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TD811.5
.5686
1987
Solid and Hazardous
Waste Report for
Fiscal Year 1987
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
November 1987
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Solid and Hazardous
Waste Report for
Fiscal Year 1987
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
November 1987
U S Environmental Protection Agcr
Tiegion 5', Library t5^'1^ ,&r,n
230 S. Dearborn Street, Room 16,«
Chicago, IL 60604
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Solid and Hazardous
Waste Report for
Fiscal Year 1987
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
November 1987
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FOREWORD
This report provides a summary of the accomplishments of the Office of Solid Waste and
Emergency Response (OSWER) of the U.S. Environmental Protection Agency for fiscal
year 1987. During this period, substantial progress was made in the implementation of
both the Resource Conservation and Recovery Act (RCRA) and the Superfund programs.
The many accomplishments described in this report are the result of a team effort
involving Headquarters, Regional, and State personnel. I, therefore, want to pay special
tribute to the hard-working and dedicated employees who manage and implement these
complex programs.
I hope that this report will provide a better understanding of the many positive
achievements within the national solid and hazardous waste management programs. Any
comments on the information presented herein will be greatly appreciated.
J. Winston Porter
Assistant Administrator
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TABLE OF CONTENTS
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SECTION 4 CHEMICAL EMERGENCY PREPAREDNESS
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Page
EXECUTIVE SUMMARY ES-1
Superfund ES-1
Resource Conservation and Recovery Act ES-1
Underground Storage Tanks ES-2
Chemical Emergency Preparedness and Prevention Program ES-2
Special Initiatives ES-2
SECTION 1 SUPERFUND 1-1
Response Activities 1-1
Enforcement Program 1-6
Regulations, Guidances, and Other Activities 1-7
SECTION 2 RESOURCE CONSERVATION & RECOVERY ACT 2-1
Regulatory Activities and Reports to Congress 2-1
Permitting Program 2-3
Corrective Action 2-4
Enforcement 2-5
Guidances, Training, and Other Activities 2-6
SECTION 3 UNDERGROUND STORAGE TANKS 3-1
Technical Standards 3-1
Financial Responsibility Requirements 3-1
State and Local Programs 3-1
LUST Trust Fund Implementation 3-2
Outreach Activities 3-4
AND PREVENTION PROGRAM 4-1
Regulatory Activities 4-1
Regional and State Activities 4-2
Emergency Planning 4-2
Outreach Activities 4-3
International Assistance 4-3
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EXECUTIVE SUMMARY
The Office of Solid Waste and Emergency Response (OSWER) is responsible for
implementing the national solid and hazardous waste management program under the
Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous and
Solid Waste Amendments of 1984 (HSWA); the national program to respond to
environmental emergencies and clean up uncontrolled hazardous waste sites under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act (SARA); the national
program to manage hazards from underground storage tanks, also under RCRA; and the
Chemical Emergency Preparedness and Prevention Program under CERCLA.
This report summarizes the progress made in FY 1987 by the OSWER offices and EPA
Regions in meeting their program goals and priorities, and implementing their statutory
mandates.
SUPERFUND
During the first year after passage of the Superfund Amendments and Reauthorization Act
(SARA), OSWER focused on two key aspects of the program continuing site cleanups
and enforcement activities, and putting in place many of the procedural aspects of SARA,
including the initiation of numerous project management improvements. These objectives
were met and in some cases exceeded. The level of field activities in the removal,
remedial and enforcement programs equalled or exceeded pre-SARA levels, in most
cases. Project management improvements were initiated, and new contracts were
awarded, thus ensuring that the pace of the program will continue to accelerate, while
maintaining a high degree of quality control.
RCRA
A number of priorities drove the development, implementation and enforcement of the
national hazardous waste management program in FY 1987. These included meeting
permitting and closure deadlines, requiring corrective action, conducting compliance
monitoring and enforcement activities, developing and implementing regulations, and
providing policy and technical guidance to the Regions and States. Ground-water
protection, expansion of treatment capacity, and improving information management were
also key priorities during this past year.
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UNDERGROUND STORAGE TANKS
The Office of Underground Storage Tanks (OUST) is a new office established to respond
to the requirements of Subtitle I of RCRA. The purpose of the UST program is to halt the
installation of tanks that are most likely to leak from corrosion, help States identify the
universe of tanks to be regulated, establish standards for tank design and leak detection,
and clean up damage where leaks have occurred.
In FY 1987, the priorities of the UST program were to develop regulations that protect
human health and the environment; provide support and assistance to States to enable
them to train staff and develop effective methods to deal with the problems of underground
storage tanks; and evaluate alternative funding mechanisms and provide incentives for
States to apply for program approval.
CHEMICAL EMERGENCY PREPAREDNESS AND PREVENTION
FY 1987 was the second year of the Chemical Emergency Preparedness and Prevention
(CEPP) program. The overall program goals are to promote community awareness of
chemical hazards; assist in the development of State and local preparedness programs
and response capabilities; and develop a chemical accident prevention program. In FY
1986 and FY 1987 the program objectives were to develop the list of extremely hazardous
substances and accompanying guidance; build program infrastructure at the Federal,
State, and local levels; begin program implementation; and establish data bases to better
understand the causes of chemical accidents.
In FY 1987 CEPP implementation was enhanced by the new requirements of Title III of
SARA (October 1986), including a State and local emergency planning structure, industry
reporting requirements (community right-to-know) and broad participation in the planning
process. Throughout most of the year, the Preparedness Staff focused successfully on
meeting the many statutory deadlines imposed by Title III.
SPECIAL INITIATIVES
In order to meet evolving commitments in problem areas, a number of initiatives were
developed in FY 1987. Several of the more significant ones are outlined below.
Federal Facilities Compliance Initiative
OSWER recognized the importance of Federal facility compliance, and established a
special task force within the Office of Waste Programs Enforcement. The Task Force
serves as a focal point for both RCRA and CERCLA compliance issues, and is developing
an integrated strategy to solve the complex RCRA/CERCLA interaction at Federal facilities.
Since the task force was established in June 1987, it has made substantial progress,
including;
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With Region IX, negotiating the first RCRA corrective action order at a
Federal facility, the Department of Energy Idaho National Engineering
Laboratory (INEL) facility.
With Region V and the State of Minnesota, negotiating with the Army
the first agreement under section 120 of the new Superfund law for the
Twin Cities Army Ammunition Plant (TCAAP). The INEL and TCAAP
agreements will serve as models for future agreements at Federal
facilities, and should expedite future negotiations.
Developing an enforcement strategy for Federal facilities which
describes EPA authorities under RCRA and CERCLA.
Developing guidance for pre-remedial activities at Federal facilities and
strategies for identifying, assessing, evaluating, and listing Federal
facilities on the National Priorities List.
Identifying the universe of potential hazardous waste sites at Federal
facilities.
Improved Superfund Project Execution
The completion of current projects in the pipeline has been a continuing high priority within
the Superfund program. On August 19, we provided the Regions with guidance to assist in
the movement of Superfund projects more expeditiously through the system. The goal is
to significantly increase the pace of Superfund remedial work through the implementation
of the "project management approach". This approach involves selection of one
organization to perform the remedial investigation/feasibility study at a site, provide
technical support for public hearings and remedy selection, conduct the design
engineering phase, and serve as the construction manager.
Pro-Active Memoranda on Kev RCRA-CERCLA Decisions
In FY 1987, we began a process of providing the Regional Administrators at the beginning
of each quarter with a list of key RCRA and CERCLA decisions due in that quarter. This
pro-active approach is intended to keep the Regional Administrators apprised of some of
the significant commitments, by project name in most cases, within their respective
Regions. These memoranda focused on RCRA permits, closure plans, and significant
noncompliers; and Superfund Records of Decision, remedial design and construction
starts, settlements, Section 107 referrals, site work completions and expected deletions
from the National Priorities List.
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Environmental Priorities Initiative
The Environmental Priorities Initiative (EPI) is an integrated approach to identifying and
addressing environmental problems. This initiative will lead to an integrated RCRA/CERCLA
management system designed to enable the Agency, and ultimately the States, to identify,
evaluate, prioritize and clean up first those sites which present or may present the greatest
threat to human health and the environment. In FY 1987, an EPA Task Force was
established to develop an implementation plan to ensure that the EPI principles are
integrated into our program policies, regulations and guidance.
Municipal Solid Waste Activities
A rapidly developing issue in FY 1987 was heightened concern over municipal solid waste.
Many of the concerns were related to municipal waste combustion (MWC), as well as
increased interest in source reduction and recycling. During the year, OSWER began
development of a stronger EPA position in this area. Included were activities related to
MWC air pollution control and ash characterization/disposal, as well as review of options
for source reduction and recycling. The municipal solid waste initiative will be continued in
FY 1988.
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SECTION 1
SUPERFUND
The Superfund program made considerable progress over the past year. The passage of
the Superfund Amendments and Reauthorization Act of 1986 (SARA) provided us with
even more challenges to meet the broad directions given by Congress. While SARA
required a number of significant mid-course corrections, substantial progress was made in
terms of site activities over this past year. Our use of the Superfund response authorities
remedial, removal and enforcement resulted in significant accomplishments. In
parallel with these activities, we were also very active on the regulatory and policy fronts.
This section discusses the specific progress made in these areas.
RESPONSE ACTIVITIES
Three types of response actions are possible under the Superfund site response program.
They include remedial actions, removal actions and enforcement, progress in each of
which is summarized below.
Remedial Actions
Remedial actions are long-term actions that are generally undertaken at more complex
sites. These actions usually take a longer period of time than removal actions, require
extensive study to select the most effective clean-up option, and may cost millions of
dollars to implement. They may consist of removal and treatment (such as incineration) of
contaminated materials, pumping and treating of ground water, or other actions to
permanently clean up a site.
Project accomplishments for the remedial program in FY 1987 were significant. These
included 123 "first start" remedial investigation/feasibility studies (RI/FSs) and 60
subsequent RI/FSs; 58 initial records of decision (RODs) and 17 subsequent RODs; 75
remedial design (RD) starts; 41 remedial action (RA) starts; 8 sites where remedial work
was completed; and 5 deletions from the National Priorities List (NPL) (see Exhibit 1). The
remedies selected involve a variety of technologies including thermal destruction,
solidification, stabilization, aeration, soil washing and flushing, and biodegradation.
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Exhibit 1
123
RI/FS First Starts
60
Subsequent RI/FSs
58
Initial RODs
17
Subsequent RODs
75
RD Starts
41
RA Starts
8
Remedial Site
Work Completions
5
Deletions from
the NPL
Of the total 75 RODs signed in FY 1987 (58 initial and 17 subsequent), 44 of these RODs
addressed final source control. The other 30 RODs addressed temporary storage (8),
ground-water action (16), and no further action (6). Over half (57%) of the final source
control RODs employed source treatment; 44% of the source treatment remedies were
thermal destruction. The percentage of RODs addressing ground water where "pump and
treat" was selected to restore the aquifer was 69% (23/33). Many RODs contained both
source control and ground-water remedies and costs for the FY 1987 RODs (see Exhibit
2).
A key management initiative in 1987 was the development and implementation of a
strategy designed to expedite the pre-remedial process. It focuses more attention on
early decisions to ensure that fewer low priority sites reach the more resource-intensive
parts of the pre-remedial process.
During FY 1987, the pre-remedial program completed Preliminary Assessments (PAs) for
over 4,000 sites, Site Investigations (Sis) for over 1,300 sites and 155 Hazard Ranking
System (MRS) scores (see Exhibits 3 and 4). Ninety-nine sites were listed as final NPL
sites, while an additional 64 sites (63 non-Federal, 1 Federal) were proposed for listing.
In addition, the pre-remedial program substantially completed development of Update 7 to
the NPL that will propose approximately 200 new sites.
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Exhibit 2
FY 1987 ROD Summary
Total RODs Completed
Final Source Control RODs
Total RODs Employing Source Treatment
Selected Remedies*
Treatment Technology
Incineration/Thermal
Solidification
Stabilization/Neutralization
Violatilization/Aeration
Soil Washing/Flushing
Biodegradation
Other
Total
Containment
On-Site Containment
Temporary Storage
Off-Site Disposal
Ground Water
Pump and Treat
Alternate Water
Supply
No Further Action
Program
47
26
18
9
5
2
3
1
2
22
10
8
1
13
7
3
Enforcement
28
18
7
2
1
1
2
-
1
1
8
17
-
1
10
3
3
Total
75
44
25
11
6
1
4
3
2
3
30
27
8
2
23
10
6
* More than one remedy may be associated with a site
Remedy Costs
Program
Enforcement
Total
0-$2M
20
7
27
2-S5M
13
9
22
5-$10M
5
4
9
10-S20M
3
2
5
20-$50M $50M+
5
2
7
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PA's completed
23,000
(90%)
FY 1987
Exhibit 4
7500 C"
6500 |O ".";.' \
5500
4500
3500
Total CERCLIS* = 27,000 (estimate)
Percent of CERCLIS Sites with
Preliminary Assessments Completed
Through FY 1987 (Cumulative)
* (Inventory of potential Superfund sites)
2500
1500
500
\FY 1981-1986
Number of Site Investigations
Completed
Two major project management support activities initiated in FY 1987 were the Alternative
Remedial Contracts Strategy (ARCS) and the RI/FS Improvements Initiative. The ARCS
concept was fully developed and procurement actions were initiated in two EPA Regions.
Key components of ARCS include promoting continuity of performance from RI/FS to
construction management, increasing the level of competition for contract awards, and
facilitating contract management delegations to the Regions. Contract awards under this
program in the two pilot Regions will begin in December 1987, and procurement actions
will be initiated in all remaining Regions during FY 1988. The RI/FS Improvements Initiative
was forwarded to the Regions on July 23, 1987. The document includes suggested project
timelines and a series of project management recommendations.
Removal Actions
Since the inception of the Superfund program in 1980, the emergency removal program
has been highly successful. Removal actions are relatively short-term actions designed to
protect public health, welfare or the environment. Removal actions may require an
immediate response to an emergency, such as a fire, chemical leak, or explosion. Some
are quite extensive, involving significant engineering and requiring several million dollars to
complete.
In FY 1987, 254 removal actions were initiated and 193 actions were completed using
Trust Fund resources. This is, by far, the largest number of removals conducted in one
year since the program began in December 1980. The total number of removal actions
initiated since the enactment of CERCLA in 1980 is 1,051 (see Exhibit 5).
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In FY 1987, the Office of Emergency and Remedial Response (OERR) implemented Phase
I of an Emergency Response Notification System. This system involves all ten Regions
capturing and sending release notification reports to a centralized data base to be
combined with National Records Center data. This information is used by the emergency
response and preparedness programs, as well as other EPA offices and the States.
Exhibit 5
1200
1000
FY 1987
800
600 ^^^
1981-1986
400
200
Number of Removal Actions
Initiated
During the course of FY 1987, the removal program reissued all four zone contracts, two
Technical Assistance Team (TAT) contracts, four dioxin contracts, several 8(a) contracts
and two Regional Emergency Response Cleanup Services (ERGS) contracts. These
contracts provide the technical assistance and cleanup services that EPA needs to
implement an effective removal program. In addition, OERR began working to implement
the recommendations of the On-Scene Coordinator (OSC) Management Support Task
Force, intended to assist the OSCs in meeting current administrative requirements for
financial management, contract management, and documentation for cost recovery. Five
Regions established Administrative Support Units to implement the recommendations, and
the remaining five will establish similar units in FY 1988. In addition, Headquarters is
providing training to the OSCs on methods of cost control and on the new Cost
Management Manual. A software program was developed to aid the OSCs in improving
cost management. Revised removal contracts and program guidance were also
developed.
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ENFORCEMENT PROGRAM
EPA can use Superfund enforcement authorities to require a response action by a party
responsible for the contamination. EPA can obtain clean-up action by taking parties to
court, reaching an out-of-court settlement or issuing unilateral administrative orders where
there is a threat to public health and the environment. If an immediate threat to public
health develops, or if a private party delays negotiations on settlements for a lengthy
period, the Agency can use Fund money to address the hazard at once.
Under the enforcement program in FY 1987, 47 (out of 123) RI/FSs and 19 RD/RAs were
conducted by Potentially Responsible Parties (PRPs). Exhibit 6 shows total progress
(remedial plus enforcement) toward the SARA statutory goal of initiating 275 RI/FSs by
October 1989. Eighteen consent decrees were lodged to initiate remedial designs.
Several others are in the final stages prior to issuance.
Exhibit 6
300
270
240
210
180
150
120
90
60
30
0
I 1 FY 1989 Goal
HI FY 1988 Goal
EZ3 FY 1987 Goal
FY 1987 Actual
Progress toward Meeting
SARA RI/FS Goal
(Remedial & Enforcement)
Cost Recovery and Settlements
During FY 1987, the cost recovery program focused on prioritizing sites for cost recovery
based on statutes of limitations and availability of PRPs, and on revising cost recovery
revenue projections for the next five years. In FY 1987, the Regions referred 37 sites for
cost recovery at a combined dollar value of approximately $81 million, and completed 43
cost recovery settlements for a total value of almost $36 million (see Exhibit 7). In
addition, we reached 17 settlements in which PRPs will conduct the RD/RA and 50
settlements for RI/FSs. The value of the RD/RA settlements is in excess of $110 million.
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Exhibit 7
FY 1987
FY 1981-1986
80
70
60
50
40
30
20
10
Dollar Value of Cost Recovery
Settlements
($ in millions)
REGULATIONS, GUIDANCES, AND OTHER ACTIVITIES
In parallel with the substantial site activities, OSWER was very active in developing
regulations and guidance. Some of these activities were mandated by SARA, others were
needed to improve the pace of the Superfund programs. In particular, the "project
management approach" was implemented to assist the Regions in moving Superfund
projects more expeditiously through the system (as discussed in the Executive Summary).
Extensive guidance was also drafted on how CERCLA actions should comply with
applicable or relevant and appropriate requirements (ARARs) of other Federal laws, as
required by SARA. The following sections outline additional regulatory and guidance
activities during the past year.
National Contingency Plan (NCP)
A major effort over the past year has been the mandated revision of the NCP, which
contains most of the Superfund regulatory program. Key elements of the NCP will include
the selection of remedy process, State involvement in cleanup activities, requirements
related to off-site disposal of Superfund waste, and details of the administrative record to
be maintained. We expect proposal of the revised NCP during the first half of FY 1988.
Hazard Ranking System (MRS)
The revised MRS will be used to identify National Priorities List sites. We have compressed
the time schedule and expect to complete this rule before the end of FY 1988.
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Guidance for Determining Selection of Remedy
EPA decision makers were provided guidance to assist in making the selection of remedy
at Superfund sites. The following key criteria should be considered in evaluating
alternatives:
Compliance with ARARs
Reduction of toxicity, mobility, and volume
Short-term effectiveness
Long-term effectiveness and permanence
Implementability
Cost
Community reaction
State acceptance
Overall protection of human health and the environment
Technical Assistance Grants (TAGs)
Another SARA provision requires that TAGs be made available to citizen groups to hire
their own consultants to review site activities. We expect to publish an interim final rule
this winter, and we will make grant awards under its provisions as we develop the final
rule.
Streamlining the Settlement Process
Key elements of this guidance document (issued February 12, 1987) are establishment of
criteria for settlement decisions; formation of two committees to expedite policy decisions
in Headquarters; and setting of deadlines for settlement negotiations, for which only the
Regional Administrator or the Assistant Administrator can extend the period of negotiation.
Nonbindina Allocation of Resources (NBARs)
The NEAR guidance (issued May 28, 1987) discusses the preliminary allocation of costs of
cleanup among PRPs and is based on such factors as volume, toxicity, mobility, and the
nature of the case against the parties.
Guidance on De Minimis Settlements
This guidance (issued June 19, 1987) provides that EPA will enter into £le_ minimi's
settlements with small contributors who are minimally liable for the costs of cleanup. This
settlement mechanism removes the minor contributors from the negotiation process so
EPA can concentrate its efforts on negotiating with the major responsible parties.
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Guidance on Convenants not to Sue
EPA issued guidance on covenants not to sue on July 10, 1987. A covenant not to sue is
a third mechanism EPA may use to assist the settlement process. A covenant would
provide for PRPs to select a permanent remedy in return for a release from future liability.
Guidance on Use of Mixed Funding
SARA also authorized EPA to use mixed funding measures (mixed Fund/PRP financed
cleanup) to reach settlement. EPA provided guidance that provides a method for
evaluating mixed funding agreements on October 20, 1987.
Special Notice Guidance
Special notices will be used for RI/FS and RD/RA in most cases. Special notices will
invoke moratoria on EPA conduct of RI/FSs under section 104(b), response actions under
section 104(a) and enforcement actions under section 106. Guidance was issued in
October 1987.
Reimbursement to Local Governments Rule
SARA authorizes reimbursement of local governments for costs incurred in providing
temporary emergency measures in response to releases of hazardous substances.
Reimbursement can be granted for up to $25,000 per incident. An interim final rule was
recently published in the Federal Register.
Health Assessment Guidance
A close working relationship was maintained with the Agency for Toxic Substances and
Disease Registry (ATSDR) throughout the year. A procedural manual on conducting
health assessments was jointly issued by EPA and ATSDR. The manual is designed to
integrate health assessment provisions of SARA into the remedial program.
Suoerfund Innovative Technology Evaluation (SITE) Program
The SITE program was established by SARA to help develop treatment technologies
necessary to implement the new cleanup standards. The program's objective is to
develop, demonstrate, and subsequently encourage the use of such technologies as
alternatives to land disposal. Presently, 22 technologies have been accepted into the
program, and the third Request for Proposals will be distributed in January 1988. By the
end of the calendar year, we will have initiated field demonstrations of infrared incineration,
solidification, in-situ vacuum extraction, and oxygen enhanced incineration technologies.
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Outreach and Training Activities
A key element of reauthorization was conducting a variety of outreach and training
activities designed to reach the Regional and State implementors. Throughout the year,
OERR and the Office of Waste Programs Enforcement (OWPE) staff visited all ten EPA
Regions to provide hands-on advice on incorporating new SARA provisions in ongoing
projects and on developing RODs,
OSWER produced a national teleconference designed to introduce a broad range of
Regional and State personnel to the SARA provisions. This was followed by a series of
six, two-day conferences, sponsored by OERR and OWPE, reaching all ten Regions and
numerous State personnel, to describe emerging SARA implementation policies.
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SECTION 2
RESOURCE CONSERVATION & RECOVERY ACT
The RCRA program made substantial progress in addressing the priorities outlined for FY
1987. New regulations were developed to fill gaps in environmental protection and to
correct problems in the existing regulations. A foundation was laid to provide a more
workable program in the future by encouraging waste minimization, examining the criteria
for disposal of municipal solid waste, continuing to study large volume wastes and working
to establish and maintain reliable and useful databases. Significant progress was also
made in implementing the RCRA requirements: meeting the permitting deadlines, requiring
corrective action, conducting compliance monitoring and enforcement activities, and
providing guidance and assistance to the Regions and States. This section reviews the
specific progress made in these areas.
REGULATORY ACTIVITIES AND REPORTS TO CONGRESS
Regulations were developed in several areas in FY 1987, including land disposal, used oil,
small quantity generators and closure. The Office of Solid Waste (OSW) also prepared
several Reports to Congress in response to statutory requirements. Summaries of key
activities are provided below.
Strengthen and Improve Land Disposal Restrictions
The Hazardous and Solid Waste Amendments of 1984 (HSWA) recognized that land
disposal should be the least favored method of managing hazardous waste because of the
potential for ground-water contamination and other hazards associated with land disposal.
The program for restricting land disposal of waste includes a series of deadlines for issuing
regulations that specify levels of treatment needed before the residues left after treatment
are acceptable for land disposal. During FY 1987, the Agency issued a final rule to set the
overall framework and to restrict dioxins and solvents from land disposal (November 7,
1986). In addition, we proposed and promulgated the regulation restricting the "California
list" of hazardous wastes from land disposal (December 11, 1986, and July 8, 1987,
respectively). HSWA also mandated the development of new technological requirements
to ensure that those land disposal facilities continuing to operate and those disposing of
treated wastes provide the greatest protection possible. The Agency proposed regulations
for containing liquid hazardous waste on December 24, 1986, and expanding requirements
for leak detection systems on May 29, 1987.
On July 7, 1987, EPA promulgated a rule containing a revised list of constituents for which
there are reliable statistical tests for assessing potential ground-water contamination. On
August 24, 1987, the Agency proposed a new statistical method for determining
ground-water contamination. Current regulations do not apply to certain methods of
disposal now in existence. Examples include open burning and open detonation used by
the military. On November 7, 1986, the Agency proposed regulations covering these
facilities.
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Used Oil Standards
HSWA required EPA to make a determination as to whether used car and truck crankcase
oils should be listed as hazardous and managed under Subtitle C regulations. In a
November 1986 proposal, augmented in March 1987, the Agency announced that it will not
list as a hazardous waste used oil that is recycled. Used oil being disposed of may be
listed as a hazardous waste in the future after study, or EPA may regulate such used oil
under the Toxic Substances Control Act. Burning hazardous wastes and used oils in
boilers and industrial furnaces, as well as storage and transportation of these wastes prior
to burning, can result in air emissions containing toxic pollutants and carcinogenic
substances. EPA, therefore, proposed a rule on May 6, 1987, that would place certain
management standards on the burning of these wastes.
Small Quantity Generator Wastes
Generators of 1,000 kilograms or less per month of hazardous waste (small quantity
generators) were not subject to the hazardous waste regulations prior to HSWA. In
October 1987, the Agency proposed regulations that would make the existing rules for
storage of hazardous waste now affecting large quantity generators also apply to small
quantity generators those generating from 100 - 1,000 kilograms per month of
hazardous waste. In addition, EPA proposed and promulgated regulations requiring small
quantity generators to file a modified manifest exception report with the Agency (May 1,
1987, and September 23, 1987, respectively). This report provides the generator with a
record that the wastes have been received by the designated treatment or disposal facility.
Closing Hazardous Waste Facilities
The current regulations provide two options for closing landfills, surface impoundments,
and waste piles. There are circumstances where a combination of methods would be the
most environmentally protective. Such methods were proposed on March 19, 1987.
Further, the Agency issued a final rule on the same day to make consistent the closure
requirements for interim status and permitted facilities.
Reports to Congress
HSWA required study of municipal solid waste facilities and, if necessary, revision of the
solid waste disposal criteria. The Agency issued a nine volume Report to Congress on
Municipal Waste Combustion on July 7, 1987. In addition, two informational documents
were released in October 1986: "A Survey of Household Hazardous Wastes and Related
Collection Programs" and "Census of State and Territorial Subtitle D Non-Hazardous
Waste Programs."
RCRA exempted certain large volume wastes from regulation under Subtitle C until further
study and Reports to Congress. In FY 1987, EPA continued to study oil, gas and
geothermal energy production wastes to determine whether they should be regulated
under Subtitle C, and expects to issue a final report by December 31, 1987. In addition.
the Agency developed a study on wastes from utilities for a Report to Congress, also due
in December 1987.
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The Agency issued a Report to Congress on Waste Minimization in October 1986 that
showed current waste generation and management practices. The report stated that there
is a need to develop incentives for research into methods of waste reduction and laid out
the types of programs that are necessary over the next several years to move industry
toward aggressive waste reduction.
Subtitle D - Report to Congress. RCRA established a cooperative framework for
Federal, State, and local governments to control the management of solid waste under
Subtitle D. HSWA required the Agency to conduct a study of the extent to which the
existing Subtitle D Land Disposal Criteria are adequate to protect human health and the
environment from ground-water contamination. During 1987, work continued on a Report
to Congress through the collection of data on Subtitle D waste characteristics, Subtitle D
facility characteristics, and State Subtitle D program characteristics. In November 1986,
Phase I of this Report to Congress was issued. The final report will include the Agency's
final conclusions about solid waste disposal facilities and practices, and will be issued in
early 1988.
Increased attention has also been focused on working more closely with States and
localities, who will continue to have the basic solid waste management responsibility, to
ensure that their planning activities are improved and that the public is fully involved.
PERMITTING PROGRAM
The RCRA statutory deadlines for permitting provide an ambitious agenda for the Agency.
Progress toward meeting the November 1988 deadline for land disposal permits was
significant in 1987. EPA and the States issued 54 permits for land disposal facilities and
denied 37 permits for land disposal facilities. Closure plans for 332 land disposal facilities
were approved during the same time period (see Exhibit 8). The Agency and the States
also issued 14 permits for incinerators and denied two permits for incinerators as well as
approved closure plans for 13 incinerators in FY 1987 (see Exhibit 9). The statutory
deadline for incinerator permits is November 1989.
To promote faster permitting and increase capacity development, EPA proposed, on June
3, 1987, a new system for permitting mobile treatment units; and on August 14, 1987, it
proposed simplified procedures to allow changes at interim status and permitted facilities
that are necessary to comply with new regulations. This regulation will allow facilities to
avoid delays in, or termination of, treatment and disposal services as they proceed to
meet the new requirements. On September 23, 1987, the Agency proposed a revised
process that would provide a more flexible and rapid system for issuing permit
modifications.
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Exhibit 8
540
480
420
360
300
240
180
120
60
'87
'82-'86
Permits
Issued
Permits
Denied
Closure Plans
Approved
Land Disposal Facility Final Determinations
50
40
30
Exhibit 9
ZJ'87
'82-'86
Permits Permits Closure Plans
Issued Denied Approved
Incinerator Final Determinations
CORRECTIVE ACTION
HSWA called for the cleanup of releases from solid waste management units at RCRA
facilities. HSWA corrective action covers releases not only to ground water, but to air,
surface water, and soil. The development of this program is being coordinated closely
with the CERCLA cleanup program. On October 24, 1986, EPA proposed a rule to require
facilities to demonstrate financial assurance for corrective action. The Agency published
the National Corrective Action Strategy in October 1986 and proposed and promulgated
regulations to allow the development of a corrective action program at regulated units after
permitting a land disposal facility (December 9, 1986, and June 22. 1987). In FY 1987,
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the following corrective action initiatives were taken: RCRA facility assessments (RFAs)
were undertaken at 311 land disposal facilities, ten incinerators, and 57 storage facilities.
In addition, RCRA facility investigations (RFIs) were undertaken at 34 land disposal
facilities, two incinerators, and seven storage facilities. In FY 1987, the Regions drafted 25
corrective action administrative orders under RCRA sections 3008(h) and 3013; and seven
judicial referrals for corrective action under RCRA sections 3008(h) and 7003. In addition
to the 25 orders, the Regions issued ten final section 3008(h) administrative orders.
An intensive corrective action order training course was completed for all Regions and
Headquarters in June 1987. Completion of this course enabled EPA Headquarters and
Regional staff to effectively develop corrective action orders under 3008(h). The 3008(h)
model order was developed and utilized in draft form throughout most of the fiscal year.
Final revisions are now under review and the final model order should be completed in
early FY 1988. The RCRA Corrective Action Plan was completed November 14, 1986.
This plan provides detailed Scopes of Work for conducting RFIs, Corrective Measures
Studies (CMS), and Corrective Measures Implementation (CMI). The final Interim
Measures Guidance was issued June 10, 1987. This provides guidance in developing and
ordering short term actions in response to immediate threats or potential threats of
exposure to hazardous wastes.
ENFORCEMENT
In FY 1987, RCRA enforcement focused its attention on pursuing formal enforcement
actions against RCRA land disposal facilities with inadequate ground-water monitoring
systems; assuring compliance with approved closure plans, final orders, decrees and
permit conditions; as well as enforcing major HSWA requirements, including land disposal
bans. Emphasis was also placed on ensuring Federal facility compliance and supporting
criminal enforcement.
Inspections
All of the approximately 1,500 land disposal facilities received either a compliance
evaluation inspection or a comprehensive ground-water monitoring evaluation by either
EPA or the States in FY 1987, as required by HSWA. In addition, all Federal, State and
local treatment, storage and disposal facilities and a large majority of other treatment and
storage facilities were inspected.
Significant Non-Compilers (SNCs)
Particular emphasis was placed on assuring enforcement against SNCs (i.e., facilities with
Class I violations of the ground-water monitoring, closure, post-closure or financial
responsibility requirements). At the beginning of the year, there were 744 SNCs, 260 of
which had not been addressed with formal enforcement action. At the end of FY 1987, all
but 7 of these had either been addressed by EPA or the States with enforcement actions
or they had returned to compliance (see Exhibit 10).
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Loss of Interim Status (LOIS)
LOIS inspections were conducted in FY 1986 at all of the approximately 1,500 land
disposal facilities in existence on November 8, 1985. Inspections were conducted to
determine the validity of those facilities certifying compliance with the ground-water
monitoring and financial responsibility requirements, and to ensure that those facilities who
failed to certify were not operating hazardous waste disposal units. Many of the violations
discovered as a result of these inspections were addressed with formal enforcement
actions in FY 1987. For FY 1987, 994 facilities lost interim status. Of that number, 59
facilities were discovered to be operating without interim status, resulting in 16
administrative orders and 42 civil referrals. In addition, of the 100 facilities that failed to
submit closure plans, the Agency issued 55 administrative orders and processed 33 civil
referrals.
Exhibit 10
Tatar Begirtrting-of-year
: SNC* * 744
Beginning-of-year SNCs
with Formal Enforcement
Action or Returned to Compliance
GUIDANCES, TRAINING, AND OTHER ACTIVITIES
A major Headquarters implementation activity is the development and issuance of
guidance documents to interpret the requirements of technical regulations and explain how
those requirements can be met. In FY 1987, OSW issued 16 guidance documents
addressing the following areas:
Incineration
Ground-water alternate concentration limits
Corrective action
Closure
State program development
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Radioactive mixed waste
Tank systems
Minimum technology requirements
Test methods
Land disposal restrictions
Another important Headquarters activity is providing training and direct technical
assistance to the Regions and States. The Permit Assistance Teams provide specialized
technical expertise to the Regions and States for particularly difficult or precedent-setting
permit or closure issues. In FY 1987, the Permit Assistance Teams conducted over 55
reviews of such issues.
In FY 1987 training courses were presented to Regional and State staff on:
RCRA Facility Assessments
RCRA Facility Investigations
Risk Assessment Communication
Land Disposal Restrictions
Ground-water Technical Enforcement Guidance Document
The RCRA program manages large and ever-growing amounts of data on facility
permitting and compliance status, hazardous waste generation, and from special surveys.
A major effort is under way to develop more reliable and useful data bases, necessary to
manage the hazardous waste program. During FY 1987, the Agency determined the types
of data and data categories needed, and designed methods of data entry suitable for easy
State-Federal interaction. In January 1987, EPA initiated a survey of treatment, storage,
disposal and recycling facilities. In August 1987, the Agency began a new study of the
current waste generation rates.
Office of Ombudsman
In May 1986, OSWER established the Office of Ombudsman in Headquarters, as required
by section 2008 of RCRA. Each of the ten Regional Offices also designated a
representative to respond to hazardous waste complaints, grievances, and requests for
information. In its first year, the Office of Ombudsman received over 2.000 requests for
assistance. The interaction with primarily private citizens and small businessmen is a
valuable tool in EPA's management of the hazardous waste program.
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SECTION 3
UNDERGROUND STORAGE TANKS
Major accomplishments of the Office of Underground Storage Tanks (OUST) for FY 1987
included the proposal of regulations for tank technical standards, corrective action and
State program approval, as well as development of policies and procedures to support
implementation of the Leaking Underground Storage Tank (LUST) Trust Fund. OUST has
placed significant emphasis on creating a program which will work and can realistically be
carried out in 50 States and 3,000 counties. OUST Regional and Headquarters staff
recognize that their role is to build effective State programs rather than to be directly
involved in implementing the program.
TECHNICAL STANDARDS
On April 17, 1987, OUST proposed a comprehensive set of technical standards for
underground storage tanks. These included design, construction, installation, and release
detection standards for new tanks, release detection and upgrading requirements for
existing tanks, and corrective action requirements for tanks found to be leaking. The
objective of OUST in drafting these rules was to fashion a regulatory program that is
practical, flexible, and easy to understand and implement. During June, OUST conducted
public hearings on the proposed rule. The hearings were attended by more than 1,000
people and over 100 people testified. OUST has since received approximately 5,000
comments from over 1,100 commenters. During the public comment period, OUST took
the opportunity to solicit comments more directly by conducting three separate series of
expert meetings on different aspects of the rules and by interviewing in person over 50
manufacturers, owners, installers, tank testers, and State and local regulators.
FINANCIAL RESPONSIBILITY REQUIREMENTS
On April 17, 1987, EPA also proposed financial responsibility requirements for underground
storage tank (UST) owners and operators. Simultaneously, OUST launched a project
aimed at developing State funds or financial assurance mechanisms that could be
available when the financial responsibility requirements take effect. OUST has since
worked closely with the insurance industry, tank owners and State officials to assure that
the proposed regulations promote OUST's objective to encourage the availability and use
of financial assurance mechanisms in the future.
STATE AND LOCAL PROGRAMS
EPA proposed requirements for the approval of State UST programs to operate in lieu of
the Federal requirements. This proposal established flexible program elements and
methods for judging the stringency and enforcement adequacy of State programs. In
drafting these requirements, OUST's primary objective was to emphasize environmental
results while being flexible in the means various States may choose to obtain those
results.
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Many States and local governments have started or accelerated development of their own
UST programs. In part, this stems from the work of EPA Regional and Headquarters
programs. By the end of the second year of the UST or preventive program, 48 States
had their own notification systems, with 1.7 million tanks registered with the States. Two
notification systems are being run by EPA Regional Offices, with contractor help. Many
States have chosen to use the nationally developed notification form and software. Many
States have or are developing fee systems to fund their State prevention programs. The
fee systems are frequently based on notifications or permits for tanks and this is providing
an incentive for States to update and complete their tank inventories. OUST's emphasis
on flexibility and letting States determine what is the best way to run their UST programs is
demonstrated by the mix of agencies responsible for the program. Five States have
placed the program in the State Fire Marshall's Office, one in the State Corporation
Commission, about eight in the water program and the remainder in the hazardous waste
program.
LUST TRUST FUND IMPLEMENTATION
Following the passage of SARA, OUST moved quickly to complete the policy ingredients
necessary for implementing the LUST Trust Fund. Essential elements of this effort include:
OSWER guidelines for initial cooperative agreements
Federal Register notice for State clearinghouse review
Delegations of key authorities to Regional Offices
Mechanism for allocation of funds to Regions
OSWER directive for implementation of cost recovery provisions
In addition, OUST worked closely with other offices to ensure the timely production of other
critical guidances pertaining to legal issues, accounting and financial policies, and Federal
lead role in corrective actions. These products paved the way for rapid start-up of the
Trust Fund program, consistent with the goals of environmental protection and State
implementation.
States are taking the lead in implementing the Trust Fund program. Forty States and
three territories have now signed cooperative agreements, and several more should be
completed early in FY 1988 (Exhibit 11). Many of these States are now procuring
contractors and will begin site assessments and cleanups soon. EPA has provided a
limited backup role, taking a lead or supporting role in a few enforcement cases only on
State request; but most States have moved ahead with existing or new authorities to take
the lead in addressing UST leaks. OUST has started to work through grant agreements
with several organizations such as the New England Interstate Water Pollution Association,
the Environmental Task Force, and the U.S. Conference of Mayors, on projects that will
help the regulated community and others understand, carry out, or comply with the final
technical and financial responsibility regulations.
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OUTREACH ACTIVITIES
During FY 1987 OUST developed the following products to inform the regulated community
about the UST program:
A quarterly bulletin, "Lustline", aimed at State officials, discusses the
latest UST issues and developments
A technical newsletter focuses on technical information exchange
A "plain English" brochure on designing and installing tanks under the
current laws, the Interim Prohibition
Two "plain English" brochures ("What's in the Pipeline" and "Your
Financial Responsibilities") summarize the proposed regulations to help
the regulated community understand the EPA proposal
A slide show, "Tank Talk", on the proposed regulations, mainly for use
by EPA Regional officials
A fact sheet and Qs & As on the Trust Fund
Public hearings, which were not required by law, but carried out to
receive as much helpful feedback as possible on the proposed rules
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SECTION 4
CHEMICAL EMERGENCY PREPAREDNESS AND
PREVENTION PROGRAM
The new Superfund also gave us Title III emergency planning and community
right-to-know. The overall program goals are to: promote community awareness of
chemical hazards, assist in the development of State and local preparedness programs
and response capabilities, and develop a chemical accident prevention program. In FY
1986 and 1987 the program objectives were to: develop the list of extremely hazardous
substances and accompanying guidance; build program infrastructure at the Federal,
State and local levels; begin program implementation; and establish data bases to better
understand the causes of chemical accidents. In FY 1987, implementation of the
Chemical Emergency Preparedness and Prevention (CEPP) program was enhanced by the
new requirements of Title III of SARA (October, 1986): a State and local emergency
planning structure, industry reporting requirements (community right-to-know) and broad
participation in the planning process.
Throughout most of the year, the Preparedness Staff focused on meeting the many
statutory deadlines imposed by Title III. All major program objectives and deadlines were
met.
REGULATORY ACTIVITIES
On November 17, 1986, EPA promulgated the SARA section 302/304 interim final rule
establishing the list of 406 extremely hazardous substances, their threshold planning
quantities, and the emergency planning and release notification requirementsmeeting the
30-day statutory deadline. The final rule was promulgated on April 22, in advance of the
statutory reporting deadline of May 17. The Preparedness Staff developed a proposed
rulemaking for the material safety data sheet and hazardous chemical inventory reporting
requirements within 90 days as required by Title III. The final rule was promulgated in
advance of the first SARA section 311 reports due October 17, 1987. The Preparedness
Staff also supported development of the proposed rulemaking on trade secrets in advance
of the first reporting deadlines for which trade secrets could be claimed. The
Preparedness Staff coordinated overall Title III implementation with the Office of Toxic
Substances (OTS), which has the lead for the SARA section 313 emissions inventory.
OTS promulgated a proposed rule and accompanying technical guidance on section 313
reporting requirements on June 4.
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REGIONAL AND STATE ACTIVITIES
Regions continued to work with States to develop agreements (State Implementation
Memoranda) on State program implementation and designating priority areas for technical
assistance. Agreements have been developed with about half of the States. Regions
provided assistance in conducting an exercise to test emergency plans in a priority area in
each State and provided other technical assistance and training to States and
communities. During FY 1987, State Governors established State emergency response
commissions, designated local planning districts (over 3,000 districts were established),
and appointed local emergency planning committees as required by Title III. The
Preparedness Staff developed a program to gather information on cases of chemical
accidents, prevention policies and practices, and technologies in place at the time of the
accident, and initiatives taken to prevent accidents from recurring. This program, called
the Accidental Release Information Program (ARIP), was pilot tested in one Region early in
the year. The test was expanded to all Regions in the spring.
EMERGENCY PLANNING
EPA worked with the other 13 National Response Team (NRT) agencies to develop the
guidance on emergency planning required by section 303(f). In addition to publishing the
emergency planning guide, the NRT completed a training strategy for coordinating Federal
hazardous materials training with State, local and industry training. The NRT established a
number of policies and procedures for managing the NRT/Regional Response Team (RRT)
system, began work on computer applications for preparedness and response, and
initiated planning for the 1988 Hazardous Materials Spills Conference.
EPA worked with the Federal Emergency Management Agency (FEMA) and the
Department of Transportation (DOT) in developing draft technical guidance on
site-specific planning for releases of the 406 extremely hazardous substances. EPA also
worked with FEMA to make $5 million in grants available to States for Title III training. EPA
provided the funding to FEMA through an interagency agreement and developed a plan for
use of the funds with FEMA as required by Congress. All States (except Nebraska, which
did not apply) were allocated funding through FEMA's existing comprehensive cooperative
agreement with each State. EPA and FEMA developed and delivered a joint training
course in contingency planning.
The Preparedness Staff initiated the review of emergency systems for detecting,
monitoring, alerting the public and preventing releases of extremely hazardous substances
and developed an interim Report to Congress, as required by Title III. While led by
OSWER, the study involves a cooperative effort with several offices within the Agency as
well as with FEMA, which is providing its expertise for the public alert section of the study.
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OUTREACH ACTIVITIES
Other noteworthy prevention-oriented activities completed by the Preparedness Staff
include analysis of a proposed accident prevention section of the Air Toxics Bill; working
with the Occupational Safety and Health Administration (OSHA) and the Nuclear
Regulatory Commission (NRC) on a joint inspection program directed at improving
chemical safety, filling technological gaps and supporting the tort liability system; working
with OTS and the American Institute of Chemical Engineers (AlChE) to conduct an
International Symposium on Prevention of Chemical Accidents; and working with AlChE to
identify needs for chemical process safety guidelines. The Preparedness Staff
participated in the SARA teleconference in March and conducted an additional
teleconference devoted to Title III in June. EPA worked with almost 30 other organizations
(Federal agencies, State and local organizations, trade organizations, and public interest
groups) in conducting six workshops on Title III implementation across the country in July
and August. In addition, the Preparedness Staff developed and distributed thousands of
copies of a Fact Sheet on Title III, and has made many presentations to organizations and
groups affected by Title III.
INTERNATIONAL ASSISTANCE
The Preparedness Staff is also active in international emergency response activities. In
bilateral relations, the Preparedness Staff co-chaired Joint Response Teams with Canada
and Mexico and developed Joint Contingency Plans for responding to releases along U.S.
borders. In multilateral efforts, the Preparedness Staff initiated a preparedness/prevention
project with the Organization for Economic Cooperation and Development (OECD) as a
result of the ministerial level meeting on chemicals; is working with the United Nations
Environment Program (UNEP) on two protocols for international notification of releases
and assistance in response actions; and is working with the International Program for
Chemical Safety (IPCS) in developing profile cards on toxic chemicals.
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I'.o. Environmental Protection Arc-
"!ogion 5, Library (5PL-16)
£30 S. Dearborn Street, Room 1670
Chicago, IL 60604
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