds, to the extent possible, with the types of
information compiled by state agencies.
Each successive draft of the survey incorporated changes suggested
at the prior meeting of the ASTSWKO/EPA workgroup. We appreciate
USEPA's responsiveness to our concerns and comments. Following a
decision by our Board of Directors, USEPA has agreed to provide ASTSWMO
with copies of the raw data from the surveys for our own information on
the status of state Subtitle D programs.
The attached survey represents a joint effort on the part of
ASTSWMO and USEPA, and we join with USEPA in transmitting the survey to
you.
Sincerely,
Charles Kurker, CT
Chairman
ASTSWMO Subtitle D
Workgroup
C-3
-------
APPENDIX D
STATE SUBTITLE D PROGRAM QUESTIONNAIRE
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
State Subtitle D Program Questionnaire
August 30, 1 985
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
State Subtitle D Program Questionnaire
GENERAL INSTRUCTIONS
-------
GENERAL INSTRUCTIONS
PLEASE READ THE FOLLOWING INSTRUCTIONS BEFORE YOU BEGIN TO FILL OUT THE
QUESTIONNAIRES ENCLOSED IN THIS PACKET. IF YOU SHOULD NEED FURTHER
ASSISTANCE, INFORMATION ENABLING YOU TO MAKE THE APPROPRIATE CONTACTS IS
PROVIDED AT THE END OF THESE INSTRUCTIONS.
OVERVIEW OF JHE SURVEY
Your cooperation in this survey will enable EPA to evaluate the
effectiveness of its RCRA Subtitle D waste guidelines (40 CFR, Part 257) as
implemented by the States. These Subtitle D guidelines govern "non-hazardous"
wastes not covered by Federal Subtitle C hazardous waste regulations. The
survey will be completed by all U.S. States and Territories. The data
collected through this survey will be factored into a series of economic and
environmental analyses designed to determine the effectiveness of current
guidelines and regulations and to recommend measures to Congress that would
improve the effectiveness of regulating Subtitle D wastes.
In order to minimize the burden imposed by this information
collection effort, we have developed the questionnaire design in close
cooperation with members of the State and Territorial Solid Waste Management
Officials (ASTSWMO) and have limited the scope of this survey to EPA's most
critical information gaps. By working with ASTSWMO members, EPA was able to
eliminate many questions that would have been difficult and time-consuming
to answer. The responses you provide will contribute to the computation of
much-needed nationwide estimates and to the formulation of EPA's recommenda-
tions to Congress.
-------
THE QUESTIONNAIRE
A four-pact questionnaire has been developed for this effort in
recognition of the fact that responsibilities for the Subtitle D program are
diverse and are often split between State or Territorial agencies, offices,
or individuals. The separate parts are:
. PART I - STATE ORGANIZATION AND RESOURCES;
PART II - LANDFILLS;
. PART III - LAND APPLICATION UNITS; and
• PART IV - SURFACE IMPOUNDMENTS.
Part I of the questionnaire contains budget and human resource
questions. Parts II, III and IV each contain questions in six information
areas:
• Regulations;
• Enforcement;
• Number of Units and Numbers of Establishments;
• Design and Operating Characteristics;
• Availability of Data; and
• Contact Information.
USE OF THE QUESTIONNAIRE
The questionnaires used for this survey have been designed to
minimize the effort required for their completion. Great care has been
taken to eliminate wording ambiguities and to make the instructions as
explicit as possible. We hope you will find that by carefully following all
of the instructions (in capital letters) you should encounter few, if any
difficulties. However, if you do have difficulty, a toll-free assistance
number is provided at the back of these General Instructions.
-------
EXAMPLES OF QUESTIONS
Most of the questionnaire items are straightforward and require
only the circling of the correct code(s) or the completion of short answers
on the lines which are provided. The following examples illustrate the use
of other question formats found throughout the questionnaires.
Example A
Some questions require that you code a "yes" or "no" answer for
each method listed, as indicated in the sample question below. Notice also
that in subquestion d, the "Other [Specify]" line enables you to enter a
type not covered by the preprinted response categories. Some questions also
leave space for comments as in the example below. More often, however,
space for comments is provided at the end of each questionnaire part, or you
may add attached sheets.
S3. In the table below, indicate whether your Stat* currently requires permits, plan approval
or licenses/registration for each of the listed types of Subtitle 0 landfills. [PLEASE
CIRCLE EITHER "1" OR "2" FOR EACH TYPE OF LANDFILL FOR BOTH PERMITS AND LICENSES.]
Lanafill tvpe
d. Other [SPECIFY]: ic^dPlllS ^ta^ Ofll1/ rgC£IV4
M u n i d Pa ) cgujaag. cjudse •rronv RDTw'S
_i J
A.
Permit or
plan approval
required?
Yes No
O 2
ro 2
V_i' '
1 (?)
\£s
' 0
8.
License or
registration
required?
Yea No
,
Vj^
(^ •>
^—^
-. ^)
'c>
0 2
^
COMMENTS: [PLEASE EXPLAIN IF PERMIT REQUIREMENTS VARY WITHIN ANY OF THE ABOVE CATEGORIES,
E.G. - SOME INDUSTRIAL WASTE LANDFILLS REQUIRE PERMITS AND OTHERS DON'T]
(tO P&rm'ite are, reuired
3
-------
Example B
Some questions require a number to be entered. Please make certain
that the detailed data add up to the totals, and that these totals are con-
sistent with previous answers as in the sample questions below. If the
answer is zero, enter "0." DO NOT LEAVE IT BLANK.
J1 . During 19B4, how manv individual Subtitle 0 Land -application units were active in your
State? (For the purpose of the questions in Section 0, the term "active" means "received
waste in 1984.")
WMBER OF ACTIVE
INDIVIDUAL SUBTITLE D
LAND APPLICATION UNIT5 IN 1984: 3^
J2. In the table below, please enter the numoer of active individual Subtitle 0 land applica-
tion units in 1984 in each of the following categories.
Land application unit t/pe
e. Other [SPECIFY]: dflAktrXG WC.^1< "t"T£C.Vv* < A ^
j
Sluice, onlv
e. TOTAL SHOULD EQUAL RESPONSE TO QUESTION J1 :
Number of active
individual Subtitle 0
land application units
in 1984
K/A
A/A
20
=)
0
\
30
* IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEHACE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOU APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS ON
LINE a+b.
- 4
-------
Example C
Some questions require a percentage to be entered. Please answer
in the nearest whole percentage (i.e., do not use fractions or decimals).
Also make sure your percentages add up to 100 percent as in the example
below.
AA. Khat percentage of your State's total Subtitle 0 budget for fiscal years 1984 and 1985
can* fro* the follo«ing sources: [ENTER THE PERCENTAGE RECEIVED FROM EACH FUNDING SOURCE
FOR EACH YEAR. THE TOTAL OF THE PERCENTAGES FOR EACH YEAR SHOULD EQUAL 100S]
Funding source
b. Federal sources (please include any
Subtitle D related funding for water
d. Other [SPECIFY]:
TOTAL OF LlfCS a. b, c AND d FOR EACH
Fiscal
year
ending
in
1984
9H «
S »
f s
o -,
Fiscal
year
ending
in
1985
99 5
O s
i «
0 *
1005 100S
SKIP INSTRUCTIONS
Skip instructions indicate the next question to be answered. They
save time by allowing you to ignore irrelevant questions. When you encounter
a skip instruction, continue on with the question indicated in the instruction.
The following is an example:
R4. Does your State already have a liat (or file) of establishments with Subtitle 0 surface
mpoundiranta?
Yea [GO ON TO QUESTION R5] 1
No [SKIP TO QUESTION 51] 2
-------
PLEASE CONTINUE
-------
MAKING ESTIMATES
Some questions may require data that are not available or not
known precisely. DO NOT LEAVE THESE BLANK. In these cases, please enter
your best estimate of the data and indicate your assessment of the data
quality by entering and circling one of the following letters after your
answers. USE THE SYMBOLS BELOW WHENEVER YOU ARE ESTIMATING AN ANSWER.
(VI> =
Good estimate (i.e., probably within + 10%)
Fair estimate (i.e., probably within +_ 25%)
Poor estimate (i.e., probably within + 50%)
Very Poor estimate (i.e., probably not within + 50%, or you
don't have any idea how good the estimate may be)
In the example below, subquestions b through f of Question P2 have been
estimated and the data quality indicated. Subquestion i is also an estimate
and should be entered in an identical manner in Question PI. Subquestions
a, g, and h are known exactly and need no symbols.
PI. During t*«4, now a«ny individual SiAtlUe 0 turf me* \*aHnmmt» ~tm ertAy* in your
St»te? (far Uie purpose af aw queetlone ui Section 0, the Item "active" Mine, 'r»c«
<••!• in 1994.')
*CTIVC
INDIVIDUAL suanrte o
3JHFACE IHTOUNOCNIS LH 1984 1
7O
©
PI. In th« UC1* Ml(M, pl*i«« *tt*r
ACS in 1984 in Men af
Surface LAOoifMMene type
v
NijBcr of active
inaividuti SUititle
surface laoounoent
in 1984
s — v
0
i
b. *nxcip«i seweoe aluoge
c. •**ncio«,
, a. Inaujcrial «eatt.
Hininq nMstt
1 7. Gil or g*» «a*te
.. *O:AL SHOULD CGUAL BESPOKE ra CIZSTION 01 :
/9C
^O-C^'
/ o 10
-------
DIAGRAM
ABC Co. Plant
ABC Co. Plant
'LF • (Demolition Debris)
LF »*]
,v.( Asbestos)
(Industrial
Vaste)
f-f'f'f'f'f'f'f'J
Industrial
Vaste Surface ^>
Impoundment *4
*^.
S-S"%*%.
,^?i*
WsW*
,%S?w
sWslTs'
%w%w
>»^-*"-^-«
.^•1-»^*^
KEY
SI = Surface impoundments
LF = Landfill
Hazardous Vaste
Landfills
. .'N'S'S'S'S'S',
•;ir;iLand/£;;
Application
k:ynir*Y;;;
(Industrial
^Wastes)^
fs's's's^S^N^
Landfill
(Municipal
; Sludge)
^^
s
^^
Landfill v
(Municipal!
Sludge) N>
. •* *
Application
?;Uni"t"*Zsj
(Drinking-!
£ Water-;};
Treatmentj
' f ''.• •',• :,- '',• i
sWtftftftftf-
Collection Pond
Surface Impoundment
Central City Dump
-------
DEFINITIONS
It is important in this survey to pay strict attention to the definitions
provided below. If the definitions appear ambiguous or incomplete, please
use the toll-free assistance number given at the back of these General
Instructions before filling out this questionnaire, and use the Comments
section at the end of each part of the questionnaire to describe the diffi-
culty. A diagram has been provided on the facing page to help clarify the
definitions below.
ESTABLISHMENT - A single physical location where business is conducted
or where services or industrial operations are performed by a munici-
pality, corporation, or other public or private entity. An establish-
ment may have one or more landfills, land application units, and
surface impoundments. [NOTE: The diagram shows three establishments
— (1) ABC Company, Plant #1; (2) ABC Company, Plant #2; and (3) Central
City Dump. Plant #1 and Plant #2 are two separate establishments even
though they are under the same ownership because they are at two separate
(non-contiguous) locations.]
LANDFILL - A part of an establishment at which waste is placed in or
on land and which is not a land application unit, a surface impoundment,
an injection well, or compost piles. [NOTE: The diagram shows a
total of six landfills — four in Plant fl, one in Plant #2 (the
hazardous waste landfills are not counted), and one in the City Dump.
The contiguous landfills in Plant #1 are counted separately because
they are discrete units with different types of waste. The contiguous
landfills of Plant #2 and the City Dump are counted separately because
they have different owners.]
Municipal Waste Landfill - A landfill that primarily receives
household refuse and commercial waste. It may also receive a
limited amount of other types of Subtitle D wastes, such as
municipal sewage sludge and industrial wastes.
Industrial Waste Landfill - A landfill that primarily receives
waste from factories, processing plants, and other manufacturing
activities.
Demolition Debris Landfill - A landfill that receives only
construction or demolition debris (e.g., debris from the con-
struction or demolition of bridges, highways, or buildings),
brush, stumps and rubble.
Other Landfill - A landfill receiving Subtitle D wastes that does
not not fall into any of the above categories (e.g., a landfill
that receives only municipal sewage sludge).
-------
LAND APPLICATION UNIT - A part of an establishment at which waste is
applied onto or incorporated into the soil surface for the purpose of
beneficial use or waste treatment and disposal. Land application is
often referred to as landfarming or landspreading. Specifically
excluded from this definition are manure spreading operations. [NOTE:
The diagram shows three land application units — one in Plant #1 and
two in Plant #2. In Plant #2, the land application units are contiguous
but counted separately because they are discrete units with different
types of waste.]
Municipal Sewage Sludge Land Application Unit - A land application
unit that primarily receives sewage sludge from publicly-owned or
privately-owned domestic sewage treatment facilities, including
sludge from domestic septic tanks. [NOTE; Do not include muni-
cipal wastewater land application units in this category — these
are not included in the scope of this survey.]
• High Application Rate Units - Municipal sewage sludge land
application units where the application rate exceeds the
nutrient needs of crops. These units may be used for reclama-
tion of disturbed lands, waste treatment or disposal.
• Low Application_Rate Un^ts - Municipal sewage sludge land
application units where the application rate is based on crop
nutrient needs.
Industrial Waste_Land Application Uni t - A land application unit
that primarily receives waste (including sludge or wastewater)
from factories, processing plants, and other manufacturing or
commercial activities.
Oil or Gas Waste Land Applicatj.on Unit - A land application unit
that receives waste, such as drilling muds, generated by oil or
gas exploration and extraction operations.
Other Land Application Unit - A land application unit receiving
Subtitle D wastes that does not fall into any of the above
categories (e.g., a drinking water treatment waste land appli-
cation unit) ..
STATE - Any of the 50 states, the District of Columbia, the Commonwealth
of Puerto Rico, the Virgin Islands, Guam, American Samoa, or the Common-
wealth of the Northern Mariana Islands.
SURFACE IMPOUNDMENT - A part of an establishment which is a natural
topographic depression, man-made excavation, or diked area formed
primarily of earthen materials (although it may be lined with man-made
materials) that is designed to hold an accumulation of liquid wastes
or wastes containing free liquids. Treatment, storage, and disposal
surface impoundments are included. Surface impoundments are often
referred to as pits, ponds, or lagoons. This definition does not
include any type of tank, including concrete, fiberglass or steel
tanks. [NOTE: The diagram shows five surface impoundments — four in
10
-------
Plant #1 and one in the City Dump. Although Surface Impoundment tl
and Surface Impoundment #2 are joined, they are counted separately
because they are separate depressions. The industrial waste surface
impoundment is counted as a single impoundment although it has walls
or dikes separating parts of the single depression.]
Municipal Wastewater Surface Impoundment - A publicly owned surface
impoundment, commonly known as a sewage lagoon or sewage pond,
designed to provide partial or total treatment for domestic sewage
or a mixture of domestic and industrial wastewater.
Municipal Sewage Sludge Surface Impoundment - A surface impound-
ment that receives sewage sludge from publicly-owned or privately-
owned domestic sewage treatment establishments.
Municipal Run-off Surface Impoundment - A surface impoundment
that is used for the collection of run-off or leachate from
municipal waste landfills or municipal waste land application
units.
Industrial Waste Surface Impoundment - A surface impoundment that
primarily receives wastes from factories, processing plants
(including food processing), and other manufacturing or commercial
activities. Also included in this category are surface impound-
ments used for the collection of run-off or leachate from industrial
or demolition landfills and industrial land application units.
Agricultural Waste Surface Impoundment - A surface impoundment
that only receives waste from agricultural operations, including
farming, crop production, and animal husbandry (including feedlots).
Specifically excluded from this category are surface impoundments
that are used for wastes from slaughter houses, other animal
processing, and food processing, which are included in the "indus-
trial" category.
Mining Waste Surface Impoundment - A surface impoundment associated
with mineral extraction and beneficiation activities such as
crushing, screening, washing, floatation, etc. These minerals
include metallic and non-metallic ores, coals, sand and gravel,
but exclude oil and gas. Specifically excluded are impoundments
used for processing wastes from manufacturing establishments
which are included in the "industrial" category.
Oil or Gas Waste Surface Impoundment - A surface impoundment that
receives waste from oil or gas exploration and extraction, commonly
known as brine pits. Both disposal and emergency brine pits are
included. Specifically excluded are impoundments used for petroleum
refinery wastes, which are included in the "industrial" category.
Other Surface Impoundment - A surface impoundment receiving Sub-
title D wastes that does not fall into any of the above cate-
gories (e.g., a drinking water treatment waste impoundment).
•11
-------
IF YOU NEED HELP
Westat, Inc., a research firm in Rockville, Maryland, is under
contract with EPA to assist in this survey's design and data processing
activities. If you should have a question concerning the completion of a
specific questionnaire item, you may call their Questionnaire Assistance
Center toll-free at (800) 638-8985 and ask for the EPA Subtitle D Specialist.
If you have any general questions about the scope or purpose of this survey,
please call Mike Flynn, (202) 382-4489, of EPA's Office of Solid Waste.
PLEASE BE SURE TO SIGN THE CERTIFICATION STATEMENT AT THE END OF
THE QUESTIONNAIRE.
THANK YOU
12
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
STATE SUBTITLE D PROGRAM QUESTIONNAIRE
PART I - STATE ORGANIZATION AND RESOURCES
(Section A)
IMPORTANT: BEFORE PROCEEDING WITH THIS QUESTIONNAIRE, READ THE
GENERAL INSTRUCTIONS PAMPHLET CAREFULLY INCLUDING THE
DEFINITIONS.
1-1
-------
A. STATE ORGANIZATION AND RESOURCES
The objective of this section is to construct a directory of the agencies in your State that
are responsible for administering Subtitle D waste management programs, and to determine their
level of funding and program emphasis.
A1. In Column A, list all of the agencies with separate budgets in this State that are responsible
for developing, regulating, enforcing, overseeing, and otherwise administering any part of the
Subtitle 0 program. In Column B below, enter the total dollar amount budgeted for each agency
for Subtitle D related work for the fiscal year (FY) ending in 1984. In Column C, please
estimate the total number of person hours that the agency expended on work directly related to
Subtitle D establishments, issues and activities during the FY ending in 1984. In Columns D
through K, please estimate the percent of total hours that were expended in each of the listed
activities during the FY ending in 1984. If you are unable to estimate the distribution of
hours across activities for an agency, put a check (./) on the 55 line for each of the agency's
activities. [DO NOT INCLUDE VACATION, HOLIDAY AND SICK LEAVE HOURS IN COLUMN C. COLUMN C
SHOULD ONLY INCLUDE HOURS WORKED]
A
G
E
N
C
Y
A.
State agency with
separate budget
B.
Total
Budget
for Sub-
title D
work the
FY ending
in 1984
C.
Total
hours
worked
on Sub-
title D
during
the FY
ending
in 1984
D.
E.
Percent of
Planning
Regulation
Development
1
Agency:
Contact Name:
Phone No:
($)
(hours)
Agency:
Contact Name:
Phone No:
($)
(hours)
OS)
Agency:
Contact Name:
Phone No:
($)
(hours)
(X)
Agency:
Contact Name:
($)
(hours)
(X)
Phone No:
IF ADDITIONAL AGENCIES ARE INVOLVED IN THE STATE SUBTITLE D PROGRAM,
CHECK THIS BOX II AND ATTACH ADDITIONAL SHEETS.
1-2
-------
Subtitle 0 program includes:
• Landfills
- municipal waste
industrial waste
- demolition debris
- other Subtitle D
landfill wastes
Land Application Units
- municipal sewage sludge
industrial waste
oil or gas waste
- other Subtitle 0 land
application wastes
• Surface Impoundments
municipal wastewater
- municipal sewage sludge
- municipal run-off
- industrial waste
agricultural waste
- mining waste
- oil or gas waste
- other Subtitle D surface
impoundment wastes
F.
Total Subtitle
G. H. I. J.
D Hours in Each Activity
K. L.
Total percent
(columns D-K
should equal
100%)
Surveillance
and
Enforcement
Other
[SPECIFY]:
Training Permitting Technical
Given Research or Licensing Assistance
OS)
100%
(S)
OS)
OS)
OS)
(S)
OS)
Os)
100%
OS)
OS)
OS)
Os)
OS)
100%
OS)
OS)
OS)
(ss)
Os)
100%
OS)
1-3
-------
A2. Please indicate below how your State defines the fiscal year ending in 1984.
a. Fiscal year ending in 1984: , through , 198A
(month) (year) (month) (year)
A3. Using the agency numbers from question A1 above, please indicate which agency or
agencies have the following responsibilities. If the responsibility is not assigned
to any particular agency indicate by circling NA. [CIRCLE ALL APPLICABLE AGENCY
NUMBERS]
Responsibility Agency Number(s)
LANDFILLS:
a. Subtitle 0 municipal waste landfills 1 2 3 4 NA
b. Subtitle D industrial waste landfills 1 2 3 4 NA
c. Subtitle D demolition debris landfills 1 2 3 4 NA
d. All other types of Subtitle 0 landfills (such as
drinking water treatment waste landfills, or any
other landfills not included in a, b and c above) 1 2 3 4 NA
LAND APPLICATION:
e. Subtitle D municipal sewage sludge land application units .... 1 2 3 4 NA
f. Subtitle D industrial waste land application units 1 2 3 4 NA
g. Subtitle D oil or gas waste land application units 1 2 3 4 NA
h. All other types of Subtitle 0 land application units
(such as drinking water treatment waste land application
units, or any other land application units not included
in e, f, and g above) 1 2 3 4 NA
'1-4
-------
Responsibility Agency Number(s)
SURFACE IMPOUNDMENTS:
i. Subtitle D municipal wastewater surface impoundments 1 2 3 4 NA
j. Subtitle D municipal sewage sludge surface impoundments 1 2 3 4 NA
k. Subtitle D municipal run-off surface impoundments 1 2 3 4 NA
1. Subtitle D industrial waste surface impoundments 1 2 3 4 NA
m. Subtitle D agricultural waste surface impoundments 1 2 3 4 NA
n. Subtitle 0 mining waste surface impoundments 1 2 3 4 MA
o. Subtitle D oil or gas waste surface impoundments 1 2 3 4 NA
p. All other types of Subtitle D surface impoundments
(such as drinking water treatment waste surface
impoundments not included in i through o above) 1 2 3 4 NA
•1-5
-------
A4. What percentage of your State's total Subtitle D budget for fiscal years ending in 1984
and 1985 came from the following sources: [ENTER THE PERCENTAGE RECEIVED FROM EACH FUNDING
SOURCE FOR EACH YEAR. THE TOTAL OF THE PERCENTAGES FOR EACH YEAR SHOULD EQUAL 100%]
Funding source
a. State sources
b. Federal sources (please include any
Subtitle D related funding for water
d. Other [SPECIFY]:
Fiscal
year
ending
in
1984
%
%
V
t*
-------
A6. Please list the other program or programs from which funds are obtained to support
Subtitle D activities:
A7. Please indicate the areas in which Subtitle D program effectiveness would be most improved
by additional resources, by ranking each of the areas listed below 1 through 7 according
to the expected improvement in effectiveness. Use the rank "1" for the area that would
show the greatest improvement, "2" for the area that would show the next greatest improve-
ment, "7" for the area that would show the least improvement, etc. (The areas listed
below are the same areas that were listed in question A1.)
b. Regulation Development
c. Surveillance and
d. Training Given
e . Research
f. Permitting or Licensing....
g. Technical assistance
h. Other [SPECIFY]*:
Rank each area "1" (for greatest improvement)
through "7" (for least improvement) [USE EACH
NUMBER, 1 THROUGH 7 ONCE FOR EACH PROCESS TYPE]*
Landfills
Land Application Units
Surface Impoundments
•IF YOU USE "H Other [SPECIFY]:", PLEASE RANK THE ITEMS ON A SCALE OF 1-8.
1-7
-------
A8. For those areas you ranked "1" and "2" in question A7, please indicate how you would
use the additional resources to improve Subtitle D program effectiveness. [* A LIST
OF SUBTITLE D PROCESS TYPES IS INCLUDED IN QUESTION A3, AND THE DEFINITIONS OF THESE
SUBTITLE D PROCESSES MAY BE FOUND IN THE GENERAL INSTRUCTIONS]
USE OF ADDITIONAL RESOURCES FOR AREAS RANKED "1" IN QUESTION A7:
LANDFILLS ("1");
LAND APPLICATION UNITS ("1"):
SURFACE IMPOUNDMENTS ("1");
USE OF ADDITIONAL RESOURCES FOR AREAS RANKED "2" IN QUESTION A7:
LANDFILLS ("2"):
LAND APPLICATION UNITS ("2"):
SURFACE IMPOUNDMENTS ("2");
A9. How many establishments in your State had active Subtitle D processes (landfills, land
application units, and/or surface impoundments) in 1984? (For the purpose of this
questionnaire, "active" means "received waste during 1984" and "1984" 'refers to the
calendar year 1984. An "establishment" is a single physical location where business is
conducted or where services or industrial operations are performed by a municipality,
corporation, or other public or private entity. An establishment may have one or imore
landfills, land application units, and surface impoundments. An example and explanatory
diagram is included in the General Instructions.)
NUMBER OF ESTABLISHMENTS WITH
ACTIVE SUBTITLE D PROCESSES IN 1984:
1-8
-------
A10. Please estimate the number of establishments that only had inactive or closed Subtitle 0
landfills, land application units, and or surface impoundments in 1984 in your State.
NUMBER OF ESTABLISHMENTS WITH
ONLY INACTIVE OR CLOSED
SUBTITLE 0 PROCESSES IN 1984:
A11. Please identify a contact person for this section of the survey, should it be necessary to
clarify responses:
Contact Name:
Title:
Agency/Program:
Telephone: ( ) Ext.:
A12. COMMENTS - Please include any comments or further amplification of responses to this
section below or on attached sheets.
1-9
-------
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
STATE SUBTITLE D PROGRAM QUESTIONNAIRE
PART II - LANDFILLS
(Sections B-G)
IMPORTANT: BEFORE PROCEEDING WITH THIS SECTION, READ THE GENERAL
INSTRUCTIONS AT THE FRONT OF THIS QUESTIONNAIRE CAREFULLY.
PLEASE PAY SPECIAL ATTENTION TO THE DEFINITIONS BELOW.
LANDFILL - A part of an establishment at which waste is placed in or on land and which is not
a land application unit, a surface impoundment, an injection well, or compost pile.
Municipal Waste Landfill - A landfill that primarily receives household refuse and
commercial waste. It may also receive a limited amount of other types of Subtitle
0 wastes, such as municipal sewage sludge and industrial wastes.
Industrial Waste Landfill - A landfill that primarily receives waste from factories,
processing plants, and other manufacturing activities.
Demolition Debris Landfill - A landfill that receives only construction or demolition
debris (e.g., debris from the construction of or demolition of bridges, highways,
or buildings), brush, stumps and rubble.
Other Landfill - A landfill receiving Subtitle D wastes that does not fall into any of
the above categories (e.g., a landfill that receives only municipal sewage sludge).
II-l
-------
B. SUBTITLE D LANDFILL REGULATIONS
The objective of this section is to gather current information on existing and proposed State
regulations and permits.
81. The table below presents a list of specific requirements for Subtitle D landfills. For
each column A through D, circle code 1 if these requirements are specifically included in
the State regulations. Circle code 2 if these requirements are not specifically included
in the State regulations, but can be enforced under general performance standards or State
policies. Circle code 3 if there are no enforceable requirements. [FOR EACH REQUIREMENT,
PLEASE CIRCLE ONLY ONE CODE FOR EACH LANDFILL TYPE]
Requirements included
in current State
Subtitle D program?
a» Natural <».Q«» cimy} liners
b» Synthetic linete '
c. Jjbcetion standards (e.g.,
floodplains)
d« ieechat* col lection and
«, i*achate crutractetizntion/
j analysis
f. Leachate treatment
g. Groundwater protection
standard'
h. Groundwater monitoring
i. Corrective action for
groundwater contamination
j. Air protection standard
k* Mr emission* monitoring
1. Jfethane «ooitoring
ft* itethsne eeafcrol*
ft. Uwrreetiv* action for off--
" site aethatw migration
•Q. Sueftee water protection
;i stSBxtfctd*
p. Surface water monitoring
q. Corrective action for sur-
face water contamination
r. Run-off collection
and removal
s. Run-off characterization/
analysis
t. Run-off treatment
u» 8fcn>'«oo «ontrolar''"';ss"vrv' ''j:0
v, Restrictions on receipt
of liquid w»at*
*» Reetrictione 00 type*
r^sdtfed - "*** '* ""^
X. Daily covet
y» Endangered species criteria
z. Disease vectors criteria
aa. Safety criteria:
Bird hazards
bb. Safety criteria:
Uncontrolled access
cc. Closure standards
(e.g., caps)
dd. Postclosure monitoring
e« . Financial f e«ponsibility
Landfi
A.
Municipal waste
Specifically
included
in the
regulations
f v /"f &", •*'»&*&
1
t
1
f
1
1
1
1
1
t' /
1
t
f
t
1
1
1
1
1
'' " 1
1
-|
1
t
1
1
1
1
1
1
Enforced
under
general
standards
and
policies
»v - Z. - ,S -
2 ."
2 * '
v - - -2 *
,
". I
2
2
2 .
2
2
•»2
2 *
2
2.
'
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
No en-
forceable
require-
ments
•*
s«svv "•••.•• .% J*fr-ftWfl.>^ Av •
3
5
5 '
3
3
3
3
3
3
3
5
5 '
5
?
3
3
3
3
3
5
5
3
>
5
3
3
3
3
3
3 _
8.
Industrial waste
Specifically
included
in the
regulations
tm*tat»JL -sr- - *
-*y«,-r,
t
t : '
1
1
1
1
1
1
1
1
, 1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
, . 1
Enforced
under
general
standards
and
policies
I
2
2
2,
• ' *»'
'2 ,
2
2
2
2
2
1
2
s> 2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
. . 2 .
No en-
forceabl
require-
ments
- 4 5
~'S '
- t S <.
»
if ^
•• I:-'' "; -
: ?' ;S'V •
3
3
3
3
., ',..,
; f" J1 ..
: ff ^
••• | '5
^
- '4 > •
?
v 3
3
3
3
3
3
.5 > - -
: ,1
; 5. -
,
, ., v*p
: ?
3 .
3
3
3
3
3
,. 3 ....
II-2
-------
IMPORTANT: SEE DEFINITION OF LANDFILL
TYPE ON PAGE II-1.
Types
C.
Demolition debris
Specifically
included
in the
regulations
1
1
- '1
1
;• i " =
1
1
1
1
1
" i
$
1 :
1
1
1
1
1
1
1
jt
1
1
1
t
1
1
1
1
1
v .
Enforced
under
general
standards
and
policies
2
2
2,
'i *
2
"2
2
2
2
2
2
2
2
2
2 „.,
2
2
2
2
2
fr •••'; ' f v. •• j£ .-, •£>•
' *'.'.
.'„ •.x~>"*.<.,.-!-»
2
2
2
2
2
2
2
2
2
only
No en-
forceable
require-
ments
3
3
3
>
5
3
3
3
3
3
$
= *
*
;' 5 "
.3
'3
3
3
3
3
" - ' - 5; ' ;
•-/ r;>-
«1 ,„;,., , . ,,
3
' . 3
5
3
3
3
3
3
3
Other
Specifically
included
in the
regulations
•j
1 ,
' 1
1 >
1 ..'
1
1
1
1
1
1 t
t *
"1
,* •'*
1 x
1
1
1
1
1
' t
t \
t :'
t :
t
1
1
1
1
i
1 -
D.
[SPECIFY]:
Enforced
under
general
standards
and
policies
, 2, ,
2
2
2
, '2
2
2
2
2
2
2
2
2
2
'2 :
2
2
2
2
2
2
2
2-
2
2 :
2
2
2
2
I •
2
No en-
forceable
require-
ments
J ..
?
3
3
J
3
3
3
3
3
5
5
3
3
5
3
3
3
3
3
?
7
5
3
3
3
3
3
3
3
II-3
-------
B2. Please indicate for each landfill type whether the following specific requirements are
included in formally proposed State regulations. [IF THERE ARE NO FORMALLY PROPOSED
REGULATIONS IN YOUR STATE, PLEASE PLACE A CHECK IN THE BOX: | | AND SKIP TO 83.]
Specific requirements included
in formally proposed regulations?
A.
Municipal
waste
Landfill Types
8.
Industrial
waste
C.
Demolition
debris
D.
Other
[SPECIFY]:
liiwra
l*«Bt*altt esJI*ctio« and rawsval
,J^Bh*^:;£h^^
Leachate treatment
Groundwater protection standard
Groundwater monitoring
Corrective action for groundwater
contamination
Air protection standard
Surface water monitoring
Corrective action for surface
water contamination
Run-off collection and removal
Run-off characterization/analysis
Run-off treatment
Sutotitl* $ «*«t*« jr*e»iv*f''
QOWMP- '',- * ,' ;*-' "'. ••.,'.
_ Ijeci^cjritifjpiw^.
Disease vectors criteria
Safety criteria: Bird hazards
Safety criteria: Uncontrolled
access
Closure standards (e.g., caps)
Postclosure monitoring
Financial 1
Yes No
n
f
2,
2
2
2
2
2
Yes No
1 Z
t
1
f
1
1
1
1
1
f
t
t
1
1
1
1
1
1
t'
*
.%
2
2
2
2
2
2
2
2
2
2
2
2
2
Yes
1 2
1 2
1 2
1 • Z
Yes
• t- -
No
t
t
t
1
1
1
1
1
I
2
2
I.
2
2
2
2
2
f;
.11-4
-------
83. In the table below, indicate whether your State currently requires permits, plan approval
or licenses/registration for each of the listed types of Subtitle D landfills. [PLEASE
CIRCLE EITHER "1" OR "2" FOR EACH TYPE OF LANDFILL FOR BOTH PERMITS AND LICENSES.]
Landfill type
d. Other [SPECIFY]:
A.
Permit or
plan approval
required?
Yes No
1 2
1 2
1 2
1 2
B.
License or
registration
required?
Yes No
1 2
1 2
1 2
1 2
COMMENTS: [PLEASE EXPLAIN IF PERMIT REQUIREMENTS VARY WITHIN ANY OF THE ABOVE CATEGORIES,
E.G. - SOME INDUSTRIAL WASTE LANDFILLS REQUIRE PERMITS AND OTHERS DON'T]
B4.
How many of the active individual Subtitle D landfills of each type in your State currently
have permits/approved plans, or licenses/registrations?
Landfill type
a. Municipal waste
b. Industrial waste
d. Other (SPECIFY):
Number of indi-
vidual Subtitle
D landfills that
have permits or
approved plans
Number of indi-
vidual Subtitle
D landfills
licensed or
registered
•II-5
-------
85. la there a written or published schedule of your State's permit fees for Subtitle 0
landfills? [CIRCLE ONLY ONE CODE]
Yes [PLEASE ATTACH A COPY OF THE
FEE SCHEDULE TO THE BACK OF
THIS QUESTIONNAIRE] 1
No 2
N/A (THERE ARE NO LANDFILL PERMIT
FEES IN MY STATE) 3
86. Please attach a copy of your State's Subtitle D landfill regulations (existing and
proposed, if any) to the back of this questionnaire.
II-6
-------
IMPORTANT NOTE:
1984 REFERS TO CALENDAR
YEAR 1984 THROUGHOUT THE
REMAINING QUESTIONNAIRE.
C. ENFORCEMENT OF LANDFILL REGULATIONS
C1. How many inspections for compliance with State Subtitle 0 regulations were made during
1984 for each type of landfill listed below? [COUNT INDIVIDUAL INSPECTIONS, E.G., IF YOU
HAD 100 LANDFILLS AND EACH WAS INSPECTED TWICE DURING CALENDAR YEAR 1984, YOUR NUMBER OF
INSPECTIONS WOULD BE 200]
Landfill type
c. Demolition debris only
d. Other (SPECIFY):
e. TOTAL NUMBER OF INSPECTIONS DURING 1984
Number of
inspections
during 1984
II-7
-------
C2. How frequently are individual Subtitle D landfills inspected for compliance?
PERCENTAGE OF LANDFILLS FALLING IN EACH FREQUENCY OF INSPECTION CATEGORY]
[ENTER THE
Landfill type
a. Municipal
waste
b. Industrial
waste
c. Demolition
debris only
d. Other
[SPECIFY]:
Frequency of Inspection
A.
Never
Inspected
*
%
%
V
rtl
B.
Leas than
once every
two years
IV
/o
a/
/it
%
%
c.
Once
every
two
years
%
%
%
%
D.
Once
a
year
%
%
%
' IV
/O
£.
Twice
a
year
%
%
%
%
F.
Four
times
a
year
%
%
Of
/O
%
G.
More than
four times
a year
%
%
%
%
H.
Other
[SPECIFY
FOR EACH
TYPE]:
%
%
%
IX
/Q
i.
Total
[SHOUL
EQUAL
100«]
10055
100S
100S
100S
C3. Do you have a checklist of criteria for inspections? [CIRCLE ONLY ONE CODE]
Yes [PLEASE ATTACH A COPY OF THE
CHECKLIST TO THE BACK OF'
THIS QUESTIONNAIRE]
No
II-8
-------
C4. In the table below, please describe the number and types of violations that were found
by your State's 1984 landfill inspection program. In Columns A through D, report the
number of individual Subtitle D landfills that had at least one violation of the types
listed below.
Violation type
a. Groundwater contamination*.
b. Groundwater monitoring
c. Surface water contamination*
e. Methane control deficiencies
f. Operational deficiencies (e.g.,
daily cover violation, or
blowing litter) and other
g. Other violations in 1984 [SPECIFY]:
Number of individual Subtitle 0 landfills
(by type) in violation in 1984:
A.
Minicipal
waste
B.
Industrial
waste
C.
Demolition
debris only
D.
Other
[SPECIFY]:
*[PLEASE USE THAT DEFINITION CF CONTAMINATION THAT BEST APPLIES TO YOUR STATE WHEN ANSWERING
THIS QUESTION, I.E., THE DEFINITION USED IN YOUR STATE (E.G., IN REGS, ETC.)].
11-9
-------
0. THE NUMBER OF ACTIVE INDIVIDUAL SUBTITLE D LANDFILLS AND THE
NUMBER OF ESTABLISHMENTS WITH ACTIVE LANDFILLS
The objective of this section is to obtain information on the number of active individual
Subtitle D landfills (both permitted and unpermitted), and the number of establishments with
Subtitle D landfills. [SEE GENERAL INSTRUCTIONS FOR A DIAGRAM AND DEFINITIONS OF LANDFILL AND
ESTABLISHMENT]
D1. During 1984, how many individual Subtitle D landfills were active in your State? (For the
purpose of the questions in Section D, the term "active" means "received waste in 1984.")
NUMBER OF ACTIVE INDIVIDUAL
SUBTITLE D LANDFILLS IN 1984:
D2. In the table below, please enter the number of active individual Subtitle D landfills in
1984 in each of the following categories.
Landfill type
d. Other [SPECIFY]:
e. TOTAL SHOULD EQUAL RESPONSE TO QUESTION D1 :
Number of active
individual Subtitle D
landfills in 1984
03. How many establishments in your State had active Subtitle D landfills in 1984? (An
establishment is defined as a single physical location where business is conducted or
where services or industrial operations are performed by a municipality, corporation,
or other public or private entity. An establishment may have two or more landfills).
NUMBER OF ESTABLISHMENTS WITH
ACTIVE SUBTITLE D LANDFILLS IN 1984:
11-10
-------
04. In the table below, please enter the number of individual active Subtitle D landfills in
1984 (by landfill type) in each of the ownership categories listed.
Landfill type
a. Municipal
b. Industrial
waste
c. Demolition
debris only. . .
d. Other
[SPECIFY]:
Number of individual active Subtitle D landfills
A.
Owned by
State
government
B.
Owned by
local
governments
C.
Owned by
Federal
government
0.
Privately
owned
E.
Other*
F.
Total number
of landfills
by type
[THIS SHOULD
EQUAL THE
NUMBER IN D2]
* [SPECIFY "OTHER" OWNERSHIP CATEGORY, IF USED]:
"II-ll
-------
E. LANDFILL DESIGN AND OPERATING CHARACTERISTICS
The objective of this section is to determine the design and operating characteristics of
Subtitle 0 landfills.
E1. In the table below, please enter the number of active individual Subtitle D landfills in
1984 (by landfill type) in each of the landfill acreage categories listed. (Acreage
should include active, inactive, and closed portions of each landfill. Column D totals
should equal the distribution of individual landfills in Question D2.)
Landfill type
d. Other [SPECIFY]:
e. TOTAL NUMBER OF LANDFILLS
BY ACREAGE CATEGORY
Number of active individual Subtitle D landfills with:
A.
Less than
10
acres
B.
10 - 100
acres
C.
More than
100 acres
D.
Total number
of landfills
by type
11-12
-------
E2. In the table below, please enter the number of active individual Subtitle D landfills (by
landfill type) according to the amount of waste received in 1984. Column D Totals should
equal the number of landfills in question 02. (Note: Assume 500 pounds per cubic yard of
waste as received if units conversion is necessary.)
Landfill type
d. Other [SPECIFY]:
e. TOTAL NUMBER OF
LANDFILLS BY CATEGORY
Number of active individual Subtitle D landfills
by amount of waste received in 1984:
A.
Received less
than 30,000
cubic yards
in 1984 (30
tons per day)
B.
Received,
30,000 -1'
600,000
cubic yards
in 1984
(30-500 tons
per day)
C.
Received more
than 600,000
cubic yards
in 1984 (500
tons per day)
D.
Total number
of landfills
by type [THIS
SHOULD EQUAL
THE NUMBER
IN D2]
•11-13
-------
E3. Please describe any local, regional or statewide landfill capacity problems in your State.
[ATTACH ADDITIONAL SHEETS IF NECESSARY]
E4. In the table below, please enter the number of active individual Subtitle D landfills (by
landfill type) that had groundwater, surface water, air and methane monitoring in 1984.
Landfill type
b. Industrial waste
d. Other [SPECIFY]:
e. TOTAL NUMBER OF LANDFILLS
WITH EACH TYPE OF MONITORING:
Number of active individual Subtitle D
landfills that had:
A.
Groundwater
Monitoring
B.
Surface
Water
Monitoring
C.
Air
Emissions
Monitoring
D.
Methane
Monitoring
11-14
-------
E5. In the table below, please estimate the number of active individual Subtitle D landfills
(by landfill type) that had or used the following release prevention/management methods
in 1984:
Management method
Number of active individual Subtitle D landfills:
A.
Municipal
waste
B.
Industrial
wastes
C.
Demolition
debris only
D.
Other
[SPECIFY]:
•a. Synthetic liners
b. Natural liners (e.g., clay),
including slurry walls . . .
c. Natural renovation (i.e.,
leachate attenuation). . . .
d. Leachate collection systems .
e. Leachate treatment (except
leachate recirculation) . . .
f. Leachate recirculation . . .
g. Run-on/run-off controls. . .
h. Methane controls (vents,
recovery)
i. Restrictions on receipt of
liquid wastes (e.g., bulk
liquid restrictions) ....
'11-15
-------
E6. Certain non-household hazardous wastes are exempted from Federal and some State hazardous
waste regulations if generated in small quantities. Please indicate the percentage of
Subtitle D landfills of each type that receive such wastes?
Landfill type
b. Industrial waste
c. Demolition debris only
d. Other [SPECIFY]:
Percent that receive
exempted non-household
hazardous wastes.
%
%
%
-------
E7. What is the typical State-wide tipping fee (i.e., fee or charge levied on disposers,
transporters, or collectors bringing Subtitle D waste to a landfill) to landfill cus-
tomers for disposal of sludges and other solid waste at each of the following types
of Subtitle D landfills? [ENTER TYPICAL TIPPING FEES AND CIRCLE THE UNIT CODE AT THE
BOTTOM OF THE TABLE]*
Landfill type
a. Municipal waste. . .
b. Industrial wastes. .
c. Demolition debris
only
d. Other [SPECIFY]:
Sludges
Typical
tipping
fees Range
$ $ to $
$ $ to $
$ $ to $
$ $ to $
[CIRCLE ONE]:
Per ton 01
Per cubic yard. ...... » . 02
Other [SPECIFY]:
03
Other Solid Waste
Typical
tipping
fees Range
$ $ to $
$ $ to $
$ $ to $
$ $ to $
[CIRCLE ONE]:
Per ton 01
Other [SPECIFY]:
03
*[IF THIS QUESTION IS NOT APPLICABLE TO YOUR STATE, PLEASE PLACE A CHECK (V ) IN THE BOX:
AND EXPLAIN WHY BELOW, (E.G., "THERE ARE NO TIPPING FEES IN MY STATE," "FEES ARE CHARGED BY
LOCAL GOVERNMENTS AND STATE DOES NOT MONITOR")]
11-17
-------
F. AVAILABILITY OF DATA
F1. In the table below, please estimate the proportion of individual Subtitle D landfills
(by landfill type) for which your State has each type of monitoring data available:
Landfill type
a. Municipal
waste
b. Industrial
waste
c. Demolition
debris
only
d. Other
[SPECIFY]:
A.
Groundwater monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH LANDFILL TYPE]
None Some Most
(OS) (1-50%) (>50«)
1 2 3
1 2 3
1 2 3
1 2 3
B.
Surface water monitor-
ing data available for:
[CIRCLE ONE CODE FOR
EACH LANDFILL TYPE]
None Some Most
(0%) (1-50%) O50S)
1 2 3
1 2 3
1 2- 3
1 2 3
C.
Leachate characteriza-
tion data available for
[CIRCLE ONE CODE FOR
EACH LANDFILL TYPE]
None Some Most
(0%) (1-50%) (>50S)
1 2 3
1 2 3
1 2 3
1 2 3
11-18
-------
D.
Air emission monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH LANDFILL TYPE]
None Some Most
(03) (1-505S) (>50S)
1 2 3
1 2 3
1 2 3
1 2 3
E.
Methane monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH LANDFILL TYPE]
None Some Most
(OS) (1-5055) O50SS)
1 2 3
1 2 3
1 2 3
1 2 3
11-19
-------
(Please continue.
11-20
-------
F2. Please estimate the number of individual Subtitle D landfills (by landfill type) for
which your State has case studies. (Case studies include monitoring data, but in addition
include a sufficient level of detail on site design and operating practices to provide
some indication of the causes for the success or failure of the landfill to protect human
health and the environment. Some case studies may also include information on design and
operating costs of the landfill and tipping fees.)
[IF YOU ARE NOT AWARE OF ANY CASE STUDIES OF SUBTITLE D LANDFILLS IN YOUR STATE, PLEASE
PLACE A CHECK ( >/ ) IN THE BOX: | |, AND SKIP TO QUESTION F4.]
Landfill type
c. Demolition debris only....
d. Other [SPECIFY]:
Number of 3
A.
With case studies
ndividual Subtitle D i
B.
With case studies
that include design
and operating costs
andfills
C.
With case
studies that
include
tipping fees
F3. List any alternate sources of case study information that you know of in your State (e.g.,
local governments that have case study data).
SOURCE:
CONTACT PERSON
(AREA CODE) TELEPHONE
F4. Does your State already have a list (or file) of establishments with Subtitle D landfills?
Yes [GO ON TO QUESTION F5] 1
No [SKIP TO QUESTION G1] 2
11-21
-------
F5. In what format is(are) the list(s)? [EXAMPLES: ON A COMPUTER FILE, IN A CARD FILE, ON A
WORD PROCESSING DISK, ETC.]
F6. What doea(do) the list(s) cover? [EXAMPLES: PERMITTED LANDFILLS ONLY, INDUSTRIAL LANDFILLS
ONLY, ALL TYPES OF LANDFILLS THAT ARE LARGER THAN ONE ACRE, ETC.]
F7. If possible, please attach copies of any list(s) to this completed questionnaire. If this
is not possible, please indicate below how EPA could obtain a list of landfills in your
State.
11-22
-------
G. CONTACT INFORMATION AND COMMENTS AND ATTACHMENTS: LANDFILLS
G1. Please identify a contact person for this landfills section of the survey, should it be
necessary to clarify responses:
Contact Name:
Title:
Agency/Program:
Telephone: ( ) Ext.:
G2. COMMENTS - Please include any comments or further amplification of responses to Sections
8 through F below or on attached sheets.
G3. CHECKLIST OF ATTACHMENTS TO PART II - LANDFILLS:
[Please check •J the appropriate box if you have attached the following]:
a. Schedule of State permit fees (Question 85) | j
b. State Subtitle D landfill regulations (Question 86) | |
c. Checklist of State critieria for inspections (Question C3) | j
d. List of establishments with Subtitle D landfills (Question F7) | j
e. Attached comment sheets (Question G2) I I
11-23
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
STATE SUBTITLE D PROGRAM QUESTIONNAIRE
PART III - LAND APPLICATION UNITS
(Sections H-M)
IMPORTANT: BEFORE PROCEEDING WITH THIS SECTION, READ THE GENERAL
INSTRUCTIONS AT THE FRONT OF THIS QUESTIONNAIRE CAREFULLY.
PLEASE PAY SPECIAL ATTENTION TO THE DEFINITIONS BELOW.
LAND APPLICATION UNIT - A part of an establishment at which waste is applied onto or
incorporated into the soil surface for the purpose of beneficial use or waste
treatment and disposal. Land application is often referred to as landfarming or
land spread ing. Specifically excluded from this definition are manure spreading
operations.
Municipal Sewage Sludge Land Application Unit - A land application unit that primarily
receives sewage sludge from publicily-owned or privately-owned domestic sewage
treatment facilities, including sludge from domestic septic tanks. (Note: do not
include municipal wastewater land application units in this category - these are not
included in the scope of this survey).
High application rate units - Municipal sewage sludge land application units
where the application rate exceeds the nutrient needs of crops, for
reclamation of disturbed lands, waste treatment or disposal.
Low application rate units - Municipal sewage sludge land application units
where the application rate is based on crop nutrient needs.
Industrial Waste Land Application Unit - A land application unit that primarily receives
waste (including sludge or wastewater) from factories, processing plants, and other
manufacturing or commercial activities.
Oil or Gas Waste Land Application Unit - A land application unit that receives waste, such
as drilling muds, generated by oil or gas exploration and extraction operations.
Other Land Application Unit - A land application unit receiving Subtitle D wastes that does
not fall into any of the above categories (e.g., a drinking water treatment waste land
application unit).
III-l
-------
H. SUBTITLE D LAND APPLICATION UNIT REGULATIONS
The objective of this section is to gather current information on existing and proposed State
regulations and permits.
H1. The table below presents a list of specific requirements for Subtitle D land application units.
For each column A through E, circle code 1 if these requirements are specifically included
in the State regulations. Circle code 2 if these requirements are not specifieai 1 y included
in the State regulations, but can be enforced under general performance standards or State
policies. Circle code 3 if there are no enforceable requirements. [FOR EACH REQUIREMENT,
PLEASE CIRCLE ONLY ONE CODE FOR EACH LAND APPLICATION UNIT TYPE]
Requirements included
in current State
Subtitle D program?
8. location otanxtecda (e.g.,
floorfplaina
b« tioat* application Baits
e» Restrictions oft growing
food chain crops
4* Ssstrietior* on typo* of
Subtitle D wastes received
«« Sludg* quality criteria
f. Waste disinfection prior
to application
g. Soil monitoring
h. Groundwater protection
standard
i . Groundwater monitoring
j. Corrective action for
groundwater contamination
k« Air emission monitor ing
1. Mr protection standards
». Surface water protection
standards " ~
ru Sutfacs water monifcoting
o» Cerrectivs? action for swr-
fttce water contanifietion
p. Run-off collection
and removal
q. Run-off characterization/
analysis
r. Run-off treatment
s. Run-on controls
t. Endangered species criteria
u* Oisease vectors criteria.
v« Safety criteria*
Uncontrolled access
«. Closure: standards '
x« Poatelosute monitoring
y, Financial responsibility
A.
Municipal sewage sludge at
high application rate*
Specifically
included
in the
regulations
1
1
1
1
, 1,
1
1
1
1
1
1 *' '
1
1
t
, 1 , . " ,
1
1
1
1
1
1
1
1
1
1
Enforced
under
general
standards
and
policies
2
2
2,
2
2
2
2
2
2
2
I
2
2
2
2
2
2
2
2
2
2
2
2
2
2
No en-
forceable
require-
ments
5
3
3-
j.
5
3
3
3
3
3
S
J
>
?
J
3
3
3
3
3
?
>
J
?
3
Land
Applica
B.
Municipal sewage sludge at
low application rate*
Specifically
included
in the
regulations
1
1
; t ,
t
t
1
1
1
1
1
1
1
' 1
1
1
1 '
1
1
1
1
1
1
t
1
1
Enforced
under
general
standards
and
policies
2
^
2
t
Z
2
2
2
2
2
t
2
2
2
2
2
2
2
2
2
2
2
2
„ 2
2
No en-
force a!
requir
ments
3
3
J
5
3
3
3
3
3
3
5
5
3
3
3
3
3
3
3
3
3
3
3
3
3
* NOTE THAT THERE ARE TWO TYPES OF MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS. HIGH APPLICATION RATE UNITS EXCEED CROP NUTRIENT NEEDS WHEREAS LOW
APPLICATION RATE UNITS DO NOT. (SEE PAGE III-1). IF YOUR STATE DOES NOT
DIFFERENTIATE BETWEEN HIGH AND LOW APPLICATION RATE UNITS, CIRCLE THE
CODE IN COLUMNS A AND B FOR EACH REQUIREMENT.
III-2
-------
IMPORTANT: SEE DEFINITION OF LAND APPLICATION
UNIT TYPE ON PAGE III-1.
Unit Types
c.
Industrial waste
Specifically
included
in the
regulations
"-"-t 1
; ; t
: ? :
1
1 ,
1
1
1
1
1
1
t
1
= 1
- .t . .
1
1
1
1
• 1
1
1
1
1
1
Enforced
under
general
standards
and
policies
2
z
?
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
No en-
forceable
require-
ments
3,
3
*
3
3
3
3
3
3
3
3
5
3
3
3
3
3
3
3
3
3 :
1
3
3
3
Oil
Specifically
included
in the
regulations
t
t
1
1
1
1
1
1
1
1
1
I
' ' 1
t
„.„• *
1
1
1
1
1
1
1
1
t
1
D.
or gas waste
Enforced
under
general
standards
and
policies
2
t
2
2
2
2
2
2
2
2
2
: 2
2
2
2
2
2
2
2
2
' 2
2
2
2
2
No en-
forceable
require-
ments
3 i
3 =
J i
5
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
J
3
Other
Specifically
included
in the
regulations
1
?
t I
1 :
1 .
1
1
1
1
1
T
t
t
*
t
1
1
1
1
1
1
1
1
t
1
E.
[SPECIFY]:
Enforced
under
general
standards
and
policies
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Z
2
2
2
2
2
2 .
2
2
2
2
No en-
forceable
require-
ments
3
3
3
3
3
3
3
3
3
3
" = 3
, : 3
- : ?
3
: 3
3
3
3
3
3
5
•• ^ 3
3
3
; 3
III-3
-------
H2. Please indicate (for each land application unit type) whether the following specific
requirements are included in formally proposed State regulations. [IF THERE ARE NO
FORMALLY PROPOSED REGULATIONS IN YOUR STATE, PLEASE PLACE A CHECK IN THE BOX: ||
AND SKIP TO H3.]
Specific requirements included
in formally proposed regulations?
a. Location standacow (*«$»*
floodpiain*
b. testa ^plication liaits :
e« Raatrictiona on growing food
chain- cropa
d, fiaatrietiona on typea of
Subtitle & waste* received:
»» Saat* diainf action prior to
jppUcv&ian ,_ x ^
f. Soil monitoring
g. Groundwater protection standard
h. Groundwater monitoring
i. Corrective action for groundwater
contamination
j. Air emission monitoring
k, Air protection standard* *'• ' '
1.. Surface water protection «tand«rd»
». Sorfac*; water wooitoring ; , ,
n. fibraBctiv* action for aurfac*- ' .'/
xatwc contantinatioo
o. Sun-off collection m& **»»¥«&•<> -
p. Run-off characterization/ analysis
q. Run-off treatment
r. Run-on controls
s. Endangered species criteria
t. Disease vectors criteria
u» Safety criteria* Sird hazard*
^^t^*":*3™^*1 ** > .-
*+• Clo8«* sfcarxi*«te.> - .;',--.'
x» ftjateiflswra «o»itorint( --:;/•?" -
X. Financial responsibility- ;
• <
Land Application Unit Types
A.
Municipal
sewage
si udge at
high appli-
cation rate*
Yes N£
1 2
t 2
, 1 2
t Z
-t 2.
'1 2
1 2
1 2
1 2
1 2
' t: ' ' t
t 2
1 - 2
-
1 t - ',z
- t;,;, / 2 •
""1" *'z
1 2
1 2
1 2
1 2
*'"'r 2
t- 2
t!, 2
• r . 2 '
1 2
B.
Municipal
sewage
sludge at
low appli-
cation rate*
Yes N£
1 2
1 2
1 2
1 2
1 -.,*,,
1 2
1 2
1 2
1 2
1 2
1 ; "l *
1 2
t : J
? . 2
• 1 I 2'
1 2
1 2
1 2
1 2
1 2
'? 2
1 2
12
1 . 2
t 2
C.
Industrial
waste
Yes _No
1 t
1 2
1 2
1 2
., f ,. .38 .,.
1 1 ' 2
1 2
1 2
1 2
1 2
t" 2.
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2-
1 2
1 2
1 2
1 2
D.
Oil or gas
waste
Yes Nki
V 2 -
't , 3E
J""1
t- '"' 2
: -•''','
. 1 "' 2:
'/^
,t"" 2
f 2
1 2
1 2
1 2
1 2
1 2
1 2
t 2
1 2
t 2
1 2
1 2
1 2
1 2
1 2
t 2
1 2
1 2
1 2
1 2
E.
Other
[SPECIFY
Yes i[
: t
i 1
t
; -.
- ,' 1
: {'-:' '
'>J' '
"*i
1
1
1
1
J t
i 1
: 1
; 1
j 1
1
1
1
1
1
.; > ,'
t
1
1
; i
* NOTE THAT THERE ARE TWO TYPES OF MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS. HIGH APPLICATION RATE UNITS EXCEED CROP NUTRIENT NEEDS WHEREAS LOW
APPLICATION RATE UNITS DO NOT. (SEE PAGE III-1). IF YOUR STATE DOES NOT
DIFFERENTIATE BETWEEN HIGH AND LOW APPLICATION RATE UNITS, CIRCLE THE SAME
CODE IN COLUMNS A AND B FOR EACH REQUIREMENT.
III-4
-------
H3. In the table below, indicate whether your State currently requires permits/plan approval
or licenses/registration for each of the listed types of Subtitle 0 land application
units, [CIRCLE ONE CODE FOR EACH TYPE DF LAND APPLICATION UNIT]
Land application unit type
a. Municipal sewage sludge at high application rate*.
b. Municipal sewage sludge at low application rate* .
e. Other [SPECIFY]:
A.
Permit or
plan approval
required?
Yes _No
1 2
1 2
1 2
1 2
1 2
B.
License or
registration
required?
Yes _No
1 2
1 2
1 2
1 2
1 2
* NOTE THAT THERE ARE TWO TYPES OF MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS. HIGH APPLICATION RATE UNITS EXCEED CROP NUTRIENT NEEDS WHEREAS LOW
APPLICATION RATE UNITS DO NOT. (SEE PAGE III-1). IF YOUR STATE DOES NOT
DIFFERENTIATE BETWEEN HIGH AND LOW APPLICATION RATE UNITS, CIRCLE THE SAME
CODE IN COLUMNS A AND 8 FOR EACH REQUIREMENT.
COMMENTS: [PLEASE EXPLAIN IF PERMIT REQUIREMENTS VARY WITHIN A CATEGORY, E.G. - SOME
INDUSTRIAL WASTE LAND APPLICATION UNITS REQUIRE PERMITS AND OTHERS DON'T]
III-5
-------
H4. How many of the active individual Subtitle D land application units of each type in your
State currently have permits/approved plans or licenses/registration?
a.
b.
wfe
c.
d.
e.
Land application unit type
Municipal sewage sludge at high
application rate*
Municipal sewage sludge at low
Total wtnicijwi sewage sludge*. „ . . . .
Industrial waste
Oil or gas waste
Other (SPECIFY):
Number of indi-
vidual Subtitle
D land applica-
tion units that
have permits or
approved plans
Number of indi-
vidual Subtitle
D land applica-
tion units
licensed or
registered
IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
H5. Is there a written or published schedule of your State's permit fees for Subtitle D
land application units? [CIRCLE ONLY ONE CODE]
Yes [PLEASE ATTACH A COPY OF THE
FEE SCHEDULE TO THE BACK OF
THIS QUESTIONNAIRE]
No
N/A [THERE ARE NO PERMIT FEES
IN MY STATE]
H6. Please attach a copy of your State's Subtitle D land application unit regulations
(existing and proposed, if any) to the back of this questionnaire.
III-6
-------
IMPORTANT NOTE:
1984 REFERS TO CALENDAR
YEAR 1984 THROUGHOUT THE
REMAINING QUESTIONNAIRE.
I. ENFORCEMENT OF LAND APPLICATION UNIT REGULATIONS
11. How many inspections for compliance with State Subtitle D regulations were made during
1984 for each type of land application unit listed below? [COUNT INDIVIDUAL INSPECTIONS,
E.G., IF YOU HAD 100 LAND APPLICATION UNITS AND EACH WAS INSPECTED TWICE DURING CALENDAR
YEAR 1984, YOUR NUMBER OF INSPECTIONS WOULD BE 200]
Land application unit type
a. Municipal sewage sludge at high application rate*
. / ..,,.,
e. Other (SPECIFY):
e. TOTAL NUMBER OF INSPECTIONS DURING 1984
Number of
inspections
during 1984
! 1:
•
IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF INSPECTIONS OF MUNICIPAL SEWAGE
SLUDGE UNITS ON LINE a+b.
III-7
-------
12. How frequently are individual Subtitle 0 land application units inspected for compliance?
[ENTER THE PERCENTAGE OF LAND APPLICATION UNITS FALLING IN EACH FREQUENCY OF INSPECTION
CATEGORY]
Frequency of Inspection
Land applica-
tion unit
type
a. Municipal
sewage sludge
at high appli-
cation rate*
b. Municipal
sewage sludge
at low appli-
cation rate*
•*,«**& Total »ur»i-
cip«i sew*ja
niodge-*
c. Industrial
waste
d. Oil or gas
waste
e. Other
[SPECIFY]:
A.
Never
Inspected
%
%
% ;
/O
/O
%
B.
Less than
once every
two years
o/
fQ
ro
%
/O
%
%
C.
Once
every
two
years
O/
/O
%
• a
X
%
%
0.
Once
a
year
%
%
* -t
''%»
/Q
o/
/a
s
E.
Twice
a
year
0>
%
•' •
%
%
%
%
F.
Four
times
a
year
%
%
%
/Q
%
%
G.
More than
four times
a year
o/
/n
%
a
55
%
%
H.
Other
[SPECIFY
FOR EACH
TYPE]:
V
fO
a/
/o
if
5
£
%
5!
I.
Total
[SHOUL
EQUAL
100S]
i
1005
100%
100%
100%
* IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE PERCENTAGE OF ALL MUNICIPAL SEWAGE SLUDGE UNITS
IN EACH COLUMN ON LINE a+b.
13. Do you have a checklist of criteria for inspections? [CIRCLE ONLY ONE CODE]
Yes [PLEASE ATTACH A COPY OF THE
CHECKLIST TO THE BACK OF
THIS QUESTIONNAIRE]
No
III-8
-------
14. In the table below, please describe the number aid types of violations that were found
by your State's 1984 land application unit inspection program. In Columns A through E,
report the number of individual Subtitle 0 land application units that had at least one
violation of the types listed below.
Violation type
a. Groundwater
b. Groundwater
monitoring program
deficiencies
c. Surface water
d. Air contamination*...
e. Operational
deficiencies
and other minor
f. Other violations in
1984 [SPECIFY]:
Number of individual Subtitle D land application
units (by type) in violation in 1984:
A.
Municipal
sewage
sludge at
high appli-
cation rate**
B.
Municipal
sewage
sludge at
low appli-
cation rate**
' 'jwr'f
T
-------
J. THE NUMBER OF ACTIVE INDIVIDUAL SUBTITLE D LAND APPLICATION UNITS AND
THE NUMBER OF ESTABLISHMENTS WITH ACTIVE LAND APPLICATION UNITS
The objective of this section is to obtain information on the number of active individual
Subtitle D land application units (both permitted and unpermitted), and the number of
establishments with Subtitle D land application units. [SEE GENERAL INSTRUCTIONS FOR A
DIAGRAM AND DEFINITIONS OF LAND APPLICATION UNIT AND ESTABLISHMENT]
J1. During 1984, how many individual Subtitle D land application units were active in your
State? (For the purpose of the questions in Section D, the term "active" means "received
waste in 1984.")
NUMBER OF ACTIVE
INDIVIDUAL SUBTITLE D
LAND APPLICATION UNITS IN 1984:
J2. In the table below, please enter the number of active individual Subtitle D land applica-
tion units in 1984 in each of the following categories.
Land application unit type
a. Municipal sewage sludge at high application rate*
b. Municipal sewage sludge at low application rate*
e. Other [SPECIFY]:
e. TOTAL SHOULD EQUAL RESPONSE TO QUESTION J1 :
Number of active
individual Subtitle D
land application units
in 1984
\
,..-.: . . JK
J3.
* IF YOUR STATE DOES NOJ_ DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS ON
LINE a+b.
How many establishments in your State had active Subtitle D land application units in
1984? (An establishment is defined as a single physical location where business is
conducted or where services or industrial operations are performed by a municipality,
corporation, or other public or private entity. An establishment may have two or more
land application units).
NUMBER OF ESTABLISHMENTS
WITH ACTIVE SUBTITLE D LAND
APPLICATION UNITS IN 1984:
111-10
-------
J4. In the table below, please enter the number of individual active Subtitle D land applica-
tion units in 1984 (by land application unit type) in each of the ownership categories
listed.
Land applica-
tion unit
type
a. Municipal
sewage sludge
at high appli-
cation rate**. . .
b. Municipal
sewage sludge
at low appli-
cation rate**...
a*b Yet*£ »tniei-
pal awMsge
c. Industrial
waste
d. Oil or gas
e. Other
[SPECIFY]:
Number of individual active Subtitle D land application units
A.
Owned by
State
government
8.
Owned by
local
governments
C.
Owned by
Federal
government
>
D.
Privately
owned
E.
Other*
F.
Total number
of land
application
units by type
[THIS SHOULD
EQUAL THE
NUMBER IN J2]
* [SPECIFY "OTHER" OWNERSHIP CATEGORY, IF USED]:
IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
'111-11
-------
K. LAND APPLICATION UNIT DESIGN AND OPERATING CHARACTERISTICS
The objective of this section is to determine the design and operating characteristics of
Subtitle D land application units.
K1. In the table below, please enter the number of active individual Subtitle D land applica-
tion units in 1984 (by land application unit type) in each of the land application unit
acreage categories listed. (Acreage should include active, inactive, and closed portions
of each land application unit. Column E totals should equal the distribution of individual
land application units in Question J2.) In Column F, please indicate the total acreage of
each land application unit type.
Land application
unit type
a. Municipal sewage
sludge at high
application rate*.
b. Municipal sewage
sludge at low
application rate*.
a*b Total municipal
sewage sludge*..,.
c. Industrial
waste
d. Oil or gas
e. Other [SPECIFY]:
f. TOTAL NUMBER OF
LAND APPLICATION
UNITS BY ACREAGE
CATEGORY
(COLUMNS A-E
AND TOTAL ACREAGE
(COLUMN F)
Number of active individual Subtitle D
land application units with:
A.
Less than
10 acres
8.
10 - 49
acres
C.
50 - 99
acres
D.
100 acres
or more
E.
Total number
of land appli-
cation units
by type
F.
Total acreage
of land appli
cation units
by type
* IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
III-12
-------
K2. In the table below, please enter the number of active individual Subtitle D land applica-
tion units (by land application unit type) according to the amount of waste received in
1984. Column E totals should equal the number of land application units in question J2.
Land application
unit type
a. Municipal sewage
sludge at high
application rate*....
b. Municipal sewage
sludge at low
application rate*....
a*t> Total municipal
mwge aludge* *>»,»«»
e. Other [SPECIFY]:
f. TOTAL NUMBER OF LAND
APPLICATION UNITS BY
CATEGORY
Number of active individual Subtitle D land application
units by amount of waste received in 1984:
A.
Received less
than 50 tons
per year
(dry weight)
B.
Received
50 - 99
tons per
year (dry
weight)
C.
Received
100-999
tons per
year (dry
weight)
0.
Received
1,000 or
more tons
per year
(dry
weight)
E.
Total number
of land appli-
cation units
by typed
[THIS SHOULD
EQUAL THE
NUMBER IN J2]
* IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
111-13
-------
K3. Certain non-household hazardous wastes are exempted from Federal and some State hazardous
waste regulations if generated in small quantities. Please indicate the percentage of
Subtitle D land application units of each type that receive such wastes?
Land application unit type
Percent that receive
exempted non-household
hazardous wastes.
Municipal sewage sludge at high application rate*.
Municipal sewage sludge at low application rate* .
'-•">'>""<, - , - • = V "
Total UKttieipai sewage: aludge* *.».«»*»»..<
Industrial waste
Agricultural waste
Other [SPECIFY):
* IF YOUR STATE DOES NOJ DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
K4. In the table below, please enter the number of active individual Subtitle D land application
units that had groundwater, surface water, air and soil monitoring in 1984.
Land application unit type
a. Municipal sewage sludge at high
application rate*
b. Municipal sewage sludge at low
application rate*
a+b Total awoicipai w»«g* afcadg****... .
d. Oil or gas waste
e. Other [SPECIFY]:
Number of active individual Subtitle D
land application units that had:
A.
Groundwater
Monitoring
B.
Surface Water
Monitoring
*
C.
Air
Monitoring
D.
Soil
Monitoring
* IF YOUR STATE DOES NOJ_ DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
111-14
-------
K5. In the table below, please estimate the number of active individual Subtitle D land
application units (by land application unit type) that had or used the following release
prevention/management methods in 1984:
Management method
a. Run- on/ run-off controls. .
b. Waste restrictions (ban
on certain Subtitle D
c. Waste application rate
d. Restrictions on the
growing of food chain
Number of active individual Subtitle D land af
A.
Municipal
sewage
sludge at
high appli-
cation rate*
B.
Municipal
sewage
sludge at
low appli-
cation rate*
**i
tofeai :
municipal
ifr^tJttrt^- -
VQVWtfvr -
aiurtge**
C.
Industrial
wastes
plication units:
D.
Oil or gas
waste
E.
Other
[SPECIFY]:
* IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" IN
COLUMNS A AND B, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS FOR
EACH MANAGEMENT METHOD IN COLUMN A+8.
K6.
Are there tipping fees (i.e., fees or charges levied on disposers, transporters, or
collectors bringing Subtitle D waste to a land application unit) for land application
unit customers for disposal of solid waste in your State? [CIRCLE ONE CODE ONLY FOR
EACH LAND APPLICATION UNIT TYPE]
Are there
Land application unit type Yea
a. Municipal sewage sludge at high application rate* . 1
b. Municipal sewage sludge at low application rate* 1
e. Other [SPECIFY]:
1
tipping fees?
No
2
2
2
2
2
* IF MUNICIPAL SEWAGE SLUDGE UNITS ARE NOT DISTINGUISHED BY HIGH AND LOW
APPLICATION RATES, CIRCLE THE SAME CODE FOR LINES a AND b.
111-15
-------
L. AVAILABILITY OF LAND APPLICATION UNIT DATA
L1. In the table below, please estimate the proportion of individual Subtitle D land
application units (by land application unit type) for which your State has each type
of monitoring data available:
Land appli-
cation unit
type
a. Municipal
sewage
sludge at
high appli-
cation rate*
b. Municipal
sewage
sludge at
low appli-
cation rate*
c. Industrial
waste
d. Oil or
gas
waste
e. Other
[SPECIFY]:
A.
Groundwater monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH LAND APPLICATION
UNIT TYPE]
None Some Most
(OS) (1-5QS) (>50%)
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
B.
Surface water monitor-
ing data available for:
[CIRCLE ONE CODE FOR
EACH LAND APPLICATION
UNIT TYPE]
None Some Most
(0%) (1-50%) (>50S)
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
C.
Soil monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH LAND APPLICATION
UNIT TYPE]
None Some Most
(0%) (1-50X) (>50%)
!
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
IF MUNICIPAL SEWAGE SLUDGE UNITS ARE NOT DISTINGUISHED BY HIGH AND LOW
APPLICATION RATES, CIRCLE THE SAME CODE FOR LINES a AND b.
111-16
-------
D.
Air emissions monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH LAND APPLICATION
UNIT TYPE]
None
(OS)
Some
(1-50*)
Most
(>50S)
"111-17
-------
L2. Please estimate the number of individual Subtitle D land application units (by land
application unit type) for which your State has case studies. (Case studies include
monitoring data, but in addition include a sufficient level of detail on sits design
and operating practices to provide some indication of the causes for the success or
failure of the land application unit to protect human health and the environment.
Some case studies may also include information on design and operating costs of the
land application unit and tipping fees.)
[IF YOU ARE NOT AWARE OF ANY CASE STUDIES OF SUBTITLE 0 LAND APPLICATION UNITS IN YOUR
STATE, PLEASE PLACE A CHECK ( V ) IN THE BOX: | |, AND SKIP TO QUESTION L4.]
Land application
unit type
a. Municipal sewage sludge
at high application rate*..
b. Municipal sewage sludge
at low application rate*...
atfe Total ntufiicipml «e»»g*
d. Oil or gas waste
e. Other [SPECIFY]:
Number of individual Subtitle D
land application units
A.
With case studies
'. . .:.
.
B.
With case studies
that include design
and operating costs
. •
C.
With case
studies that
include
tipping fees
: ,<..
» IF YOUR STATE DOES NOT DISTINGUISH MUNICIPAL SEWAGE SLUDGE LAND APPLICATION
UNITS BY HIGH AND LOW APPLICATION RATES (SEE PAGE III-1), ENTER "NA" ON
LINES a AND b, AND ENTER THE NUMBER OF MUNICIPAL SEWAGE SLUDGE UNITS IN EACH
COLUMN ON LINE a+b.
111-18
-------
L3. List any alternate sources of case study information that you Iciow of in your State (e.g.,
local governments that have land application unit case study data).
SOURCE: CONTACT PERSON (AREA CODE) TELEPHONE
L4. Does your State already have a list (or file) of establishments with Subtitle D land
application units?
Yes [GO ON TO QUESTION L5] 1
No [SKIP TO QUESTION M1] 2
L5. In what format is(are) the list(s)? [EXAMPLES: ON A COMPUTER FILE, IN A CARD FILE, ON A
WORD PROCESSING DISK, ETC.]
L6. What does(do) the list(s) cover? [EXAMPLES: PERMITTED LAND APPLICATION UNITS ONLY,
INDUSTRIAL LAND APPLICATION UNITS ONLY, ALL TYPES OF LAND APPLICATION UNITS THAT ARE
LARGER THAN ONE ACRE, ETC.]
L7. If possible, please attach copies of any list(s) to this completed questionnaire. If this
is not possible, please indicate below how EPA could obtain a list of land application
units in your State.
111-19
-------
M. CONTACT INFORMATION AND COMMENTS AND ATTACHMENTS: LAND APPLICATION UNITS
M1. Please identify a contact person for this land application units section of the survey,
should it be necessary to clarify responses:
Contact Name:
Title:
Agency/Program:
Telephone: ( ) Ext.:
M2. COMMENTS - Please include any comments or further amplification of responses to Sections
H through L below or on attached sheets.
M3. CHECKLIST OF ATTACHMENTS TO PART III - LAND APPLICATION UNITS:
[Please check (>/) the appropriate box if you have attached the following]:
a. Schedule of State permit fees (Question H5)
b. State Subtitle D land application unit regulations (Question H6).
c. Checklist of State criteria for inspections (Question 13) . . . ,
d. List of establishments with Subtitle D land application units
(Question L7)
e. Attached comment sheets (Question M2)
111-20
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
STATE SUBTITLE D PROGRAM QUESTIONNAIRE
PART IV - SURFACE IMPOUNDMENTS
(Sections N-S)
IMPORTANT: BEFORE PROCEEDING WITH THIS SECTION, READ THE GENERAL
INSTRUCTIONS AT THE FRONT OF THIS QUESTIONNAIRE CAREFULLY,
PLEASE PAY SPECIAL ATTENTION TO THE DEFINITIONS BELOW.
SURFACE IMPOUNDMENT - A part of an establishment which is a natural topographic depression,
man-made excavation, or diked area formed primarily of earthen materials (although
it may be lined with man-made materials) that is designed to hold an accumulation of
liquid wastes or wastes containing free liquids. Treatment, storage, and disposal
surface impoundments are included. Surface impoundments are often referred to as
pits, ponds, or lagoons. This definition does not include any type of tank, including
concrete, fiberglass or steel tanks.
Municipal Wastewater Surface Impoundment - A publicly owned surface impoundment, commonly
known as a sewage lagoon or sewage pond, designed to provide partial or total treatment
for domestic sewage or a mixture of domestic and industrial wastewater.
Municipal Sewage Sludge Surface Impoundment - A surface impoundment that receives sewage
sludge from publicly-owned or privately-owned domestic sewage treatment establishments,
including septic tanks.
Municipal Run-off Surface Impoundment - A surface impoundment that is used for the collection
of run-off or leachate from municipal waste landfills or municipal waste land applica-
tion units.
Industrial Waste Surface Impoundment - A surface impoundment that primarily receives wastes
from factories, processing plants (including food processing), and other manufacturing
or commercial activities. Also included in this category are surface impoundments
used for the collection of run-off or leachate from industrial or demolition landfills
and industrial land application units.
Agricultural Waste Surface Impoundment - A surface impoundment that only receives waste from
agricultural operations, including farming, crop production, and animal husbandry
(including feedlots). Specifically excluded from this category are surface impound-
ments that are used for wastes from slaughter houses, other animal processing, and
food processing, which are included in the "industrial" categoryi
Mining Waste Surface Impoundment - A surface impoundment associated with mineral extraction
and beneficiation activities such as crushing, screening, washing, floatation, etc.
These minerals include metallic and non-metallic ores, coal, sand and gravel, but
exclude oil and gas. Specifically excluded are impoundments used for processing
wastes from manufacturing establishments which are included in the "industrial"
category.
Oil or Gas Waste Surface Impoundment - A surface impoundment that receives waste from oil
or gas exploration and extraction, commonly known as brine pits. Both disposal and
emergency brine pits are included. Specifically excluded are impoundments used for
petroleum refinery wastes, which are included in the "industrial" category.
Other Surface Impoundment - A surface impoundment receiving Subtitle D wastes that does
not fall into any of the above categories (e.g., a drinking water treatment waste
impoundment).
IV-1
-------
N. SUBTITLE 0 SURFACE IMPOUNDMENT REGULATIONS
The objective of this section is to gather current information on existing and proposed State
regulations and permits.
N1. The table below presents a list of specific requirements for Subtitle D surface impoundments.
For each column A through H, circle code 1 if these requirements are specifically included
in the State regulations. Circle code 2 if these requirements are not specifically included
in the State regulations, but can be enforced under general performance standards or State
policies. Circle code 3 if there are no enforceable requirements. [FOR EACH REQUIREMENT,
PLEASE CIRCLE ONLY ONE CODE FOR EACH SURFACE IMPOUNDMENT TYPE]
Requirements included
in current State
Subtitle D program?
8
b
e
d
e
f
g
h
i
j
k
1
»
n
o
P
q
r
s
t
. location standard* (e.g.,
floodpleins)
» Natural liners (»«g.,
clay)
« synthetic linet«
« Leak detection systaa
« Groundwater protection
standard
Groundwater monitoring
. Corrective action for
groundwater contamination
Air protection standard
Air emission monitoring
Surface water protection
standards
. Surface water monitoring .
, Gftwaetiv* action for «a><
fac» Mater contamination
« uVertopping controls
(freeboard)
. Dike stability criteria
* Restriction* on ty$>«* of
Stbtitle J> wastes received ^
Endangered species criteria
Disease vectors criteria
. Safety criteria:
Uncontrolled access
Closure standards
(example: caps)
Postclosure monitoring
u. Financial responsibility
Surface Impoundr
A.
Municipal wastewater
Specifically
included
in the
regulations
1
1 '
1
1
1
1
1
1
1
1
1
1
?
1
1
1
1
1
1
1
1
Enforced
under
general
standards
and
policies
2?
*
Z
z
2.
2
2
2
2
2
J£
t
2
Z
Z
2
2
2
2
2
: 2
No en-
forceable
require-
ments
5
3
?
J
?
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
5
B.
Municipal sewage
Specifically
included
in the
regulations
1
1
1
1
1
1
1
1
1
1
1
1
>
1
1
1
1
1
1
1
1
1
Enforced
under
general
standards
and
policies
Z
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
sludge
No en-
forces
requi-
ments
; ' 3
-
3
3
3
3
3
3
3
3
3
': 3
3
>
3
3
3
3
3
3
3
3
IV-2
-------
IMPORTANT: SEE DEFINITION OF SURFACE
IMPOUNDMENT TYPE ON PAGE IV-1 .
E THROUGH H COLUMNS OF THIS QUESTION
ARE ON PAGES IV-4 AND IV-5
Types
C.
Municipal run-off
Specifically
included
in the
regulations
1
1
t
1
t
1
1
1
1
1
1
1
t
1
1
1
1
1
1
1
1
Enforced
under
general
standards
and
policies
2
2
2
2
2
2
2
2
2
2
'%
2
i
2
2
2
2
2
2
2
2
No en-
forceable
require-
ments
>
>
3
3
3
3
3
3
3
3
" >'
7
5
3
3
3
3
3
3
3
5
D.
Industrial waste
Specifically
included
in the
regulations
1
1 -
t '
1
1 ;
1
1
1
1
1
1
t
1
1
1
1
1
1
1
1
t
Enforced
under
general
standards
and
policies
Z
2
2"
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
No en-
forceable
require-
ments
5
5
• ?
?
?
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
?
IV-3
-------
(Question N1, continued)
Requirements included
in current State
Subtitle 0 program?
a. location standard* (e.g.,
fJoodDlains)
tu Hatural liners (e.g.,
day)
c« Synttwtie liners
tf« teak detection syste*
e* Groundwater protection
standard
f. Groundwater monitoring
g. Corrective action for
groundwater contamination
h. Air protection standard
i. Air emission monitoring
j. Surface water protection
standards
k. Surface water Bonitoring
1. Uorreefciv* action fait mse--
face water contamination
«. Overtopping controls
C freeboard)
n. 0ike stability criteria
o« {{estrictione on type* of
Subtitle 0 waste* received
p. Endangered species criteria
q. Disease vectors criteria
r. Safety criteria:
Uncontrolled access
s. Closure standards
(example: caps)
t. Postclosure monitoring
u» financial responsibility
E.
Agricultural waste
Specifically
included
in the
regulations
1
1
1
1
t
1
1
1
1
1
t
1
1
1
1 , ,
1
1
1
1
1
1 I
Enforced No en-
under forceable
general require-
standards ments
and
policies
2 5
, - > - , ,
2 5
2 3
2 3
2 3
2 3
2 3
2 3
2 3
2 3
2 3
-
2 3
2 3
2 3
2 3
2 3
2 3
2 3
2 3
2 3
2 3
Surface
Impoun
F.
Mining waste
Specifically
included
in the
regulations
1 :
~
1
1
1
1
1
1
1
1
1
1
t
1
t
1
1
1
1
1
1
1
Enforced
under
general
standards
and
policies
t.
2
t
t
t
2
2
2
2
2
^
2
2
Z
2
2
2
2
2
2
2 !
No en-
forcet
requii
ments
5
3
3
>
, >
;;
3
3
3
3
?
3
3
3
-3
3
3
3
3
3
3
'IV-4
-------
Types
Oil
Specifically
included
in the
regulations
t
1
1
1
1
1
1
1
1
1
1
t
1
1
$
1
1
1
1
1
1
G.
or gas waste
Enforced
under
general
standards
and
policies
Z
2
2
2
Z
2
2
2
2
2
Z
2
t
Z
- *;.„
2
2
2
2
2
2
No en-
forceable
require-
ments
5
?
3
3
3
3
3
3
3
3
'" *
*
5
5
3
3
3
3
3
3
3
Other (e.g
treatment
H.
., drinking water
sludges) [SPECIFY]:
Specifically
included
in the
regulations
1
t
1
1
1
1
1
1
1
1
> ~<.-j^y* • x-
/
T -' 4
- 4
1 -
t
1
1
1
1
1
1
1
enforced
under
general
standards
and
policies
2
2
2
2
Z
2
2
2
2
2
2
2
2
Z
2
2
2
2
2
2
2
No en-
forceable
require-
ments
J
3
5
3
3
3
3
3
3
3
3
3
3
3
J
3
3
3
3
3
3
IV-5
-------
N2. Please indicate (for each surface impoundment type) whether the following specific
requirements are included in formally proposed State regulations. [IF THERE ARE NO
FORMALLY PROPOSED REGULATIONS IN YOUR STATE, PLEASE PLACE A CHECK ( >/ ) IN THE BOX: ( |
AND SKIP TO N3.]
Specific requirements included
in formally proposed regulations?
* - • f : • - '
at* location standards (#«$**
; floodplainaj
b* Natural iir««a^C««ft*». Clay) - ,. ^ -
c* Synthetic liners.
-------
Types
E.
Agricultural
waste
Yes N£
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
t 2
1 2
1 2
1 ^
1 2
1 2
. 1 2
1 2
1 2
1 2
F.
Mining
waste
Yes N£
1 2
1 2
1 2'
1 2
1 2
1 2
1 2
1 2
1 2
1 2
t 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
G.
Oil or gas
waste
Yes No
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
, t 2
H.
Other (e.g. ,
drinking water
treatment
sludges [SPECIFY]:
. Yes _No
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
t 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
IV-7
-------
N3. In the table below, indicate whether your State currently requires permits, plan approval
or licenses/registration for each of the listed types of Subtitle D surface impoundments.
[PLEASE CIRCLE EITHER "1" OR "2" FOR EACH TYPE OF SURFACE IMPOUNDMENT FOR BOTH PERMITS AND
LICENSES.]
Surface impoundment type
a. Municipal wastewater
c. Municipal run-off
d. Industrial waste
e. Agricultural waste
h. Other (e.g., drinking water treatment sludges)
[SPECIFY]:
A.
Permit or
plan approval
required?
Yes No
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
B.
License or
registration
required?
Yes No
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
COMMENTS: [PLEASE EXPLAIN IF PERMIT REQUIREMENTS VARY WITHIN A CATEGORY, E.G. - SOME
INDUSTRIAL WASTE SURFACE IMPOUNDMENTS REQUIRE PERMITS AND OTHERS DON'T]
IV-8
-------
N4. How many of the active individual Subtitle 0 surface impoundments of each type in your
State currently have permits/plan approval or licenses/registration?
Surface impoundment type
a. Municipal wastewater
b. Municipal sewage sludge
c. Municipal run-off
d. Industrial waste
e. Agricultural waste
f. Mining waste
h. Other (e.g., drinking water treatment
sludges) [SPECIFY):
Number of indi-
vidual Subtitle
0 surface
impoundments
that have permits
or plan approval
Number of indi-
vidual Subtitle
D surface
impoundments
licensed or
registered
N5. Is there a written or published schedule of your State's permit fees for Subtitle D
surface impoundments? [CIRCLE ONLY ONE CODE]
Yes [PLEASE ATTACH A COPY OF THE
FEE SCHEDULE TO THE BACK OF
THIS QUESTIONNAIRE]
No
N/A [THERE ARE NO SURFACE IMPOUND-
MENT PERMIT FEES IN MY STATE]
N6. Please attach a copy of your State's Subtitle D surface impoundment regulations
(existing and proposed, if any) to the back of this questionnaire.
"IV-9
-------
IMPORTANT NOTE: 1984 REFERS TO CALENDAR
YEAR 1984 THROUGHOUT THE
REMAINING QUESTIONNAIRE.
0. ENFORCEMENT OF SURFACE IMPOUNDMENT REGULATIONS
01. How many inspections for compliance with State Subtitle D regulations were made during
1984 for each type of surface impoundment listed below? [COUNT INDIVIDUAL INSPECTIONS,
E.G., IF YOU HAD 100 SURFACE IMPOUNDMENTS AND EACH WAS INSPECTED TWICE DURING CALENDAR
YEAR 1984, YOUR NUMBER OF INSPECTIONS WOULD BE 200]
Surface impoundment type
Number of
inspections
during 1984
a. Municipal wastewater
b. Municipal sewage sludge
c. Municipal run-off
d. Industrial waste
e. Agricultural waste
f. Mining waste
g. Oil or gas waste
h. Other (e.g., drinking water treatment sludges) [SPECIFY]:
i. TOTAL NUMBER OF INSPECTIONS DURING 1984
IV-10
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02. How frequently are individual Subtitle D surface impoundments inspected for compliance?
[ENTER THE PERCENTAGE OF SURFACE IMPOUNDMENTS FALLING IN EACH FREQUENCY OF INSPECTION
CATEGORY]
Surface
impoundment
type
a. Municipal
wastewater
b. Municipal
sewage
sludge
c. Municipal
run-off
d. Industrial
waste
e. Agricultural
waste
f. Mining
waste
g. Oil or gas
waste
d. Other (e.g.,
drinking water
treatment
sludges)
[SPECIFY]:
Frequency of Inspection
A.
Never
Inspected
%
%
%
%
%
%
%
%
B.
Less than
once every
two years
V
/n
%
%
%
%
%
%
%
C.
Once
every
two
years
Of
/o
V
fQ
%
%
%
%
%
%
D.
Once
a
year
V
/o
%
V
/Q
O/
•4)
%
-------
03.
Do you have a checklist of criteria for inspections? [CIRCLE ONLY ONE CODE]
Yes [PLEASE ATTACH A COPY OF
CHECKLIST TO THE BACK OF
THIS QUESTIONNAIRE] . .
No
THE
04. In the table below, please describe the number and types of violations that were found
by your State's 1984 surface impoundment inspection program. In Columns A through H,
report the number of individual Subtitle D surface impoundments that had at least one
violation of the types listed below.
Violation type
b. Groundwater monitoring
e. Operational deficiencies
f. Other violations in 1984 [SPECIFY]:
Number of individual Subtitle D surface
A.
Municipal
wastewater
B.
Municipal
sewage
sludge
C.
Municipal
run-off
D.
Industrial
waste
*[PLEASE USE -THAT DEFINITION If CONTAMINATION THAT BEST APPLIES TO YOUR STATE WHEN ANSWERING
THIS QUESTION, I.E., THE DEFINITION USED IN YOUR STATE (e.g.,-IN REGS, ETC.]).
IV-12
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impoundments (by type) in violation in 1984:
E.
Agricultural
waste
F.
Mining
waste
G.
Oil or gas
waste
H.
Other (e.g.,
drinking water
treatment sludges)
[SPECIFY]:
a. Groundwater contamination
b. Groundwater monitoring
program deficiencies
c. Surface water
contamination
d. Air contamination
e. Operational deficiencies
and other minor violations
f. Other violations in 1984
IV-13
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P. THE NUMBER OF ACTIVE INDIVIDUAL SUBTITLE D SURFACE IMPOUNDMENTS AND THE
NUMBER OF ESTABLISHMENTS WITH ACTIVE SURFACE IMPOUNDMENTS
The objective of this section is to obtain information on the number of active individual
Subtitle D surface impoundments (both permitted and unpermitted), and the number of estab-
lishments with Subtitle D surface impoundments. [SEE GENERAL INSTRUCTIONS FOR A DIAGRAM
AND DEFINITIONS OF SURFACE IMPOUNDMENT AND ESTABLISHMENT]
P1. During 1984, how many individual Subtitle D surface impoundments were active in your
State? (For the purpose of the questions in Section D, the term "active" means "received
waste in 1984.")
NUMBER OF ACTIVE
INDIVIDUAL SUBTITLE D
SURFACE IMPOUNDMENTS IN 1984:
P2. In the table below, please enter the number of active individual Subtitle 0 surface
impoundments in 1984 in each of the following categories.
Surface impoundment type
h. Other (e.g., drinking water treatment sludges) [SPECIFY]:
i. TOTAL SHOULD EQUAL RESPONSE TO QUESTION P1 :
Number of active
individual Subtitle D
sur face impoundments
in 1984
IV-14
-------
P3. How many establishments in your State had active Subtitle D surface impoundments in 1984?
(An establishment is defined as a single physical location where business is conducted
or where services or industrial operations are performed by a municipality, corporation,
or other public or private entity. An establishment may have two or more surface
impoundments).
NUMBER OF ESTABLISHMENTS
WITH ACTIVE SUBTITLE D
SURFACE IMPOUNDMENTS IN 1984:
P4. In the table below, please enter the number of individual active Subtitle D surface
impoundments in 1984 (by surface impoundment type) in each of the ownership categories
listed.
Surface
impoundment
type
a. Municipal
wastewater. . . .
b. Municipal
sewage sludge.
c. Municipal
run-off
d. Industrial
waste
e. Agricultural
f. Mining waste..
g. Oil or gas
d. Other (e.g.,
drinking water
treatment
si udges )
[SPECIFY]:
Number of individual active Subtitle D surface impoundments
A.
Owned by
State
government
8.
Owned by
local
governments
C.
Owned by
Federal
government
D.
Privately
owned
E.
Other*
F.
Total number
of surface
impoundments
by type
[THIS SHOULD
EQUAL THE
NUMBER IN P2]
* [SPECIFY "OTHER" OWNERSHIP CATEGORY, IF USED]:
IV-15
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Q. SURFACE IMPOUNDMENT DESIGN AND OPERATING CHARACTERISTICS
The objective of this section is to determine the design and operating characteristics of
Subtitle D surface impoundments.
Q1. In the table below, please enter the number of active individual Subtitle D surface
impoundments in 1984 (by surface impoundment type) in each of the surface impoundment
acreage categories listed. (Acreage should include active, inactive, and closed portions
of each surface impoundment. Column H totals should equal the distribution of individual
surface impoundments in Question P2.)
Surface impoundment type
Number of active individual Subtitle D
A.
Less than
one tenth
acre
B.
0.1 - 0.4
acres
C.
0.5 - 0.9
acres
a. Municipal wastewater
b. Municipal sewage sludge ,
c. Municipal run-off ,
d. Industrial waste
e. Agricultural waste ,
f. Min ing waste ,
g. Oil or gas waste ,
h. Other (e.g., drinking water treatment sludges)
[SPECIFY]:
i. TOTAL NUMBER OF SURFACE IMPOUNDMENTS
BY ACREAGE CATEGORY
IV-16
-------
surface impoundments with:
0.
1 - 5
acres
E.
6-10
acres
F.
11 - 100
acres
G.
More than
100 acres
H.
Total number
of surface
impoundments
by type
a. Municipal wastewater
b. Municipal sewage sludge
c. Municipal run-off ;
d. Industrial waste
e. Agricultural waste
f. Mining waste
g. Oil or gas waste
h. Other
IV-17
-------
Q2. In the table below, please enter the number of active individual Subtitle D surface
impoundments (by surface impoundment type) according to the amount of waste received in
1984. Column G totals should equal the number of surface impoundments in Question P2.
Number of active individual Subtitle 0 surface
Surface impoundment type
h. Other (e.g., drinking water
treatment sludges) [SPECIFY]:
i. TOTAL NUMBER OF SURFACE
IMPOUNDMENTS BY CATEGORY
A.
Received less
than 50,000
gallons per
day
6.
Received
50,000 -
99,999
gallons
per day
1
C.
Received
100,000 -
499,999
gallons
per day
D.
Received
500,000 -
999,999
gallons
per day
IV-18
-------
impoundments by amount of waste received in 1984:
E.
Received
1,000,000 -
9,999,999
gallons per
day
F.
Received
10,000,000
or more
gallons
per day
G.
Total number of
surface impound-
ments by type
[THIS SHOULD EQUAL
THE NUMBER IN 92]
a. Municipal wastewater
b. Municipal sewage sludge
c. Municipal run-off
d. Industrial waste
e. Agricultural waste
f. Mining waste
g. Oil or gas waste
h. Other
•IV-19
-------
Q3. In the table below, please enter the number of active individual Subtitle D surface
impoundments (by surface impoundment type) that had groundwater, surface water, and air
emissions monitoring in 1984.
Surface impoundment type
Number of active individual Subtitle D
surface impoundments that had:
A.
Groundwater
Monitoring
B.
Surface
Water
Monitoring
C.
Air
Emissions
Monitoring
a. Municipal wastewater....
b. Municipal sewage sludge.
c. Municipal run-off
d. Industrial waste
e. Agricultural waste ,
f. Mining waste... ,
g. Oil and gas waste ,
h. Other (e.g., drinking water treatment sludges)
[SPECIFY]:
e. TOTAL NUMBER OF SURFACE IMPOUNDMENTS
WITH EACH TYPE OF MONITORING:
IV-20
-------
(Please continue....)
IV-21
-------
Q4. In the table below, please estimate the number of active individual Subtitle D surface
impoundments (by surface impoundment type) that had or used the following release
prevention/management methods in 1984:
Management method
b. Natural liners (e.g., clay)
c. Leak detection systems .
e. Waste restrictions (ban on
certain Subtitle D waste types). . .
Number of active individual Subtitle 0
A.
Municipal
wastewater
8.
Municipal
sewage
sludge
C.
Municipal
run-off
D.
Industrial
waste
IV-22
-------
surface impoundments
E.
Agricultural
waste
F.
Mining
waste
G.
Oil or gas
waste
H.
Other (e.g., drinking
water treatment sludges)
[SPECIFY]:
a. Synthetic liners
b. Natural liners
c. Leak detection systems
d. Overtopping controls
e. Waste restrictions
f. Discharge permit
•IV-2 3
-------
Q5. Certain non-household hazardous wastes are exempted from Federal and some State hazardous
waste regulations if generated in small quantities. Please indicate the percentage of
Subtitle D surface impoundments of each type that receive such wastes?
a.
b.
c.
d.
e.
f.
0.
h.
Surface impoundment type
Other (e.g., drinking water treatment
sludges) [SPECIFY):
Percent that receive
exempted non-household
hazardous wastes.
%
\ »
%
%
%
%
%
%
IV-2 4
-------
R. AVAILABILITY OF SURFACE IMPOUNDMENT DATA
R1. In the table below, please estimate the proportion of individual Subtitle D surface
impoundments (by surface impoundment type) for which your State has each type of
monitoring data available:
Surface
impoundment
type
a. Municipal
wastewater
b. Municipal
sewage
sludge
c. Municipal
run-off
d. Industrial
waste
e. Agricul-
tural
waste
f. Mining
waste
g. Oil and
gas waste
h. Other
(e.g.,
drinking
water
treatment
sludges)
[SPECIFY]:
A.
Groundwater monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH SURFACE IMPOUND-
MENT TYPE]
None Some Most
(OS) (1-5055) (>50S)
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
8.
Surface water monitor-
ing data available for:
[CIRCLE ONE CODE FOR
EACH SURFACE IMPOUND-
MENT TYPE]
None Some Most
(OX) (1-50X5) O50SS)
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
C.
Air emission monitoring
data available for:
[CIRCLE ONE CODE FOR
EACH SURFACE IMPOUND-
MENT TYPE]
None Some Most
(055) (1-5055) O5055)
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
1 2 3
IV-2 5
-------
R2. Please estimate the number of individual Subtitle 0 surface impoundments (by surface
impoundment type) for which your State has case studies. (Case studies include monitoring
data, but in addition include a sufficient level of detail on site design and cpsrating
practices to provide some indication of the causes for success or failure of the surface
impoundment to protect human health and the environment. Some case studies may also
include information on design and operating costs of the surface impoundment.)
[IF YOU ARE NOT AWARE CF ANY CASE STUDIES OF SUBTITLE D SURFACE IMPOUNDMENTS IN YOUR
STATE, PLEASE PLACE A CHECK ( x/ ) IN THE BOX: | |, AND SKIP TO QUESTION R4.]
Surface impoundment type
a. Municipal wastewater
b. Municipal sewage sludge
d. Industrial waste
e. Agricultural waste
g. Oil or gas waste
h. Other (e.g., drinking water treatment
sludges) [SPECIFY]:
Number of individual Subtitle D
surface impoundments
A.
With case studies
B.
With case studies
that include design
and operating costs
R3. List any alternate sources of case study information that you know of in your State (e.g.,
local governments that have surface impoundment case study data).
SOURCE:
CONTACT PERSON
(AREA CODE) TELEPHONE
IV-2 6
-------
R4. Does your State already have a list (or file) of establishments with Subtitle D surface
impoundments?
Yes [GO ON TO QUESTION R5] 1
No [SKIP TO QUESTION 51] 2
R5. In what format is(are) the list(s)? [EXAMPLES: ON A COMPUTER FILE, IN A CARD FILE, ON A
WORD PROCESSING DISK, ETC.]
R6. What does(do) the list(s) cover? [EXAMPLES: PERMITTED SURFACE IMPOUNDMENTS ONLY,
INDUSTRIAL SURFACE IMPOUNDMENTS ONLY, ALL TYPES OF SURFACE IMPOUNDMENTS THAT ARE LARGER
THAN ONE ACRE, ETC.]
R7. If possible, please attach copies of any list(s) to this completed questionnaire. If this
is not possible, please indicate below how EPA could obtain a list of surface impoundments
in your State.
'IV-2 7
-------
S. CONTACT INFORMATION AND COMMENTS AND ATTACHMENTS: SURFACE IMPOUNDMENTS
51. Please identify a contact person for this suface impoundments section of the survey,
should it be necessary to clarify responses:
Contact Name:
Title:
Agency/Program:
Telephone: ( ) Ext.:
52. COMMENTS - Please include any comments or further amplification of responses to Sections
N through R below or on attached sheets.
S3. CHECKLIST OF ATTACHMENTS TO PART IV - SURFACE IMPOUNDMENTS:
[Please check ( ) the appropriate box if you have attached the following]:
a. Schedule of State permit fees (Question N5) ,
b. State Subtitle D surface impoundment regulations (Question N6).
c. Checklist of State critieria for inspections (Question 03). . .
d. List of establishments with Subtitle D surface impoundment
(Question R7) ,
e. Attached comment sheets (Question S2)
IV-2 8
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
STATE SUBTITLE D PROGRAM QUESTIONNAIRE
CERTIFICATION STATEMENT
THE DIRECTOR OF STATE SOLID WASTE PROGRAMS, OR HIS AUTHORIZED REPRESENTATIVE,
MUST SIGN AND DATE THE CERTIFICATION WHERE INDICATED. THE PRINTED OR TYPED NAME
OF THE PERSON SIGNING THE CERTIFICATION MUST ALSO BE INCLUDED WHERE INDICATED.
CERTIFICATION
I certify that I have examined the information submitted in this and all attached documents,
and that the submitted information is accurate, and as complete as possible.
PRINT OR TYPE NAME
SIGNATURE
DATE SIGNED
AFTER COMPLETING THIS QUESTIONNAIRE, RETURN IT TO EPA IN THE
ENVELOPE ENCLOSED IN THE QUESTIONNAIRE PACKAGE.
PLEASE RETURN ALL COMPLETED SECTIONS OF THE MASTER QUESTIONNAIRE
IN THE SAME ENVELOPE.
V-l
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