OOOR85100
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                   PERMIT APPLICANTS'  GUIDANCE MANUAL                     [
                 FOR-.EXPOSURE INFORMATION  REQUIREMENTS

                         UNDER RCRA SECTION 3019
                                  FINAL
                         U.S. Environmental Protection Agency
                         K^;:;r,n 5, Library (5PL-16)
                         :? ;  o. Dearborn St -eet, Room 1670
                         Cnicago, 1L  60604
                         Office of Solid  Waste
                   ^'
             United  States Environmental Protection Agency

                        Washington, D.C.   20460
                               July 3.,  1985                     '. '**
                                                                           , '.
                                                                           ;^

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                      ACKNOWLEDGEMENTS
This manual was prepared by the; Land Disposal Branch and the
Permits Branch of thซ Office of Solid waste.  EPA personnel
who were major contributors to this document"" include Arthur
Day, .Terry Grogan, Robert Kayser, and Glen Galen:.  Many other
EPA staff served on the Exposure Information Guidance Workgroup
and provided expeditious review, and useful comments during the
preparation of the Manual.   Betsy Marcotte of Sobotka a.id
Company also played a significant role in assisting in the
preparation of this document.

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                        TABLE OF CONTENTS
Section 1.0  Introduction

  1.1  RCRA Section 3019: The Exposure Information Provision
    1.1.1  Applicability of the Provision
    1.1.2  Scope of Provision
    1.1.3  Regulatory Codification
  1.2  Purpose and Outline of the Exposure Information Process
    1.2.1  General.Procedures         ,     '
    1.2.2  Relationship to the RCRA Permitting Process
  1.3  General Guidance on Information Requirements

Section 2.0 Information Requirements

  2.1  General Information
  2.2  Pathway-Specific Information
    2.2.1  Ground Water
    2.2.2  Surface Water
    2.2.3  Air
    2.2.4  Subsurface Gas
    2.2.5  Soil
  2.3  Transportation Information
  2'. 4  Management Practice Information
  2.5  Known Release Information

Section 3.0  Exposure Potential of the Unit

  3.1  Introduction
  3.2  Potential for Human Exposure Via the Ground-Water Pathway
  3.3  Potential for Human Exposure Via the Surface-Water Pathway
  3.4  Potential for Human Exposure Via the Air Pathway
  3.5  Potential for Human Exposure Prom Subsurface Gas Releases
  3.6  Potential for Human Exposure From Releases to Soil
  3.7  Potential for Human Exposure From Transportation-Related
       Releases
  3.8  Potential for Human Exposure From Worker-Management
       Practices

Appendix A.  Information Requirements Checklist and Part B
             Cross-Reference

Appendix B.  Regional Contacts

Appendix C.  State Solid and Hazardous Waste Agencies

Appendix D.  List of Chemicals to be Determined in Landfill
             Leachate, Surface Impoundment Contents, or
             Accepted Wastes

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                        U.O  INTRODUCTION

     The purpose of thi's document is to provide owners and
operators of hazardous waste landfills and surface impoundments
that are subject to permitting under the Resource Conservation and
Recovery Act of 1976 (RCRA) with guidance for submitting informa-
tion on the potential for public exposure to hazardous wastes, as
required by Section 3019 of RCRA.  This requirement was established
by the 1984 Hazardous and Solid Waste Amendments to RCRA.
     This document is divided into three sections with four
appendices.  Section 1" briefly describes the statutory requirement
(including who is subject to the requirement, deadlines, and the
general scope.of.the information which must be submitted); discusses
the purposes of the exposure information process (including its
relationship to RCRA permitting and.the "Continuing Releases"
provision); and.presents general.guidance on information require-
ments.  Section 2 delineates specific information items which must
be submitted to satisfy Section 3019,,, beyond the information
already contained in the RCRA-permit application.  These "new"
information items include data on various exposure pathways (e.g.,
surface water), transportation, management practices, and past
or current releases.
     In addition to submitting these information items, applicants
must provide a, narrative discussion addressing the exposure potential
related to their landfill or surface impoundment unit.  Section 3
provide? general guidance on how applicants should,structure this
discussion^  That Section provides examples of . how^.,specif ic
location, design, and .operating characteristics affect exposure.

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                              1 - 2
potential for each of the exposure pathways.   Appendix A of this
Manual provides a checklist which the applicant should use to
cross-reference the location of information.already included in
the RCRA Part B permit application relevant to exposure assessment.
(Such Part B information need not be resubmitted to meet Section
3019 requirements.)  The checklist should also be used to indicate
the location of other exposure information, not included in the
Part B, which has already been submitted to the Agency.  Appendix 3
contains a list of EPA contacts for further information.  Appendix '
is a list of State solid and hazardous waste agencies.  Finally,
Appendix D lists chemicals of special interest in waste analysis.

1.1  RCRA SECTION 3019:  THE EXPOSURE INFORMATION PROVISION
     Section 3019 of the Hazardous and Solid Waste Amendments of
1984 establishes a new program for the collection, reporting,
and analysis of information on the potential human exposure from
releases of contaminants from hazardous waste landfills and surface
impoundments.  Section 3019 addresses public concern that releases
of hazardous waste and hazardous constituents from these units
may pose a potential risk to public health.  The full text of
Section 3019 is included as Figure 1.                             " "
1.1.1  Applicability of the Provision             "
     Beginning on August 8, 1985, nine months after the enactment
of the Hazardous and Solid Waste Amendments,  all Part B permit
applications for surface impoundments and landfills must be
accompanied by information that is ". . . reasonably ascertainable
by the owner or operator on the potential for the "public to be"'
exposed to hazardous wastes 'or hazardous'constituents through

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 FIGURE 1.0       Resource Conservation and Recovery  Act of  1976;
                   Subtitle C -  Hazardous Waste  Management

 Section 3019.   Exposure Information and Health Assessments
 •>'•.*••,..                i-  & .? .4. ซ •  -

 " ~  "Sec;  J019. (a) EXPOSURE INFORM ATION.-Beginning on the date nine months
•fter the enactment  of the Hazardous and Solid Waste  Amendments  of  1984, each
application for a final determination regarding a permit  under -section 3005(c)  for a
landfni  or iurftce impoundment  shall be accompanied  by  information  reasonably
ascerUinable by the owner or operator on  the potential for the  public to be exposed to
hazardous wastes or hazardous constituents  through releases related to the  unit.  At a
           ch information must address:
      .     "(1)  reasonably forteeable -potential releases from both normal operations
     and accidents  at the unit, including releases associated with transportation to or
     ifrom the unit;     .      -;
           "(2)  the potential pathways of human exposure to hazardous wastes or
    .constituents resulting from the, releases described under paragraph (1); and,
     '      "13)  the "potential magnitude and nature of the human closure  resulting
                            '"  '
The owner or operator of a landfill or surface impoundment for which an application for
sucK a final determination under section 3005(c) has been submitted prior to the date of
enactmtnt  of Uปe Hazardous and  Solid Waste  Amendments of 1984 shall submit  the
Information required by'this subsection to the Administrator (or the SUte, in the case of
a State with an authorized program) no later than the date 9 months after such date of
                    '       "    "
                ,
           M)  tfป Administrator  (or the < State, in the case  of a State with an
     authorized program) shall make the information required by subsection (a), together
 T , * jvitg' other  re^eVaflt information, avaQable to the Agency for Toxic Substances and
  -^.Diseas* Registry ^established by section 104(0 of the Comprehensive Environmental
  ~ . Response, Compensa.tion and Liability Act of 1980.
 .  ' :  ^Si , "(2), Wh%i1eyer In'ifit judgment of thซ Administrator, or the State (in the ease
  .   of a .State with an authorized program), a landfill or a surface impoundment pcses a
 "    substantial  potential risk  to human health, due to the existence  of releases  of
     hazardous  constituents,  the   magnitude  of  contamination  with   hazardous
     constituents  which  may be the result of a  release, or the magnitude  of the
     population exposed to such release or contamination, the Administrator or the State
     (with the concurrence of the Administrator) may request the Administrator of the
     Agency for Toxic Substances and Disease Registry to conduct a health assessment
     in connection with such facility and take other appropriate  action with respect to
     such  risks  as  authorized by  section  104(b)  and  (i)  of  the Comprehensive
     Environmental  Response, Compensation and Liability  Act of 1980. If  funds  are
     provided in connection with such request the Administrator of such Agency shall
     conduct such health assessment.
     "(c) MEMBERS OF THE PUBLIC.— Any member of the public may submit evidence
of releases of or exposure to hazardous constituents from such a facility, or as to the
risks or health effects associated with such releases or exposure, to the Administrator of
the Agency for Toxic Substances and Disease Registry, the Administrator, or the State
(in the case of a  State with an authorized program).
     "(d) PRIORITY.— In  determining the order in which to conduct health assessments
under this subsection, the  Administrator of the Agency for Toxic Substances and Disease

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FIGURE  1.0    (continued)
Registry shall five priority to those facilities or sites at  where there is documented
evidence of release of hazardous constituents,  at  which the potential risk to human
health appears highest, and for  which in the judgment of the Administrator of such
Agency existing health assessment  data  is  inadequate to  assess the potential  risk to
human health as provided in subjsection (f).             • . •  ;
     "(e) PERIODIC REPORTS.— The Administrator of such Agency shall issue periodic
reports which include the  results of all the  assessments, carried out under this section.
Such assessments or other activities shall be reported after appropriate peer review.;.!
     "(f) DEFINITION.— For the purposes of this section, the term  health assessments'
shall  include preliminary assessments of the potential risk to human health  posed by
individual sites and facilities subject to this section, based on such factors as the nature
and extent  of contamination, the  existence of potential for pathways of human exposure
(including  ground   or  surface water  contamination,  air < emissions,  and  food chain
contamination), the size and potential susceptibility of the  community within 'the likely
pathways of exposure, the comparison of expected human exposure levels to the short-
term  and long-term health effects associated  with  identified contaminants and any
available recommended exposure or tolerance limits  for such  contaminants, and the
comparison of existing morbidity and mortality data on diseases that may be associated
with the observed  levels of exposure. The assessment shall  include an evaluation iff the
risks  to the  potentially affected population from  all sources  of such contaminants,
cinluding known point or nonpoint sources other than the site or facility in. question.  A
purpose of such preliminary assessments  shall be to help determine whether  full-scale
health or epidemiological studies  and medical evaluations of exposed populations shall be
undertaken.        •                     ,  ,
     "(g) COST RECOVERY.— In any case in  which a health assessment performed under
this  section  discloses the exposure of  a  population to the  release  of a hazardous
substance,  the costs of such health  assessment may be recovered as a cost bf; response
under  section 107  of the  Comprehensive Environmental Response, Compensation, and
Liability Act  of 1980  from  persons causing or contributing  to such release of such
hazardous substance or, in the case of multiple .releases contributing to such exposure, to
all such release.                                          "'./.„*

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                              1-3                              .
releases related to the units."  The owner or operator of a land-
fill or surface impoundment 'that submitted a Part B permit
application before August'8, '1985, must also submit exposure
information as required by Section 3019.  The information must
be submitted to the EPA Regional Administrator no later than
August 8, 1985.
     The information must be sent to EPA, since it is very unlikely
that any States wil.l receive RCRA authorization for the exposure
Information provision by August 8, 1985-  EPA will work coopera-
tively with States in the review of this information.  Owners and
operators are encouraged to also submit a copy of the exposure
information to the State RCRA permitting agency.  State agencies
will generally be Involved in permitting the facilities subject to
this requirement.  In addition, States will be authorized In the
future to administer'the exposure information provision.  Providing
copies of the information to the States should, therefore, help to
expedite the overall permitting process.  (Appendices B and C contain
lists of Regional and State agencies.)
1.1-. 2  Scope -'of the Provision
     The exposure information requirement under Section 3019(a)
provides that, at a minimum, the owner or operator submit
information addressing the following elements:
     "(1) reasonably foreseeable potential releases from
     _: .  .both normal operations and accidents at the unit,
       : "-." including releases associated with transportation
 ..._-.,-...; to or from the unit;
     -,'K 2)-':'the potential pathways of human exposure to

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                              1 - 4

          hazardous wastes or constituents resulting from
          the releases described under paragraph (1);  and
     "(3) the potential magnitude and nature of the human
          exposure resulting from such releases."
     Section 3019(b) suggests that the permitting agency is
responsible for conducting a preliminary assessment of the
exposure information.  If the Regional Administrator or the State
determine that "a 1-andfill or surface impoundment poses a substan-
tial potential risk to human health, due to the existence of
releases of hazardous constituents, the magnitude of contamination
with hazardous constituents which may be the result of a release,
or the magnitude of the population exposed to such release or
contamination," they may request assistance from the Agency for
Toxic Substances and Disease Registry (ATSDP).  The ATSDR was
established by Section 104(i) of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA) to
conduct health assessments.
     Section 3019(c) allows members of the public to submit relevant
information on releases, exposure, risks, or health effects to SPA,
authorized States, or ATSDR.
1.1.3  Regulatory Codification
     In order to add RCRA Section 3019 to the Code of  Federal
Regulations (CPR), EPA will in the near future publish a final rule
in the Federal Register, adding paragraph (j) to existing 40 CFR
Section 270.10.  This new provision will basically repeat.the language
of Section 3019(a), regarding applicability, content,  and deadlines
for the exposure information requirement.

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                              1-5
1.2  PURPOSE AND OUTLINE OP THE EXPOSURE INFORMATION PROCESS
     Section 3019 suggests that exposure information will be used
by EPA and authorized States in determining whether a health
assessment of a landfill or surface impoundment  should be
conducted.  EPA believes that exposure information can also serve
other purposes, related to the RCRA permitting process (especially
the new provision for corrective action for continuing releases).
Consequently, EPA intends to use exposure information in the
following ways:
     0 To ensure that appropriate emergency actions are taken,
       including alerting the public to current  adverse exposures
       to hazardous constituents, when immediate threats are
       evident.
     0 To examine prior, current, and potential  exposures and
       to refer cases of actual exposure for health assessments
       of the exposed individuals.
     0 To establish permit conditions necessary  to ensure the
       prevention of situations that could present a significant
       risk to human health.
     0 To supplement the corrective action investigation and
       response process under the Continuing Releases provisions
       (RCRA Sections 3004(u) and 3008(h)).
     0 To support Agency actions on other related RCRA provisions
       (e.g., petitions for waivers from the prohibition on the
       land disposal of specified wastes or waivers of the surface
       impoundment retrofitting requirement; Alternate Concentration
       Limit proposals).

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                              1-6
     The following sections  provide a brief outline  of the exposure
information process and expand upon the relationship of this  process
to RCRA permitting and continuing release programs.
1.2.1  General Procedures
     Owners or operators must submit their completed Exposure
Information Report (EIR) to  the EPA Regional Office  for review.
A list of EPA Regional Offices and the names and telephone numbers
of contacts for exposure information is presented in Appendix B.
Copies of the EIR should also be sent to State agencies.   A list
of State solid and hazardous waste agencies is contained in
Appendix C.
     EPA will review the EIR for compliance with Section 3019
requirements, as outlined in this Manual.  The owner or.operator
will be required to furnish  additional information if the review
indicates that the submittal is incomplete.
     The regulatory response to the submitted information will
vary, depending on what the  information reveals.  As noted earlier,
a health assessment will be  conducted whenever the unit poses a
"substantial potential risk  to public health." In some cases,
the submitted information may meet the requirements  outlined  in
this Manual but still not provide clear evidence regarding the
existence of or potential for releases, much less the likely
exposure and health impacts  of any releases.  When the information
identified by this document  is submitted but the situation is still
unclear, EPA may use its other authorities, including RCRA Sections
3004(u), 3008(h), 3013, and  7003, to obtain more definitive
indications of releases and  exposures.

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                              1-7
1.2.2  Relationship to the RCRA Permitting Process
     In developing Section 3019, Congress intended to separate the
exposure information provision from the facility permitting require-
ments in Section 3004.  Although the exposure information is  to
accompany a permit application, it need not be in hand for a  permit
application to be declared complete and a permit to be issued (see
130 Congressional Record S9187; daily edition July 25, 1984).
     As a matter of policy, the Agency intends to implement this
provision in a manner that will have practical application in
permit development whenever possible.  For example, members of
the public may be interested in the exposure information submitted
by the permit applicant and may wish to discuss the exposure
information during the permitting process.  EPA and State permit
writers may find the information in the EIR useful in establishing
permit conditions and making permit issuance or denial decisions.
     The Regional Administrator may add requirements to a facility
permit to mitigate the potential for exposure, even when there is
no current exposure as a result of a past or current release.  For
example, these permit conditions could address circumstances  directly
related to the design and/or operation of the facility that could
contribute to a potential release and subsequent exposure in the
future.  The permit conditions could also address siting factors
related to the location of a unit that could create the potential
for a significant risk in the future.  Authority for such permit
conditions can be found in the RCRA facility standards (40 CFR
Part 264) and the new statutory language of RCRA 3005(c)(3):  permits
"shall contain such terms and conditions as the Administrator  (or

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                              1 - 8
the State) determines necessary to protect public health and the
environment."
     EPA also intends that Section 3019 supplement the new
Continuing Release provisions added by the Hazardous and Solid
Waste Amendments of 1984 (Section 3004(u) and 3008(h)).  The
Continuing Release authorities will generally be used when it is
unclear from existing information if a release has occurred or
whether the release, poses a substantial threat.  The investigations
conducted under Sections 3004(u) and 3008(h) will result in more
complete information which can then be used in developing corrective
action response measures and, in cases when actual exposure has
occurred which poses a substantial potential risk to human health,
pursuing a health assessment.  The information contained in the EIR
may also prove helpful in determining the scope of any clean-up
required under Sections 3004(u) or 3008(h) (or other authorities)
and the priority of such action.
1.3  GENERAL GUIDANCE ON INFORMATION REQUIREMENTS
     The exposure information required under Section 3019 is to
be "reasonably ascertainable by the owner or operator."  EPA
believes that the owner or operator of a facility who has
submitted or will submit a RCRA permit application should have
most of the necessary information at hand to complete the Exposure
Information Report (EIR).  The Part B permit application is the
obvious source of much of that information, and this Manual uses
the Part 3 as the heart of the EIR.  Other information which may
be available to the permit applicant beyond the Part B, such as
summaries of worker exposure records, medical files, insurance

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                              1-9
records and accident logs,  will also prove valuable in preparing
the EIR.
    • As noted earlier, the  owner or operator does  not have to
resubmit information included in the Part B application for the
purposes of the exposure information requirement.   (Furthermore,
the owner or operator need  not resubmit other information
discussed in this Manual, if that information was  provided to
EPA in other contexts, e.g., enforcement proceedings or other
permit actions.  The applicant must note the specific location
and nature of that information in the EIR.)  Appendix A outlines
which Part B items are relevant and allows the applicant to note
where in the Part B application the information is found.  If
the applicant has submitted information on releases or exposure
from the units of concern in response to the Continuing Release
provision, this should be noted in particular.  This approach
assumes that the applicant's Part B submittal will meet the
informational requirements  of 40 CFR Sections 270.14-21, as
appropriate.  Part B information which is incomplete or techni-
cally deficient in terms of those requirements will also generally
be inadequate in terms of the Section 3019 exposure information
requirements.
     EPA will need some information not usually found in Part 3
applications in order to carry out Section 3019.  Section 2 of
this Manual provides a specific discussion of each of these items,
which are also included as  "Additional Information" items in
Appendix A.  Generally, this will be information which the

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                               1-10
 applicant already has onsite or in his office, or which can be
 readily obtained without significant expenditures of time or
 money.  If information required in Section 2.0 is already existing
 (e.g., available on-site or at local firms or government agencies)
 and is accessible to the owner or operator (e.g., can be obtained
 by visiting or phoning an office), the owner or operator must
 submit it.  Applicants must indicate in the EIR why they were
 unable to secure any information which is not submitted.
      EPA does not expect applicants to develop major, expensive new
• pieces of information (e.g., new aerial photos or land use maps),
 because of the statutory language that exposure information be
 "reasonably ascertainable." However, if applicants have already
 developed or have easy access to more sophisticated or expensive
 information or analyses which are related to the requirements of
 Section 3019 (e.g., exposure models, actual health data from
 previous health assessments), such information must be identified
 and included in the EIR.  In addition to the minimum requirements
 outlined in this Manual, applicants may on their own initiative
 develop and submit additional information and analyses.
      Applicants who provide all of the exposure information and
 discussion described in this Manual (either in the Part B or the
 EIR) will generally be considered to have met the Section 3019
 information submittal requirement.  Depending on the nature of
 that information, however, EPA may need to follow up with
 additional inquiries, as discussed earlier in this Section.

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              2.0  INFORMATION REQUIREMENTS





     Much of the information necessary to develop the Exposure



Information Report (EIR)  is available in a properly completed



RCRA permit application.   When submitting an EIR, the applicant



should cross-reference the sections of the Part B that contain



relevant exposure information.  Appendix A, which contains a



checklist for the relevant Part B information,  must be completed



by the applicant.  This cnecklist provides a cross-reference



to the location of the Part B data, so that anyone reviewing



the EIR will be able to obtain easy access to the information



in the permit application.



     The checklist also outlines the additional information



beyond the Part B that must be submitted in the EIR.  This



Section of the Manual provides guidance for the EIR requirements



which are not generally found in Part B permit  applications.



These additional information requirements are briefly described



in the following sections: (2.1) general information; (2.2)



pathway-specific information; (2.3) transportation information;



(2.4) management practices information; and, (2.5) known release



information.  The information items described here correspond



to those in the "Additional Information" portions of Appendix A.



     Please note that this Manual requires the  identification



on maps of a number of physical objects (e.g.,  drinking water



wells) within specified distances from the surface impoundment



or landfill unit.  The distances specified were chosen to be



consistent with the distances used in the CERCLA Hazardous

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                             2-2



Waste Site Ranking System.  Applicants are encouraged to provide



such information on one or two maps (rather than separate maps for



each requirement) to the extent possible.  The scale of the map(s)



must be sufficient to clearly indicate the items of concern; a



scale of 1 inch to 2000 feet should be the minimum requirement,



in most cases.



     The owner or operator must submit the information described



below/  unless the -information has already been provided, either in



the Part B application or in response to information requests by EPA,



e.g., under the Continuing Release provision (Section 3004(u)).  The



applicant should identify the location of the relevant information



in the  documents previously submitted.  The Agency may have a need



for additional  exposure-related information to support corrective



action  investigations and to examine the need for case referrals



for health assessments.  The Agency may use other authorities



(e.g.,  RCRA Sections 3004(u), 3008(h), 3013, and 7003) to gather



any further exposure-related information.



2.1  GENERAL INFORMATION



     The general information described below includes additional



data beyond the Part B concerning the wastes handled, the area



around  the facility, inspection and compliance records, and



insurance information.   Applicants must provide:



     0   Any health or risk assessment information and reports on



        the units.   This includes information prepared in relation



        to liability insurance or for any other purpose.  Many



        insurance underwriters perform an examination of the



        sources of  releases,  transport pathways, and potential



        receptors in order to identify high risk sites.  Any

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                        2 - 3
   insurance claims and settlements relating to the operation
   of the units of concern must also be summarized.
 0  Zoning and land use maps of the area surrounding the site,
   indicating the current and potential zoning and land use
   activities.  Such maps are usually available from local
   government agencies.  These maps should, at a minimum,
   extend outward from the unit for a radius of four miles.
 0  Recent, existing aerial photographs of the facility area.
   These are available from local firms engaged in regional-
   planning, local government agencies, State agencies (high-
   way department, agricultural or forestry department), USGS,
   or the U.S. Soil Conservation Service.  The owner/operator
   should include any recent stereophotos, if available.
 0  Identify the types of existing waste analyses, not already
   submitted in the Part B, that are representative of wastes
   routinely accepted (both in the past and currently).
   Summarize the results of the analyses in tabular form,
   including the presence and approximate concentration
   ranges of constituents.  Examples of such information
   include analyses of chemical constituents in the waste
   streams, landfill leachate, or impoundment contents.  The
   analyses could be detailed chemical analyses, such as a
   scan for the priority pollutants identified under the Clean
   Water Act, or more limited analyses, such as generator
   data sheets or analyses for constituents known to be in
   the waste streams.  These analyses also include additional
   analyses that may have been performed in the course of
   preparing any delisting petitions, NPDES permit discharge
:/:-analyses, or waste/leachate liner compatability testing.

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                     2-4





    In most cases, EPA recommends that the applicant



provide a representative analysis of the ten largest waste



streams (by volume) handled by the facility as well as of



the wastes contained in surface impoundments and any leachate



from landfill leachate collection systems.  (If such analysis



is submitted in response to the previous paragraph, that will



satisfy this recommendation.)  This analysis should determine



the presence and concentrations (or range of concentrations)



of hazardous constituents.  Section 3019 is concerned with



potential public exposure to all hazardous wastes or hazardous



constituents.  Given the time available, however, we recommend



that this analysis be conducted for the constituents listed in



Appendix D of this Manual.  Representative samples of land-



fill leachate and surface impoundment wastes may be obtained



by compositing samples from the same unit.  (EPA publication



SW-846—Test Methods for Evaluating Solid Waste should be



consulted for recommended sampling and analysis procedures.)



    In lieu of the recommended waste analysis, applicants may



choose to submit a discussion of how existing waste stream,



impoundment or leachate analyses adequately identify and



quantify the hazardous constituents contained in the unit and



why further analysis is not necessary.   The applicant may base



this discussion on the existing waste analysis, knowledge of



the process generating the waste,  and the disposal practices



at the unit.  For example, an engineering analysis of the



waste stream process, information provided by the generator,



and a site audit of the generator, may allow the applicant



to characterize the waste by analyzing for a limited number



of hazardous constituents.  If the applicant can further

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                        2-5
   demonstrate that multiple units  accept  nearly  identical
   wastes,  he may choose one unit to be  representative  of
   all like units.
0  A current estimate of the annual volume or  amount  of
   wastes received  at each unit.   This  information should
   be available in  response to RCRA manifest and  record
   keeping  requirements  (Part  264,  Subpart E).   In addition,
   provide  a description of any pretreatment process  used
   for these units.  If  this information has already  been
   included in the  Part  8, indicate its  location.

0  Identify which Federal, State and local environmental and
   health agencies  conduct inspections  and maintain reports
   on the operation of the landfill or  surface impoundment.
   The applicant must Indicate where complete  copies  of these
   reports  are available (e.g., applicant's files, specific
   office of the relevant agency).   Summarize  past compliance
   with any permits, regulations, or standards relating to
   the unit, including dates and brief  descriptions of  any
   violations.  The applicant  must fully describe any
   major violations of those programs and  resulting releases
   to-any pathway as outlined  in Section 2.5-   Examples
   of the types of  records to  be identified or summarized
   are:
     - reports on occupational health and  safety resulting
       from inspections  by OSHA (Occupational  Safety and
       Health Administration)  or similar State or local
       agencies;
     - compliance records with NPDES (National Pollution
       Discharge Elimination System) and other surface
       water point  source discharge permits;

-------
                             2 - 6
          - compliance records for applicable Federal or State
            air quality standards and any permits controlling
            air emissions;
          - evaluation records from the Open Dump Inventory
            (if the unit failed the subsurface gas criteria,
            describe monitoring results and any remedial actions);
          - records of notification to the National Response  Center
            or other government authorities concerning any release
            of hazardous substances that exceeded or equaled  the
            Reportable Quantities established under CERCLA:
          - accident reports submitted to the Federal Department
            of Transportation (or similar State agency) describing
            any release of hazardous waste or constituent; and
          - Fire Marshal reports required by local fire departments

2.2  PATHWAY-SPECIFIC INFORMATION
     Human exposure to hazardous waste or waste constituent
releases from the facility may occur or be detected through a
number of potential exposure pathways.  Owners and operators  must
characterize these pathways in order to determine the potential
for exposure to hazardous waste'releases (See Section 3). The
statute mentions the following potential exposure pathways:
ground water, surface water, air, and food-chain contamination.
Subsurface gas has also been added in the Manual as a unique
type of air pathway, and the indirect path of food-chain contamin-
ation has been incorporated into the pathways which directly
receive the release.  Soil contamination was included in the  Manual
as a pathway due to the possible contamination via soil of
other pathways (i.e., through crops, run-off to surface water,
and release of particulates to air), as well as the potential
for direct exposure.
     The additional pathway information that must be submitted in

the EIR is described below, in sections for each of the pathways.

-------
                             2-7






2.2.1   Ground  Water



     0   Provide  an existing map showing  the  location of all known



        ground water  withdrawal wells within three miles of the



        unit.  Such maps  may  be available  from  local health



        agencies responsible  for  regulating  ground water use.



        The  number and  location of  licensed  drinking water



        wells  within  the  same area  must  be provided or estimated,



        based  on the  available data.





     0   Provide  a narrative discussion describing general



        ground-water  usage patterns within the  three mile radius,



        including any known uses  of groundwater for commercial



        food preparation, or  agricultural  irrigation.  The



        discussion must identify, if  known,  which aquifers



        are  used, as  well as  any  nearby  high use pumping  operations



        that may alter ground-water flow patterns.





     0   If ground-water studies of  the  area  have been  done,



        provide  any  map(s)  showing  the  location of  regional



        ground-water recharge and discharge  areas.  These maps



        are  usually  available from  USGS  publications.





     8   Provide  net  precipitation (precipitation minus evaporation),



        using  net seasonal  rainfall data,  if available.   If  not



        available,  calculate  net  precipation by substracting  the



        mean annual  evaporation  for the  region from the normal



        annual precipitation.  Such data are available from  standard



        reference documents,  e.g.,  The  Climatic Atlas  of the  United



        States^  U.S.  Department  of  Commerce.

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                             2-8



2.2.2  Surface Water



     0  Provide an existing map showing the location of all surface



        water bodies within a three mile radius of the unit (e.g.,



        USGS or similar topographical map).  Identify on the map



        downstream drinking water intake sources, estimate the



        populations served, and note the locations of other



        intakes for known major industrial or commercial uses.



        Provide a narrative discussion of general surface-water



        use within the three mile radius, including any other



        known major uses, such as commercial fishing, recre-



        ational, and agricultural uses.  Such information should



        be available from water resource and planning agencies.





     0  Provide velocities of streams and rivers (including mean,



        high, and low flow) passing through the property and



        within 1000 feet of the property.  Possible sources



        include the U.S. Army Corps of Engineers, USGS, and



        State water resource agencies.





     0  Describe any monitoring system used to monitor surface-



        water quality, and provide a summary of resulting



        surface-water quality data.





2.2.3  Air



     0  Describe any air monitoring system around the unit,



        and provide a summary of resulting air quality data.





     0  Estimate the population within a four mile radius of



        the unit.   Information on this subject should be avail-



        able from local planning agencies.

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                             2-9
2.2.4  Subsurface Gas





     0  Identify the past disposal of any municipal-type wastes



        in the unit; specify the types of waste and provide



        approximate quantities and dates of disposal, if known.



        (Such wastes include: incinerator, composting, or resource



        recovery residues; septic tank wastes; municipal waste



        water treatment sludges; and normal domestic waste and



        garbage.)





     0  Indicate on a map any known locations of underground



        conduits inside the property boundary and within.



        1000 feet of the boundary.  Possible sources of infor-



        mation include local utility companies.





     0  Describe any monitoring, recovery or control systems



        for subsurface gas release and provide a summary of



        resulting  data.



2.2.5  Soil



     0  If soil sampling for contamination has been done around



        the unit,  the applicant must identify the location of



        the sampling sites and any soil contamination on a map.



        Analytical results must be summarized, including chemicals



        analyzed for, chemicals found, and levels measured.






2.3  TRANSPORTATION INFORMATION





     Accidents or  leaks during the transportation of wastes at



the facility site  may result in human exposure.  The applicant

-------
                             2-10





must submit information concerning transport on-site and in the



immediate vicinity (e.g.,  on access roads),  as defined below.



Part B requirements also require submission  of traffic documenta-



tion; if the applicant has previously submitted all or portions



of the information requirements given below, reference to their



location in the Part B application will be accepted.





     0  Provide general descriptions (including capacity) of



        the types of vehicles and containers used to transport



        hazardous waste to and within the facility.





     0  Identify normal transport routes for haaardous waste



        into the site and  within a distance  of one mile of the



        facility entries.






     0  Describe procedures for clean-up of  spills or leaks



        resulting from the transport of waste on-site (or in



        the immediate vicinity of the facility) and unloading/



        loading activities on-site.





2.4  MANAGEMENT PRACTICES  INFORMATION



     A potential cause of  releases and human exposure to hazardous



wastes is improper management practices at landfills and surface



impoundments.   Information on worker injuries, accidents, and



illnesses related to the hazardous waste units may be used to  help



identify those facilities  with questionable  management practices



and, hence, with potential for releases.  Such information may



also serve as  an indicator that a release has already occurred to



one of the direct exposure pathways.  Therefore, the following

-------
                             2-11





information must be submitted.



     0  Summarize existing worker illness,  accident,  or injury



        reports and logs related to  the operation of  the surface



        impoundment or landfill.  This  includes  a summary of



        Worker's Compensation claims filed  or  hcspitalization



        records documenting worker illness,  accidents,  or injuries



        related to operation of  the  unit.





2.5  KNOWN RELEASE INFORMATION



     Unless information on known releases  (including  those



releases violating existing permits  or  standards a==  noted in



Section 2.1) has been submitted  previously  in  the Part  B



application, or in response to requests under  the Continuing



Release provision (Section 3004(u)), the applicant must provide



a description of the nature and  magnitude of any known  release,



including the following:



     0  existing evidence identifying the release, including  a



        summary of any relevant  monitoring  data;



     0  the pathway and extent of any migration  of the



        released waste or constituent (if characterized);



     0  any corrective action taken, and the effectiveness



        of such measures (if known); and



     0  the extent and severity  of impact of any known



        public exposures resulting from releases of  waste



        or consituents.  Identify and summarize  any  studies



        (prepared by the applicant,  other government agencies,



        the public, or others)  that  characterize the impact of



        the exposures.

-------
                             2-12
     While the appropriate sections of the Part B application



should adequately describe most ground-water releases, the



applicant must provide any additional information available.   This



additional information includes any analytical data for wells



not otherwise reported to EPA indicating a release, and information



concerning any affected public or private water supplies and



estimates of the populations served.  Also, any known food-chain



contamination due to agricultural or food preparation uses of



contaminated water must be described.



     Surface water releases that must be described include those



resulting from overtopping of impoundments, uncontrolled run-off



from active landfills, and sediment transport or wash-out due to



erosion, run-off, or flooding.  Evidence may include visual



sightings and fish kills, as well as monitoring data.  Information



on known instances of human exposure must also include any



known food-chain contamination (e.g., fish bioaccumulation) .



     Evidence of vapor or particulate releases to air primarily



consists of air monitoring data, although visible emissions,



odor complaints by the public, and documented air impacts on



workers may also serve as indicators.  The most obvious indications



of subsurface gas release, in addition to monitoring data, are



fire or explosion related to methane migration.  Releases to  soil



are defined through any soil sampling that has been done (see



Section 2.2.4), although stressed' vegatation and/or soil



discoloration may also serve as indicators of possible



release to the soil.  Any known food chain contamination due



to agricultural use of the contaminated soil must be described.

-------
                         2-13





     Transportation-related releases are associated with



accidents occuring on-site or within one mile of facility



entries.  While transport is normally associated with truck



or rail hauling, other transportation methods, such as



pipelines and barges, nust also be included in reporting



of accidents and releases.

-------
               3.0  EXPOSURE POTENTIAL OF THE UNIT






3.1  Introduction



     Owners or operators of hazardous waste landfill and surface



impoundment units subject to Section 3019 must provide the exposure-




related information outlined in Appendix A and Section 2.0 of this



Manual.  In addition/  they must prepare a narrative discussion



based on that information on the potential for the public to be



exposed to hazardous wastes or hazardous constituents through



releases related to the unit.  This section describes the approach




owners or operators should use to describe the potential for human



exposure via each of the pathways identified in Section 2.0 for



each unit of concern.



     For each unit, for each pathway, the owner or operator should



draw conclusions regarding the potential for and possible magnitude



of human exposure from both normal operations and accidents at or



near the unit(s) of concern.  The owner or operator should discuss



both the potential for direct human exposure and the potential for



human exposure from the contamination of food chain crops.  In



particular, the applicant should describe site-specific location,



design and operating factors that mitigate the potential for releases



(e.g., lilers, leachate collection systems, etc.) as well as factors



that increase the potential for exposure (e.g., high ground water



flow rates, downgradient drinking water wells, etc.).



     The Agency expects that a properly prepared discussion of




exposure potential as outlined in this Section can generally be



accomplished in 2 to 3 pages for each of the pathways at each of



the relevant units.  These discussions should present conclusions

-------
                              3-2





and the major factors which lead to the conclusions, but detailed



analyses are not required.  Owners or operators should base their



discussion and conclusions on relevant Part B information (see



Appendix A) and the information requested in Section 2.0; Part B



information need not be resubmitted or repeated in detail.  Owners



or operators can use additional information they may have to



prepare these descriptions; they should document or reference



the sources of these data.





3.2  Potential for Human Exposure Via the J3round Water_Pathway



      The owner or operator should describe how the unit's loca-



tion affects the potential for and possible magnitude of human



exposure from releases to ground water.  For example, the potential



magnitude of human exposure is increased if the unit is located



in an area characterized by high rates of ground-water flow, a



shallow aquifer, high net precipitation, and porous soils, or if



the unit is located upgradient from a public drinking water well



system.



     The owner or operator should then describe the design and



operating features that affect the potential for releases and the



magnitude of these releases.  For example, double synthetic liner



containment systems coupled with leachate collection systems



and run-on/run-off control systems minimize the potential for



releases from a unit.  Correctly placed and screened monitoring



wells can pick up releases that do occur and enable the owner or



operator to take corrective action before human exposure  occurs.



Leak detection procedures  for surface impoundments, such  as

-------
                            3-3





routine analysis of leachate, will also allow the early detection



of releases.





3.3   Potential for Human Exposure Via the Surface Water Pathway



      The owner or operator should describe how the unit's loca-



tion affects the potential for human exposure from releases to



surface water.  For example, the potential magnitude of human



exposure is increased if a unit is located adjacent to surface



water or upstream from drinking water intakes.  Units located



next to stream segments characterized by high flow rates and



dilution capacity may have a lower exposure potential than units



located along stream segments that are stagnant.



     Certain design and operating features affect the potential for



and -the magnitude of surface water releases.  For example, units



with secondary containment systems, runoff control systems, dikes,



etc., are less likely to have releases than units without such con-



tainment and runoff control systems.   Automatic cut-off systems



and overflow alarms also decrease the potential for releases from



surface impoundments.   The owner or operator should describe how



the design and operating characteristics of operating surface



impoundments and landfills affect the potential for releases



that threaten human health.  The owner or operator should also



describe the effectiveness of the facility design and emergency



procedures to minimize the effects of floods or severe storm events.





3.4   Potential for Human Exposure Via the Air Pathway



      The owner or operator should describe how the unit's location



affects the potential  for human exposure from air releases.  For

-------
                              3-4





example, the potential magnitude of human exposure from air releases



is much higher if the unit is located in a densely populated area



rather than a relatively unpopulated rural area.  Units located



in areas characterized by frequent inversions or limited dispersion



also have a greater potential for exposure than units where releases



are quickly dispersed.  Temperature, wind speed, precipitation and



topography all affect the ambient atmosphere's ability to disperse



air releases.



     The design and operation of the unit will affect the potential



for and the magnitude of releases.  The applicant should describe



how the facility's design and operation affect the potential for



release of air emissions which could threaten human health and the



environment.  For example, the applicant should briefly describe



any venting systems for subsurface gas, the design of any caps on



the unit, any dust suppression or particulate controls, and any



disposal by bulk evaporation.



     The owner or operator should also describe any waste character-



istics indicative of potential for releases to air, such as the



incompatibility, reactivity,  or ignitability of the waste, as well



as the volatility of waste constituents.  The applicant should



briefly outline special handling, treatment, or mixing procedures



used to ensure that violent reactions, fires, explosions, and



extensive evaporation of volatile constituents do not occur.



3 .5   Potential for Human Exposure From Subsurface Gas Releases



      The owner or operator should describe how the unit's loca-



tion affects the potential for human exposure from subsurface



gas releases.  For example, the potential magnitude of human

-------
                              3-5





exposure is affected by the existence of barriers  to or conduits



for subsurface gas migration in the vicinity of  the unit.  Units



located far from buildings or other structures that could  trap



the methane are much less likely to have releases  with significant



exposure potential.



     The applicant should describe how the facility design and



operation affects the potential for releases of  subsurface gas.  For



example, units that do not contain municipal waste are less likely



to have such releases than are co-disposal units.  Also, operating



surface impoundments have limited potential for  exposures  from



subsurface gas releases because of their large exposed surface area.



Any gas control measures should be described, including trenches,



cut-off walls, vents, and recovery systems.





3.6   Potential for Human Exposure From Releases to Soil



      The owner or operator should describe how  the unit's loca-



tion, design,  and operating characteristics affect the potential



for and possible magnitude of human exposure from  releases to soil.



The potential  for human exposure due to off-site transport of



contaminated soil should be described.   For example, contaminated



soil may reach surface water through run-off, and wind dispersion



may result in  off-site transport through the air pathway.  Direct



human exposure to contaminated soil on-site is also possible, and



the applicant  should describe operating features affecting such



exposures,  e.g., on-site spill clean-up procedures, as well as



security procedures used to limit public access  to the unit and

-------
                              3-6                             '





any nearby contaminated area.  If food crops are grown in, or



adjacent to, contaminated soil,  the applicant should discuss the



potential for food-chain contamination.





3.7  Potential for Human Exposure FromJTransportation-Related Releases



     The owner or operator should describe how methods and routes



of transportation of waste on-site and in the immediate vicinity



of the facility affect the potential for human exposure from



releases related to transportation accidents or leaks from vehicles



used to transport the waste.  For example, the potential magnitude



of releases is increased when transportation routes move significant



quantities of waste through a highly populated area to an off-site



disposal facility, as opposed to transportation routes through



thinly populated rural areas or routes where the waste remains



on-site from generation to disposal.  Similarly, accident and



spill prevention programs and procedures are likely to mitigate



the potential for human exposure from transportation-related



releases.  These are the types of factors that should be described



in this section of the EIR.





3.8  Potential for Human Exposure From Worker-Management _Practices



     The information submitted by the applicant concerning management



practices consists of data on worker injuries, accidents, and illnesses



related to the operation of the landfill or surface impoundment.



The discussion in this section should focus on the nature and



frequency of such cases, and any patterns of occurrence  indicating



that releases from the unit may have occurred in the past  (or



may be occurring).  The applicant should  analyze the worker data

-------
                           3-7



and discuss the potential for off-site migration and public



exposure resulting from any releases related to worker-management



practices.



     The owner or operator should briefly describe training



programs in place for the workers that ensure the safe handling



of wastes and minimize the potential for releases from normal



operations of the unit.  The facility should ha/e developed



contingency and other emergency plans that are designed to minimize



the potential for human exposure from accidental releases at the



facility, and these should be briefly described as well.  Any



steps instituted to correct any past problems evidenced by the



worker data should also be outlined.

-------
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-------
                           APPENDIX B

                Contacts at EPA Regional Offices
Region

Region I
Region II
Region III
Region IV
Region V
Region VI
Contact

Gerrard Sotolongo
Waste Management Division
State Waste Programs Branch
CN/RI Waste Programs Section
U.S. EPA - Region I
John F. Kennedy Building
Room 1900
Boston, MA  02203
(617) 223-1724  '

Diane Buxbaum
Technical Support Section
Roan 1000
2AW-SW
U.S. EPA - Region II
26 Federal Plaza
New York, NY  10278
<212) 264-2724

Sam Rotenberg
RCRA Support Section
U.S. EPA - Region III
841 Chestnut Street
Philadelphia, PA  19107
(215) 597-2842

Doug McCurry, Chief
Waste Engineering Section
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, GA  30308
(404) 881-3067

Edith Ardiente/ Chief
Technical Programs Section
(5 AHMF)
U.S. EPA - Region V
230 S. Dearborn Street
Chicago, IL  60604
(312) 8b6-6l35

Mark deLorimer
Technical Section (6 AW-HT)
U.S. EPA - Region VI
1201 Elm Street
First International  Building
Dallas, TX  75270
(214) 767-2663
-------
APPENDIX B


Region VII
Region VIII
Region IX
Region X
Luetta Flournoy
Permits Section
RCRA Branch
U.S. EPA - Region VII
726 Minnesota Avenue
Kansas City, KS  66101
(816) 374-6531

Mike Gansecki
Hazardous Waste Management Branch
RCRA Permits Section
8HWM-WM
U.S. EPA Region VIII
999 18th Street
Suite 1300
Denver, CO  80202-2413
(303) 293-1662

Barbara Gross
RCRA Branch
Alternative Technology Section
(T-2-3)
U.S. EPA - Region IX
215 Fremont Street
San Francisco, CA  94^.05
(415) 974-7101

Keven Wong
RCRA Branch
Alternative Technology Section
(T-2-3)
U.S. EPA - Region IX
215 Fremont Street
San Francisco, CA  94105
(415) 974-7481

Jeff Webb
Hazardous Waste Division
MS-533
U.S. EPA - Region X
1200 Sixth Avenue
Seattle, WA  98101
(206) 442-1099
                              B-2
-------
                                   Appendix C
                        STATE SOLID AND HAZARDOUS WASTE A3ENCIES
                            Environmental Protection Agency
                               Office of Solid Waste
                                   June 10, 1985
                                  SW - 393
ALABAMA

Daniel E. Cooper, Director
Land Division
Alabama Dept. of Envirormentai
  Management
1751 Federal Drive
Montgomery, Alabama  36130

CML (205) 271-7730

ALASKA

Stan Hungerford
Air & Solid Waste Management
Dept of Environmental Conservation
Pouch 0
Juneau, Alaska  99811

CML (907) 465-2635

AMERICAN SAMOA

Pati. Faiai, Executive Secretary
Environmental Quality Commission
American Samoa Government
Pago Pago, American Samoa  96799

Overseas Operator
(Commercial Call 633-4116)

Randy Morris, Deputy Director
Department of Public Works
Pago Pago, American Samoa  96799

ARIZONA

Sally Mapes, Acting Manager
Compliance Section
Department of Health Services
2005 North Central
Third Floor
Phoenix, Arizona  85004

CML (602) 257-2209
ARKANSAS

Vincent Blubaugh, Chief
Solid & Hazardous Waste Div.
Department of Pollution Control
  and Ecology
P.O. Box 9583
8001 National Drive
Little Rock, Arkansas  72209

CML (501) 562-7444, ex. 504

CALIFORNIA

Joel Moskowitz, Deputy Director
Toxic Substance Control Program
Department of Health Services
714 P Street, Roan 1253
Sacramento, California  95814

CML (916) 322-7202

Micheal Campos, Executive Director
State Water Resources Control Board
P.O. Box 100
Sacramento, California 95801

CML (916) 445-1553

COLORADO

Kenneth Waesche, Director
Waste Management Division
Colorado Department of Health
4210 E. llth Ave.
Denver, Colorado 80220

CML (303) 320-8333

Orville Stoddard, Deputy Director
Waste Management Division
Colorado Department of Health
4210 East llth Ave.
Denver, Colorado  80220

CML (303) 320-8333
-------
COMMONWEALTH OF NORTH MARIANA ISLANDS
DISTRICT OF COLUMBIA
George Chan, Administrator
Division of Environmental Quality
Department of Public Health and
 Environmental Services
Commonwealth of the North
  Mariana Islands
Saipan, Mariana Islands  96950

Overseas Operator:  6984
Cable address:  GOV. NMI Saipan

CONNECTICUT

Stephen Hitchock, Director
Hazardous Material Management Unit
Department of Environmental Protection
State Office Building
165 Capitol Ave.
Hartford, Connecticut  06106

CML (203) 566-4924

Micheal Cawley,
Connecticut Resource Recovery
  Authority
179 Allyn St., Suite 603
Professional Building
Hartford, Connecticut  06103

CML (203) 549-6390

DELAWARE

William Razor, Supervisor
Solid Waste Management Branch
Department of Natural Resources
  and Environmental Control
89 Kings Highway
P.O. Box 1401
Dover, Delaware  19901

CML (302) 736-4781
Angelo Tcmpros, Chief
Department of Consumer &
  Regulatory Affairs
Pesticides & Hazardous Waste
  Management  Rocm 112
5010 Overlook Avenue, S.w.
Washington, D.C.  20032

CML (202) 767-8422

FLORIDA

Robert W. McVety, Administrator
Solid & Hazardous waste Section
Department of Environmental
  Regulation
Twin Towers Office Building
2600 Blair Stone Rd.
Tallahassee, Florida  32301

CML (904) 488-0300

GEORGIA

John Taylor, Chief
Land Protection Branch
Environmental Protection Division
Department of Natural Resources
270 Washington St. S.W., Room 723
Atlanta, Georgia  30334

CML (404) 656-2833

GUAM

James Branch, Administrator
EPA, Government of Guam
P.O. Box 2999
Agana, Guam  96910

Overseas Operator
(Commercial Call 646-8863)
-------
 HAWAII
IOWA
Melvin Koizumi, Deputy Director
Environmental Health Division
Department of Health
P.O. Box 3373
Honolulu, Hawaii  96801

California FTS Operator
8-556-0220
OIL  (808) 548-4139

IDAHO

Steve Provant, Supervisor
Hazardous Materials Bureau
Department of Health and Welfare
State House
Boise, Idaho  83720

CML  (208) 334-2293

ILLINOIS
Robert Kuykendall, Manager
Division of Land Pollution Control
Environmental Protection Agency
2200 Churchill Rd.  Roan A-104
Springfield, Illinois  62706

CML (217) 782-6760

William Child, Deputy Manager
Division of Land Pollution Control
Environmental Protection Agency
22UO Churchhill Rd.  Room A-104
Springfield, Illinois  62706

CML (217) 782-6760

INDIANA

David Lairm, Director,
Land Pollution Control Division
State Board of Health
1330 West Michigan Street
Indianapolis, Indiana 46206

CML (317) 243-5010
Ronald Kolpa
Hazardous waste Program Coordinator
Dept. of Water, Air & Waste Mgmt.
Henry A. Wallace Building
900 East Grand
Des Moines, Iowa  50319

CML (515) 281-8925

KANSAS

Dennis Murphey, Manager
Bureau of Waste Management
Dept. of Health and Environment
Forbes Field, Building 321
Tbpeka, Kansas  66620

CML (913) 862-9360

KENTUCKY

J. Alex Barber, Director
Division of Waste Management
Dept. of Environmental Protection
Cabinet for Natural Resources and
  Environmental Protection
18 Beilly Rd.
Frankfort, Kentucy  40601

CML (502) 564-6716

LOUISIANA

Gerald J. Healy, Administrator
Solid Waste Management Division
Dept. of Environmental Quality
P.O. Box 44307
Baton Rouge, Louisiana  70804

CML (504) 342-1216

Glenn Miller, Administrator
Hazardous Waste Management Division
Dept. of Environmental Quality
P.O. Box 44307
Baton Rouge, Louisiana  70804

CML (504) 342-1227
-------
MAINE
MICHIGAN
David Boulter, Director
Licensing and Enforcement Division
Bureau of Oil & Hazardous Materials
Dept. of Environmental Protection
State House — Station 17
Augusta, Maine  04333

CML  (207) 289-2651

MARYLAND

Bernard Bigham
Waste Management Administration
Dept. of Health & Mental Hygiene
201 W. Preston Street, Room 212
Baltimore, Maryland  21201

CML  (301) 225-5649

Alvin Bowles, Chief
Hazardous Waste Division
Waste Management Administration
Dept. of Health & Mental Hygiene
201 W. Preston Street
Baltimore, M.D.  21201

(301) 383-5734

Ronald Nelson, Director
Waste Management Administration
Office of Environmental Programs
Dept. of Health & Mental Hygiene
201 West Preston Street/Rm. 212
Baltimore, Maryland  21201

CML  (301) 225-5647

MASSACHUSETTS

William Cass, Director
Division of Solid & Hazardous Waste
Dept. of Environmental Quality
  Engineering
One Winter Street
Boston, Massachusetts  02108
Delbert Elector, Chief
Hazardous Waste Division
Environmental Protection Bureau
Dept. of Natural Resources
Box 30028
Lansing, Michigan  48909

CML (517) 373-2730

Allan Howard, Chief
Office of Hazardous Waste Management
Environmental Services Division
Department of Natural Resources
Box 30028
Lansing, Michigan  48909

CML (517) 373-2730

(Hazardous Waste, Liquid)
David Dennis, Chief
Oil & Hazardous Materials
  Control Section
Water Quality Division
Dept. of Natural Resources
Box 30028
Lansing, Michigan  48909

CML (517) 373-2794

John L. Hesse
Center for Environmental
  Health Sciences
Michigan Dept. of Public Health
Box 30035
Lansing, Michigan  48909

CML (517) 373-8050

MINNESOTA

Dale L. Wikre, Director
Solid and Hazardous Waste Division
Pollution Control Agency
1935 West County Rd. B-2
Roseville, Minnesota 55113
CML (617) 292-5589
CML (612) 296-7282
-------
MISSISSIPPI

Jack M. McMillan, Director
Division of Solid & Hazardous
  Waste Mgmt.
Bureau of Pollution Control
Department of Natural Resources
P.O. Box 10385
Jackson, Mississppi  39209

CML (601) 961-5062

MISSOURI

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

CML (314) 751-3241

MONTANA

Duane L. Robertson, Chief
Solid Waste Management Bureau
Dept.  of Health and Environmental
 Sciences
Cogswell Bldg.
Helena, Montana  59602

CML (406) 444-2821

NEBRASKA

Mike Steffensmeier, Acting Chief
Hazardous Waste Management Section
Dept.  of Environmental Control
State House Station
P.O. Box 94877
Lincoln, Nebraska 68509

CML (402) 471-2186
NEVADA

Verne Rosse
Waste Management Program Director
Division of Environmental Protection
Dept. of Conservation and
 Natural Resources
Capitol Complex
201 South Fall Street
Carson City, Nevada  89710

CML (702) 885-4670

NEW HAMPSHIRE

Dr. Brian Strohm, Assistant Director
Division of Public Health Services
Office of Waste Management
Department of Health and Welfare
Health and Welfare Building
Hazen Drive
Concord, New Hampshire  03301

CML (603) 271-4608

NEW JERSEY

Dr. Marwan Sadat, Director
Division of Waste Management
Department of Environmental Protection
32 E. Hanover Street, CN-027
Trenton, New Jersey  08625

CML (609) 292-1250

NEW MEXICO

Tony Drypolcher, Chief
Gound Water & Hazardous Waste Bureau
Environmental Improvement Division
N.M. Health & Environment Department
P.O. Box 968
Santa Fe, New Mexico  87504-0968

CML (505) 984-0020  Ext. 272

Peter Pache, Program Manager
Hazardous Waste Section
Ground Water & Hazardous Waste Bureau
Environmental Improvement Division
N.M. Health and Environment Department
P.O. Box 968
Santa Fe, New Mexico  87504-0968
                                            CML (505) 984-0020 Ext. 340
-------
NEW YORK
OKLAHOMA
Norman H. Nosenchuck, Director
Division of Solid & Hazardous Waste
Department of Environmental
  Conservation
50 Wolf Rd., Roan 209
Albany, New York  12233

CML (518) 457-6603

NORTH CAROLINA

William L. Meyer, Head
Solid & Hazardous Waste Management
 Branch
Division of Health Services
Department of Human Resources
P.O. Box 2091
Raleigh, North Carolina  27602

CML (919) 733-2178

NORTH DAKOTA

Martin Schock, Director
Division of. Hazardous Waste
  Management and Special Studies
Department of Health
1200 Missouri Ave., 3rd floor
Bismarck, North Dakota  58501

CML (701) 224-2366

OHIO

Steven White, Chief
Division of Solid & Hazardous
  waste Management
Ohio EPA
361 East Broad Street
Columbus, Ohio  43215
H.A. Caves, Chief
Waste Management Service
Oklahoma State Dept. of Health
P.O. Box 53551
1000 N.E. 10th St., Rocm 803
Oklahoma City, Ok.  73152

CML (405) 271-5338

OREGON

Mike Downs, Administrator
Hazardous & Solid Waste Division
Dept. of Environmental Quality
P.O. Box 1760
Portland, Oregon  97207

CML (503) 229-5356

PENNSYLVANIA

Donald A. Lazarchik, Director       .,
Bureau of Solid Waste Management
Department of Environmental Resources
Fulton Building - 8th floor
P.O. Box 2063
Harrisburg, PA  17120

CML (717) 787-9870

PUERTO RICO

Santos Rohena, Director
Solid, Toxics, & Hazardous
  Waste Program
Environmental Quality Board
P.O. Box 11488
Santurce, Puerto Rico  00910-1488

CML (809) 725-0439
CML  (614) 466-7220
-------
RHODE ISLAND
TEXAS
John S. Ouinn, Jr., Chief
Solid Waste Management Progran
Dept. of Environmental Management
204 Cannon Building
75 Davis Street
Providence, Rhode Island   02908

CML (401) 277-2797

SOUTH CAROLINA

Robert E. Malpass, Chief-
Bureau of Solid and Haz. Waste Mgtm.
S.C. Dept of Health & Environmental
 Control
2600 Bull Street
Columbia, South Carolina  29201

CML (803) 758-5681

SOUTH DAKOTA

Joel C. Smith, Administrator
Office of Air Quality & Solid Waste
Dept.  of Water & Natural Resources
Joe Foss Building
Pierre, South Dakota  57501

CML (605) 773-3329

TENNESSEE

Tom Tiesler, Director
Division of Solid Waste Management
Bureau of Environmental Services
Tennessee Department of Public Health
150 9th Ave, North
Nashville, Tennessee  37203

CML (615) 741-3424
Jack Carmichael, Chief
Bureau of Solid Waste Management
Texas Department of Health
1100 West 49th Street, T-602
Austin, Texas  78756

CML (512) 458-7271

Jay Snow, Chief
Solid Waste Section
Texas Department of Water Resources
1700 North Congress, Room 237-1
P.O. Box 13087, Capitol Station
Austin, Texas  78711

CML (512) 475-2041

OTAH

Dale Parker, Director
Bureau of Solid and Hazardous
  Waste Management
Department of Health
P.O. Box 2500
150 West North Temple
Salt Lake City, Utah  84110

CML (801) 533-4145

VERMONT

Richard A. Valentinetti, Director
Air and Solid Waste Programs
Agency of Environmental Conservation
State Office Building
P.O. Box 489
Montpelier, Vermont  05602

CML (802) 828-3395

VIRGIN ISLANDS

Robert V. Eepoel, Director
Hazardous Waste Program
Division of Natural Resources
Department of Conservation and
  Cultural Affairs
P.O. Box 4340, Charlotte Amalie
St. Thomas, Virgin  Islands  00801

D.C. Overseas Operator 472-6620
CML (809) 774-6420
-------
VIRGINIA

William F. Gilley, Director
Division of Solid and Hazardous
  Waste Management
Virginia Department of Health
Monroe Building llth floor
101 North 14th Street
Richmond, Virginia  23219

CML (804) 225-2667

WASHINGTON

Earl Tower, Supervisor
Solid Waste Mgmt. Division
Department of Ecology
Olynpia, Washington  98504

CML (206) 459-6316

Linda L. Brothers, Assistant Director
Office of Hazardous Substance &  -
  Air Quality Programs
Department of Ecology
Olympia, Washington  98504

CML (206) 459-6253

WEST VIRGINIA

Timothy Laraway, Chief
Division of Water Resources
Dept. of Natural Resources
1201 Greenbrier Street
Charleston, West Virginia  25311

CML (304) 348-5935

WISCONSIN

Paul Didier, Director
Bureau of Solid Waste Management
Dept. of Natural Resources
P.O. Box 7921
Madison, Wisconsin  53707

CML (608) 266-1327
WYOMING

Charles Porter, Supervisor
Solid Waste Management Program
State of Wyoming
Dept of Environmental Quality
Equality State Bank Building
401 West 19th St.
Cheyenne, Wyoming  82002

CML (307) 777-7752
-------
                       NOTE TO APPENDIX D
The chemicals listed in Appendix D on the folowing pages are
the priority toxic pollutants (as identified by EPA for use
in wastewater discharge analysis) that are designated as
hazardous constituents under RCRA (40 CFR Part 261).  In
addition to determination of the substances given in Appendix D,
tentative identifications should be attempted for the ten
organic compounds not listed in this Appendix that are detected
at the highest apparent concentrations by gas chromatographic
methods.  Applicants should determine if the ten identified
compounds are listed in Appendix VIII of 40 CFR Part 26l.
Identifications may be based on a search of mass spectral
libraries if GC/MS methods are used, and concentrations may be
approximated by comparison of the compounds' response to a
closely eluted standard.
-------
   APPENDIX D.
     ' LIST OF CHEMICALS TO BE DETERMINED IN LANDFILL
      LEACHATE, SURFACE IMPOUNDMENT CONTENTS, OR
      ACCEPTED WASTES
Metals
 and
Cyanide
  Dioxin
Compound Name


Antimony, Total

Arsenic, Total

Beryllium, Total

Cadmium", Total

Chromium, Total

Copper, Total

Lead, Total

Mercury, Total

Nickel, Total

Selenium, Total

Silver, Total

Thallium, Total

Zinc, Total

Cyanide, Total

2,3,7 ,8-Tetrachloro-
dibenzo-p-dioxin (TCDD)
Volatile   Aero lein
Compounds
           Acrylonitrile
           Benzene

           Bromoform

           Carbon Tetrachloride

           Chlorobenzene
 Chemical Abstract
   Service Number


7440-36-0

7440-38-2

7440-41-7

7440-43-9

7440-47-3

7440-50-8

7439-92-1

7439-97-6

7440-02-0

7782-49-2

7440-22-4

7440-28-0

7440-66-6

57-12-5


1764-01-6


107-02-8

107-13-1

71-43-2

75-25-2

56-23-5

108-90-7
                           D-l
-------
   APPENDIX D.  (CONTINUED)


                                         Chemical Abstract
           Compound Name                   Service Number

Volatile
Compounds  Chloroethane                  75-00-3
(cont.)
           2-Chloroethylvinyl Ether      110-75-8

           Chloroform                    67-66-3

           1,1-Dichloroethane            75-34-3

           1,2-Dichloroethane            107-06-2

           1,1-Dichloroethylene          75-35-4

           1,2-Dichloropropane           78-87-5

           1,3-Dichloropropylene         542-75-6

           Ethylbenzene                  100-41-4

           Methyl Bromide                74-83-9

           Methyl Chloride             .  74-87-3

           Methylene Chloride            75-09-2

           1,1,2,2-Tetrachloroethane     79-34-5

           TetrachLoroethylene           127-18-4

           Toluene                       108-88-3

           1,2-Trans-dichloroethylene    15 6-60-5

           1,1,1-Trichloroethane         71-55-6

           1,1,2 Trichloroethane         79-00-5

           Trichloroethylene             79-01-6

           Vinyl Chloride                75-01-4
                             D-2
-------
      APPENDIX D.  (CONTINUED)
               Compound Name


     Acid     2-Chlorophenol
   Compounds
              2,4-Dichlorophenol

              2,4-Dimethylphenol

              4,6-Dinitro-o-cresol

              2,4-Dinitrophenol

              2-Nitrophenol

              4-Nitrophenol

              p-Chloro-m-cresol

              Pentachlorophenol

              Phenol

              2,4,6-Trichlorophenol


Base/Neutral  Acenaphthene
 Compounds
              Acenaphthylene

              Anthracene

              Benzidine

              Benzo[a]anthracene

              Benzo[a]pyrene

              Benzo[b]fluoranthene ,

              Benzo[ghi]perylene

              Benzo[k]fluoranthene

              Bis(2-chloroethoxy)
              Methane

              Bis(2-chloroethyl) Ether
Chemical Abstract
   Service Number


  95-57-8

  120-83-2

  105-67-9

  534-52-1

  51-28-5

  88-75-5

  100-02-7

  59-50*7

  87-86-5

  108-95^2,  ,

  88-06-2


  83-32-9

  208-96-8

  120-12-7

  92-87-5   '• ;  '

  56-55-3

  50-32-3

  205-99-2

  191-24-2

  207-08-9


  111-91-1

  111-44-4
                                D-3
-------
        -   (CONTINUED)
     Compound Name


ral  Bis(2-chloroisopropyl)
.s    Ether

     Bis(2-ethylhexyl)  Phthalate

     4-Bromophenyl Phenyl  Ether

     Butyl Benzyl Phthalate

     2-Chloronaphthalene

     4-Chlorophenyl Phenyl Ether

     Chrysene

     Dibenzo [a ,h] anthracene

     1 ,2-Dichlorobenzene

     1 ,3-Dichloroben.zene

     1 ,4-Dichlorobenzene

     3 ,3 '-Dichlorobenzidine

     Diethyl Phthalate

     Dimethyl Phthalate

     Di-n-Butyl Phthalate

     2 ,4-Dinitrotoluene

     2 ,6-Dini trotoluene

     Di-n-Octyl Phthalate

     1 , 2-Diphenylhydrazine
     (as Azobenzene)

     Fluoranthene

     Flourene

     He xachloro benzene
Chemical Abstract
  Service Number



102-60-1

117-81-7

101-55-3

85-68-7

91-58-7

7005-72-3

218-01-9

53-70-3

95-50-1

541-73-1

106-46-71

91-94-1

84-66-2

131-11-3

84-74-2

121-14-2

606-20-2

117-84-0


122-66-7

206-44-0

86-73-7

118-74-1
                                                 U.P, Environments  p~ofpot.1on Agency
                                                  ' "' '• 5,  I, i >, r
             I'..
                       D-4
               '- - -sj-"1, 1L  60601
-------
V
   \
      \APPENDIX  D.
       A
(CONTINUED)
               Compound  Name
    Pesticides   alpha-Endosulf an
     (cont. )
                beta-Endofป;ulf an

                En4osulfa?n  Sulfate
                Endrin  Aldehyde

                Heptachlor

                Heptachlor  Epoxide

                PCS- 124 2

                PCS'- 125 4

                PCB-1221

                PCB-1232

                PC$rl248

                PCB-1260

                PCB-1016

                Tc-xaphene
                         Chemical Abstract
                           Service Number


                         115-29--7

                         115-29-7

                         1031-07-8

                         72-20-8

                         7421-93-4

                         76-44-8

                         1024-57-3

                         53469-21-9

                         11097-69-1

                         11104-28-2

                         11141-16-5

                         12672-29-6

                         11096S-82-5

                         12674-11-52

                         8001-35-2
                                  D-6
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