OOOB85001
                    PERMIT APPLICANTS'  GUIDANCE MANUAL


                  FOR  EXPOSURE INFORMATION REQUIREMENTS


                         UNDER RCRA SECTION 3019
                                  FINAL
                         Office of Solid Waste

              United  States Environmental Protection Agency

                        Washington, D.C.  20460
                                                      ,  , ,
                               July 3, 1985          .': '  ',  •' '"•^r, fi00.., J670
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                      ACKNOWLEDGEMENTS
This manual was prepared by the Land Disposal Branch and the
Permits Branch of the Office of Solid Waste.  EPA personnel
who were major contributors to this document include Arthur
Day, Terry Grogart, 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 and
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 From 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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                        1.0  INTRODUCTION






     The purpose of this 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 Hazard9us 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



provides general guidance on how applicants should structure this




discussion.  That Section provides examples of how specific



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 B



 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
           90)9.  (a) EXPOSURE INFORMATION.—BegInning on the dat«  nine months
after the enactment of the Hazardous  tnd Solid  Waste Amendments of 1984, each
application for a final  determination regarding a permit under section 3005(c) for a
landfOl  or surface  Impoundment shall  be  accompanied  by  information reasonably
asoertainable 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
minimum, such information must address:
           "(1) reasonably forseeable potential releases from  both  normal operations
     aad accidents at the unit, including releases associated with transportation to or
     from the unit;
           "(2)  the potential  pathways  of human exposure to  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.
The owner or operator of a landfill or surface impoundment for which an application for
such a final determination under section 3005{c) has been submitted prior to the date of
enactment of the Hazardous and Solid Waste Amendments of  1984 shall submit  the
information required by this subsection to the Administrator (or  the State, in the case of
a State with an authorized program) no later than the date 9 months after  such date of
enactment.
     "(b) HEALTH ASSESSMENTS.-
           *(1)  The  Administrator  (or  the State, in  the  case of a  State with an
     authorized program) shall  make the information required by subsection (a), together
     with other relevant information, available to the Agency for Toxic Substances  and
     Disease Registry established by section 104(0 of the Comprehensive Environmental
     Response, Compensation and Liability Act of 1980.
           "(2) Whenever in the Judgment of the Administrator,  or the State (in the case
     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 subjection (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 of 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 epidemiologieal 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 of  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 will 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;
     "(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 Tandfill 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 (ATSDR).   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 EPA,
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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1.2.2  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; dally edition July 25, 1984).
     As a matter or 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 B 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 B
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 indicste 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 r'elevant Part B information, must be completed




by the applicant.  This checklist 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 B, 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.

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                           2-7

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.

   8  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.

   0  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

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                             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 hazardous 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 as 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



 rosion, 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



 raw 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



 ccomplished 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 Ground 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.




 eak 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.   Fo'r 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 From Transportation-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_FromWorker-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 c'esigned 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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-------
Region

Region I
Region II
Region III
Region IV
Region V
Region VI
           APPENDIX B

Contacts at EPA Regional Offices


          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
          Room 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

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APPENDIX B
 egion 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  94105
(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

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                                   Appendix C
                        STATE SOLID AND HAZARDOUS WASTE AGENCIES
                            Environmental Protection Agency
                               Office of Solid Waste
                                   June 10, 1985
                                  SW - 393
ALABAMA
Daniel E. Cooper, Director
Land Division
Alabama Dept. of Environmental
  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

GML (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

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          .TH OF NORTH MARIANA ISLANDS
George Chan, Administrator
Division of Environmental Quality
Department of Public Health and
 Environmental Services
Cotjnonwealth of the North
  Mariana Islands
Saipan, Mariana Islands  96950

Overseas Operator:  6984
Cable address:  GOV. NMI Saipan

CONNECTICUT

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

CML (203) 566-4924

 ^cheal Cawley,
   necticut 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
DISTRICT OF COLUMN LA

Angelo Tonpros, Chief
Department of Consumer &
  Regulatory Affairs
Pesticides & Hazardous Waste
  Management  Room 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
(Conmercial Call 646-8863)

-------
     II
Melvin Koizumi, Deputy Director
Environmental Health Division
Department of Health
P.O. Box 3373
Honolulu, Hawaii  96801

California FTS Operator
8-556-0220
CML  (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
 ivision of Land Pollution Control
  vironmental 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
2200 Churchhill Rd.  Room A-104
Springfield, Illinois  62706

CML  (217) 782-6760

INDIANA

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

CML  (317) 243-5010
IOWA

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
Topeka, 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 Reilly 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

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   :NE
 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 Bighan
 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
  1 W. Preston Street
  Itimore, 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

CML (617) 292-5589
MICHIGAN

Delbert Rector, 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 (612) 296-7282

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  ssissiFPi
,^   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

       L.  Robertson,  Chief
    [.d Waste  Management Bureau
   ft.  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

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    YORK
  srman H. Nosenchuck, Director
Division of Solid & Hazardous Waste
Department of Environmental
  Conservation
50 Wolf Rd., Room 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

   tin Schock, Director
   is ion 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

CML (614) 466-7220
OKLAHOMA

H.A. Caves, Chief
Waste Management Service
Oklahoma State Dept. of Health
P.O. Box 53551
1000 N.E. 10th St., Roan 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
Envi rot-mental Quality Board
P.O. Box 11488
Santurce, Puerto Rico  00910-1488

CML (809) 725-0439

-------
   IDE  ISLAND
John S. Ouinn, Jr., Chief
Solid Waste Management Program
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

   1 C. Smith, Administrator
   ice of Air Quality & Solid Waste
  pt.  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
TEXAS

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

UTAH

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. 8ox 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

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    INIA
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
Olympia, Washington  98504

CML (206) 459-6316

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

CML (206) 459-6253

VEST VIPGINIA

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

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                       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 CPR 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 261.
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.

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   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   Acrolein
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

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   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

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      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

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PENDIX D.   (CONTINUED)
      Compound Name
tral  Bis(2-chloroisopropyl)
ds    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

       ,3-Dichlorobenzene

       ,4-Dichlorobenzene

      3,3'-Dichlorobenzidine

      Diethyl Phthalate

      Dimethyl Phthalate

      Di-n-Butyl Phthalate

      2,4-Dinitrotoluene

      2,6-Dinitrotoluene

      Di-n-Octyl Phthalate
      1,2-DiphenyIhydrazine
      (as Azobenzene)
      Fluoranthene

      Flourene

       exachlorobenzene
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
                        D-4

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    APPENDIX D.  (CONTINUED)



            Compound Name


Pesticides  alpha-Endosulfan
 (cont.)
            beta-Endosulfan

            Endosulfan Sulfate

            Endrin

            Endrin Aldehyde

            Heptachlor

            Heptachlor Epoxide

            PCB-1242

            PCB-1254

            PCB-1221

            PCB-1232

            PCB-1248

            PCB-1260

            PCB-1016

            Toxaphene
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

11096-82-5

12674-11-2

8001-35-2
                              D-6

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                  -  -, ,- >rtinn Agsn
U.S. Env-; -   '   -  -_' '
P.,£ion 5, Library  l^P^--L^»
030 S  Dearborn  Street,  Roo» 1670

Chicago,  IL   &0604

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