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DIRECTIVE NUMBER:  9480.0K84)
TITLE:  Land Disposal of Hazardous Waste

APPROVAL DATE: 6-12-84
EFFECTIVE DATE: 6-12-84
ORIGINATING OFFICE: office of solid waste
E FINAL
D DRAFT
  STATUS:
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    A- Pending OMB approval
    B- Pending AA-OSWER approval
[  ]  C- For review &/or comment
                                D- In development or circulating
                REFERENCE (Othtr dOCUmcntt):      headquarters
'E    DIRECTIVE   DIRECTIVE    D

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PARTS 264 AND 265 - TECHNICAL REQUIREMENTS
                                                DOC:  9480.01(84)
Key Words:

Regulations:

Subject:

Addressee:

Originator:


Source Doc:

Date:

Summary:
Land Disposal, Underground Injections

40 CFR 264 and 265

Land Disposal of Hazardous Waste

Lou A. Be Hone

Kenneth A. Shuster, Chief, Land Disposal Branch,  Office of
Solid Waste

#9480.01(84)

6-12-84
     EPA does not allow disposal of hazardous wastes in deep underground rock
formations that resulted from the testing of nuclear weapons.   This  is  prin-
cipally because of the difficulty in ensuring that hazardous wastes  placed in
such formations would not migrate.   However, the Agency position on  such disposal
does not preclude underground injection of hazardous wastes,  which is addressed
under the Underground Inspection Control Program.

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                                                            9480.01  (84)
                                                JUN 12
Mr. Lou A. bellone,
Eastham Unit
P.O. Box 16
Lovelady, TX  75851

Dear Mr. bellone:

     Thank you for your recent letter to Administrator Ruckelshaus
regarding the use of cavities produced as a result of nuclear
weapons testing for the disposal of hazardous waste.  Mr. Ruckelshaus
has asked me to respond to your letter.

     The major concern in the disposal of hazardous waste ia in
containing the waste so that the potential for migration of
hazardous constituents is minimized.  For this reason, EPA
generally requires the installation of a liner that will prevent
migration of hazardous constituents during the active lite of
the land disposal facility and a cover to minimize infiltration
of precipitation at facility closure.

     The deposition of hazardous wastes in deep underground rock
formations that are capable of containing the wastes without use
of liners or covers is not currently anong the options that EPA
allows, although we are actively developing regulations to address
this type of disposal.  However, severe fracturing of underground
rock formations can be expected as a result of underground nuclear
testing.  Such fracturing would likely provide conduits through
which hazardous constituents could migrate,  furthermore, predic-
tion of tne routes of nijration would be iir.^ossible.  Additional
detonation where hazardous wastes have been placed could result
in the generation of hazardous byproducts of unknown character
and contribute to the dispersal oc nazaraous constituents unncr-
grouno.  Nuclear test sites, therefore, are {-roo^My unsuitable
for hazardous waste- disposal.

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      I hop* that this Information is helpful to you.
Mr. Rucfcelshaus deeply appreciates your concern for the proper
disposal of hazardous waste.

                                    Sincerely yours.
                                    Kenneth A. Shuster
                                    Chief, Land Disposal Branch
                                    Office of Solid Waste
WH-565E:Rich Stessel:pj:S206:382-4654:WSM:6/12/84

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