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
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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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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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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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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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1.2 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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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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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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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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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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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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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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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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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;
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- 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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2.1 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.
-------
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.
-------
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 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
-------
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
-------
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
-------
.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
-------
: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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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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