DRAFT
24401-4
March 25, 1980
RESOURCE CONSERVATION AND RECOVERY ACT REGULATIONS
AFFECTING OWNERS AMD OPERATORS OF
HAZARDOUS WASTE FACILITIES
(40 CFR Parts 264, 265, and 266)
Supporting Documentation for Reporting Requirements
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Notice
The attached document was prepared by one or more
contractors under the guidance of EPA. It is printed here
largely as received from the contractor; the Agency has not
yet completed reviewing it.
Because of the lead time necessary to produce this
study, it was necessary to base it on a preliminary draft
of the final regulations. There were some changes made
later to the regulations. Thus this document unavoidably
does not completely correspond to the regulations finally
promulgated. The Agency is currently analyzing the effect
of the late regulatory changes on the findings of this
study.
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SUMMARY
The Resource Conservation and Recovery Act (RCRA), Sub-
title C, program is designed to control hazardous waste from
the generator to disposition facility. The paperwork involved
is to document the generation, transportation, and disposal of
hazardous wastes so that liability for mishandling can be
established.
The RCRA program regulations were first proposed in the
Federal Register in April and December 1978. More than forty
formal meetings and hearings were held with interested groups.
The list of organizations and individuals consulted number
well over 1,000. EPA is currently under a court order to
implement the program by September 1980. The regulations are
being issued as final rules in phases as per the court order.
On March 19, 1980, the Environmental Protection Agency
submitted to the Office of Management and Budget a clearance
request for the reporting and recordkeeping requirements of
Section 3004 of RCRA. These provisions cover the documenta-
tion requirements imposed on treatment, storage and disposal
facilities. At the time of this submission, companion regula-
tions defining hazardous wastes to be covered by RCRA were not
yet completed. Thus, a burden imposed on treatment, storage
and disposal facilities could only be estimated at the time.
Definitions for what constitutes hazardous wastes have now
been largely agreed upon. New definitions largely exclude
waste amounts of under 1,000 kilograms each, significantly
reducing previous estimates of reporting burdens. This docu-
ment amends the previous submission based on revised estimates.
The universe of treatment, storage and disposal facilities
potentially affected by Section 3004 is 26,400. EPA's initial
estimate of the paperwork burden under Section 3004 regulations
identified only 5 recordkeeping and reporting functions, im-
posing a total burden of $73.4 million. The current paperwork
impact analysis had recosted these five areas and finds that
they impose a burden of only $34.6 million. However, nine
additional information requirements have been identified,
bringing the total impact of RCRA, Section 3004, to $61.4
million or 3.7 million hours. Of this $29.2 million (2.3
million hours) are recurring costs. These estimates were
derived using conservative assumptions and should be seen as
an upper cost limit until more precise information on the
universe of treatment, storage and disposal facilities and
the type of waste to be covered is known.
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CONTENTS
Page
• Legal Requirements 1
• The Regulatory System 4
• Consultation Outside EPA 25
• Consideration of Alternatives to
Reduce Reporting Burdens 27
• Changes the Environmental Pro-
tection Agency has Made to
Decrease the Reporting and
Recordkeeping Burden 30
• Time Schedule for Publication 34
• Tabulation and Publication Plans 37
• Sensitive Questions 38
• Cost Reductions 39
• Evaluation Plan 49
• RCRA Form Being Submitted for
Clearance 51
Appendices
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LEGAL REQUIREMENTS
What the Law Requires
The Resource Conservation and Recovery Act (P.L. 94-580)
signed into law on October 21, 1976, establishes a Federal pro-
gram which will provide cradle to grave regulation of hazardous
wastes. The Act requires EPA to identify the characteristics
of hazardous waste and to list particular wastes as hazardous
(Section 3001). EPA is also required to establish standards
for hazardous waste management applicable to generators (Sec-
tion 5002) and transporters (Section 3003) of hazardous waste
as well as to treatment, storage and disposal facilities (Sec-
tion 3004). Waste generators, transporters and facilities must
notify EPA that they plan to handle hazardous wastes (Section
3010), and treatment, storage and disposal facilities must also
receive an EPA permit to operate (Section 5005). EPA is given
the authority to enter a hazardous waste establishment and in-
spect samples and records "(Section 3007) . If violations are
found, EPA has authority to enforce the provisions of the Act
and its regulations through appropriate civil and criminal
proceedings (Section 3008) .
EPA is also to help States develop hazardous waste manage-
ment programs and can authorize States, upon application, to ad-
minister and enforce a hazardous waste program in lieu of EPA
(Section 3006): Funds have been appropriated to this end
(Section 3011). No State can impose less stringent regulations
concerning hazardous waste than EPA (Section 5009) .
Requirements of Facilities. Section 3004 of the Resource
Conservation and Recovery Act requires that EPA establish re-
gulations covering owners and operators of facilities which
treat, store, or dispose of hazardous waste. Such performance
standards are to include:
• recordkeeping to identify wastes treated, stored or
disposed of and the manner in which they are handled;
• compliance with the manifest system established under
Section 3002.
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• handling of wastes received by the facility according
to EPA standards;
• contingency plans in the event of accidental damage;
• facility operations, staff training, and financial
responsibility;
• compliance with the permitting process required by
Section 3005.
EPA was required to consult with appropriate Federal and
State agencies and provide an opportunity for public hearings
within 18 months of the date of enactment, or by April 1978.
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The Court Order
The Environmental Protection Agency was required by
statute to promulgate rules and regulations under the Resource
Conservation and Recovery Act of 1976 by April, 1978. The
Agency did not meet this deadline. In mid-1978, the State
of Illinois filed suit against the Environniental Pro-
tection Agency seeking to speed up promulgation of the regula-
tions. Other groups joined Illinois in this effort. The case
was heard by Judge Gessell of the District Court for D.C. who
ruled on January 3, 1979, that EPA should have its regulations
in place by December of 1979. Although Judge Gessell recognized
he had no enforcement tools and that the Congress should properly
use its oversight and budgetary powers to follow up on its own
legislation, he took the case on a Court of Appeals decision.
Following the January 3rd decision, EPA realized it would be
unable to meet the December deadline. The Court permitted EPA
to draw up an order setting targets for promulgation of the
final regulations. The order, filed by Judge Gessell on December
18, 1979, (Illinois v. Costle CA £78-1689 et al. (DDC 12/18/79))
established the following deadline for promulgation of the regu-
lations:
February, 1980 - Section 3002, Section 5005, and
Section 3010.
April, 1980 - Sections 3001, parts of Section 3004,
Section 3005, and Section 5006.
September, 1980 - The remaining parts of Section 3004 (financial
responsibility and technical standards).
The Environmental Protection Agency has scheduled its
issuance of hazardous waste regulations to comply with Judge
Gessell"s court order.
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THE REGULATORY SYSTEM
Description of the Program
Following is a brief summary of how the hazardous waste
control system will operate. The determination of whether a waste
is covered by the Resource Conservation and Recovery Act require-
ments is made by consulting the list of wastes and threshhold
levels in 40 CFR Part 261 and the applicability sections in Parts
264 and 265 (40 CFR Part 264.1 and 265.1). For hazardous wastes
which are covered by the regulations, treatment, storage and
disposal facilities are subject to a variety of information
and recordkeeping requirements. These requirements are des-
cribed in this section and, for ease of understanding, have been
grouped into 11 functional areas:
Requirements Primarily Involving Reporting
Annual Report
Manifests
manifest handling
discrepancy report
unmanifested waste report
International shipments
Notification of new owners
Emergency reports
Planning Requirements
Contingency plan
Waste analysis plan
Ground-water monitoring
Closure plans, etc.
Post-closure plan
Land treatment plan/records
Inspection schedule
Recordkeeping Requirements
Operating records
Training records
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Annual Report
RCRA requires facilities to submit annual reports to the
Administrator by March 1 of each year. The annual report must
be submitted on a specified form and contains:
• the facility's EPA identification number
• the calendar year covered
• for off-site facilites, the identification number
of each hazardous waste generator from which shipments
have been received
• a description and quantity of each hazardous waste
received during the year -- for off-site facilities
this information must be listed by the identification
number of each generator
• methods of treatment, storage or disposal for each
hazardous waste
e monitoring data where required under Sections 264.92 (b) (2)
and 265.92(b)(2)
t current estimates of closure and post-closure costs
• a certification signed by the owner or operator or by
his authorized representative
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Manifest System
Regulations under Section 3004 prescribe the final steps
in the manifest system established in Section 3002 rules to
track hazardous waste from its origin with the generator
through its trip with the transporter to its disposition at
a treatment, storage or disposal facility. Owners or operators
of facilities which receive waste from off-site must sign, date
and return a copy of the manifest to the transporter immediately,
and to the generator within 30 days of receipt of the waste.
The Agency believes that the waste generator has primary respon-
sibility to assure safe delivery of his waste to an off-site
waste management facility. Consequently, the manifest is required
to be returned to the generator because this action completes
the information feedback loop, thus assuring the generator that
his waste arrived at the facility to which it was sent. The
Agency specified a 30-day period for the facility to return the
manifest to the generator in order to allow it to combine return
of manifests with monthly billings to generators, thus reducing
paperwork and postage costs. Completed manifests must be re-
tained for a period of three years from the date of delivery
of the waste at the facility. EPA anticipates both short-range
and long-range uses for hazardous waste records. Retention of
manifests for a 3-year period is deemed sufficient for the
majority of enforcement cases. Thus, the EPA has specified a
3-year period for manifests in the generator and transporter
rules as well as in these rules for facility owners or operators.
For longer-range uses, such as responding to situations such as Love
Canal in Niagara, N.Y., the facility recordkeeping rules require that
records (but not necessarily manifests) of all hazardous wastes
handled be maintained until facility closure. However, that
requirement allows the owner or operator the flexibility to de-
sign a recordkeeping system suitable to the specific needs of
his operation. Larger facilities may use automatic data proces-
sing systems. Smaller facilities nay choose to retain manifests
as the basis for recordkeeping.
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Discrepancy Reports
Facility owners or operators receiving shipments which
differ in type and/or quantity of the waste identified on the
manifest must notify EPA if these discrepancies cannot be
resolved. For bulk shipments, discrepancies of less than 10%
from the manifested amount need not be reported. A study of
discrepancies which occured under a similar system in Great
Britain showed that most of them fall within the +_5% range.
EPA anticipates that there will be few discrepancies in excess
of 10%. For shipments in containers, any discrepancy in the
manifested number of containers and those actually received
must be reported. To reduce the discrepancy reporting burden,
EPA allows the facility 15 days in which to resolve any dis-
crepancy amounts. To further minimize the burden, EPA does
not require discrepancy reporting in any fixed format -- merely
a covering letter together with a copy of the manifest in
question.
Unmanifested Shipment Report
Facilities are not required to accept unmanifested
shipments. However, if they do, they are asked to notify
EPA. The Agency wants to have a record of how this waste is
managed, if it is accepted. Furthermore, because of the uncer-
tainty associated with unmanifested hazardous waste, EPA would
also like to know as much as it can about the waste,as soon as
possible. Prompt submission of the details regarding unmani-
fested waste will enable EPA to insure that the facility is
managing the waste in an appropriate manner, and will also allow
the Agency to detect any suspicious patterns of unusually high
incidences of unmanifested waste in particular areas. Such in-
cidences should be infrequent since it is illegal to transport
hazardous wastes without a manifest.
EPA does not require a special form for the unmanifested
waste report. Facility owners or operators must submit, within
15 days of receipt of the unmanifested waste, a report to the
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EPA Regional Administrator containing:
« their EPA identification number
• the date of receipt
• the word "unmanifested" under comments
• the identification number of the generator or the
transporter
• description and quantity of the unmanifested waste
received
« methods of treatment, storage or disposal for the
waste
• and a brief explanation of why the shipment is
unmanifested.
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International Shipments
Owners or operators of facilities that have arranged to
receive hazardous wastes from foreign sources must notify the
Regional Administrator in writing at least two weeks in advance
of the expected date of arrival of the shipments at the facility.
This requirement will permit EPA to determine the quantities
and kinds of hazardous wastes being imported from abroad. It
is anticipated that few such shipments will be received each
year.
Ownership Transfer Requirements
Before transferring ownership or operation of a facility
during its operating life, or a disposal facility during the post-
closure care period, the owner or operator must notify the new
owner or operator in writing of RCRA requirements for such faci-
liities. EPA feels that it is necessary that new owners are
fully aware of their obligations at the time they agree to pur-
chase facilities.
Emergency Reports^
The owner or operator pust not*3 in the operating record
the time, date, and details of any incident that requires imple-
menting the contingency plan. Within 15 days after the incident,
he must submit a \rrritten report on the incident to the Regional
Administrator. The report must include: (1) Name, address, and
telephone number of the owner or operator; C2) Name, address, and
telephone number of the facility; (5) Date, time and type of inci-
dent; (4) Name and quantity of material(s) involved; (5) The extent
of injuries, if any; (6) An assessment of actual or potential
hazards to the environment and human health outside the facility;
and (7) Estimated quantity and disposition of hazardous waste
involved in the incident.
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Preparedness. Prevention, Contingency Plan, and Emergency
Procedures
Section 3004 of RCRA requires EPA to issue regulations
respecting contingency plans for effective action to minimize
unanticipated damage from any treatment, storage or disposal
of any hazardous waste. Requirements for preparedness and
prevention measures to minimize the need for ever using
contingency plans; and emergency response measures to be
taken during and after situations in which a contingency
plan is implemented, also are authorized by Section 3004
of RCRA. EPA believes that such requirements are necessary
adjuncts to contingency plans to insure protection of human
health and the environment.
The final contingency plan rules are intended to
minimize human health and environmental damage in the event
of an unplanned sudden or non-sudden discharge of hazardous
waste to the air, soil, or surface water. The contingency
plan must include:
• Spill prevention provisions,
• Arrangements agreed to by local and state agencies
to provide emergency response support, where needed,
• A list of facility emergency coordinators,
• A list of facility emergency equipment, and
• An evacuation plan where necessary.
Rules for the distribution and ammendment of the plan
are specified, as well as the requirement that a facility
emergency coordinator must be either present, or on call,
whenever the facility is in operation.
Emergency procedures specified in the final rules
include:
• Immediate notification of employees and local,
state, and federal authorities of any imminent
or actual emergencies,
• Immediate assessment of possible hazards to the
environment and human health outside the facility,
• Measures to preclude the spread of fires and explo-
sions to other waste,
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• Proper management of residues,
• Rehabilitation of emergency equipment and notification
of authorities before operations are resumed, and
o Recordkeeping and reporting to EPA on the nature
and consequences of any emergency.
EPA requires that contingency plans be prepared by each
facility and ammended as necessary. Although these plans must
be prepared within six months of the effective date of the
regulations, they need not be submitted to EPA at that time.
Facilities must make these plans available to EPA inspectors
during any on-site reviews and submit them to EPA together
with Part B of the permit application when this is requested.
The contingency plan must be ammended as required by the
following cases:
• Revisions to applicable regulations (interim status],
o Revisions to the facility permit (permitted status] ,
• Failure of the plan in an emergency;
• Changes in the facility design, construction,
operation, maintenance, or other circumstances
that materially increase the potential for dis-
charge of hazardous waste or change the response
necessary in an emergency,
• Changes in the persons qualified to act as facility
emergency coordinators,
• Changes in the emergency equipment at the facility.
EPA believes all these reasons for plan ammendment are
important and that local authorities, where appropriate,
have a need to know about these changes. The first four
cases could involve significant ammendments to a facility's
contingency plan, but such ammendments should occur infrequently
The last two cases may occur more often, but -- in EPA's
opinion -- are not burdensome.
The proposed rule requires that facility owners or
operators file contingency plans with local authorities.
It does not require these authorities to accept them.
Nevertheless, a facility owner or operator will have complied
with the rule if he can document that he submitted a contingency
plan to local authorities who may be called upon to provide
emergency services and that they refused to accept it.
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When an emergency occurs, the facility owner or operator
must submit a report of the event to the Regional Administrator
within 15 days. The report must include information about the
emergency, the extent of injuries or possible hazards to human
helath or the environment outside the faciltiy, and the estimated
quantity and disposition of hazardous material that results from
the incident. In addition, before the affected area can resume oper-
ations, the faciltiy must notify the Regional Administrator
and local authorities that cleanup procedures are completed and
emergency equipment is fit for reuse.
Waste Analysis Plans
The owner or operator must develop and follow a written
waste analysis plan which describes the procedures which he will
carry out to obtain a detailed chemical and physical analysis of
the waste. He must keep this plan on the premises. At a minimum,
the plan must specify:
(1) The parameters for which each hazardous waste will
be analyzed and the rationale for the selection of these parameters;
(2) The test methods which will be used for these param-
eters .
(3) The sampling method which will be used to obtain a
representative sample of the waste to be analyzed;
(4) The frequency with which the initial analysis of the
waste will be reviewed or repeated;
(5) For off-site facilities, the waste analysis that
hazardous waste generators have agreed to supply.
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Ground-Water Monitoring
Ground-water monitoring is only required for surface
impoundments, landfills, and land treatment facilities. The
final regulations also include a provision whereby the Regional
Administrator may require some degree of ground-water monitoring
if it is determined there is a high potential for discharge of
hazardous waste to ground-water from a tank. This determination
of discharge potential will be based on the ability to visually
inspect for and detect leakage and the integrity of the struc-
tural material of the tank. A variance on the ground-water
monitoring requirement may be permitted if the facility can
demonstrate that there is a low potential for the migration of
hazardous waste constituents to an underground source of drinking
water or water supply wells.
An owner or operator of a surface impoundment, landfill
or land treatment facility must, within one year of the effective
date of these regulations, install and operate a ground-water
monitoring system including compliance with the sampling, analysis,
recordkeeping, and reporting requirements.• The facility must
maintain records of the analyses of samples from all ground-water
monitoring wells and other required evaluations throughout the
active life of the facility, and for disposal facilites, through-
out the post-closure care period. During the first year, the
facility is required to submit to the Regional Administrator
the results of quarterly analyses within 15 days of when they
are completed. This will establish the level of initial background
concentrations for the facility. Thereafter, ground-water monitoring
data can be submitted on an annual basis during the active life
of the facility. In addition, the owner or operator must prepare
an outline of and time estimate for completion of a damage
assessment program describing an accelerated and modified ground-
water monitoring program capable of determining the extent and
severity of ground-water contamination caused by the facility.
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Closure. Post-Closure, and Financial Requirements
EPA has developed closure, post-closure and financial
requirement standards to assure, with a high degree of probability,
that all hazardous waste management facilities are closed so
as to minimize maintenance necessary to protect human health and
the environment. Owners or operators of facilities must prepare
closure plans which identify the steps necessary to completely
close the facility at any point during the expected life as well
as the steps necessary to close the facility at the end of its
expected life. These plans are to be prepared at the time the
interim standards become effective and are to be submitted to
the Regional Administrator with Part B of the permit application
when this is requested. When facilities are closed, owners or
operators must notify the Regional Administrator in writing at
least 180 days in advance. When closure is completed, the owner
or operator'must submit certification by a registered professional
engineer that the facility has been closed in accordance with
the specifications in the closure plan.
In addition, disposal facilities must submit a post-
closure plan to the Regional Administrator at least ISO days before
the date expected to close. Ninety days after
closure, the facility must notify both the local land authority
and the Regional Administrator and submit to each a survey plat
showing the location and dimensions of landfill cells, trenches,
etc. Disposal facilities must also record a notation on :the
property deed that will notify in perpetuity any potential pur-
chaser that the land wasused for hazardous waste disposal.
Closure and post-Closure financial standards are required
of facility owners or operators to insure that adequate funds
will be available to close each facility at any point during its
operating life and comply with post-closure requirements. EPA
requires that each facility must estimate the cost of closing
down in accordance with specified requirements. Whenever a change
in the assumptions on which the closure plan is based occurs, a
new closure plan must be prepared. In addition, each year the
estimate of closure costs must'be indexed to the latest published
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annual gross national product implicit price deflator.
Land Treatment
Food chain crops must not be grown on any part of a land
treatment facility, unless the owner or operator has the following
information based on actual field tests or extensive research. He
must also provide this information upon request from the Regional
Administrator:
(1) Analysis of the waste;
(2) Evidence that the hazardous waste constituents either
will not be transferred to the food portion of the crop by plant
uptake or direct contact, or will not be otherwise ingested by food.
chain animals; will not occur in greater concentrations in the crops
grown on the land treatment facility than in the same crops grotvn
on untreated soils under similar conditions in the same region.
The owner or operator must have in writing, and must imple-
ment, an unsaturated zone (zone of aeration) monitoring plan which
is designed to: (1) Detect the vertical migration of hazardous
waste; and (2) provide information on the background concentrations
of the hazardous waste constituents, in similar but untreated soils
nearby. The plan must include, at minimum: (1) soil monitoring
using soil cores, and (2) soil-pore water monitoring using devices
such as lysimeters.
Inspection Schedule
The owner or operator must develop and follow a written
schedule for inspecting all monitoring equipment, safety and
emergency equipment, security devices, and operating and structural
equipment (such as dikes and sump pumps) that are important to pre-
venting, detecting, or responding to environmental or human health
hazards. He must keep this schedule on the premises. The schedule
must identify the types of problems (e.g., malfunctions or deteriora-
tion) which are to be looked for during the inspection. The fre-
quency of inspection may vary for the items on the schedule.
However, it should be based on the owner's or operator's perception
of the rate of possible deterioration of the equipment and the
probability of an environmental or human health incident if the
deterioration or malfunction or any operator error goes undetected
between inspections.
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Operating Record
Facility owners or operators must keep an operating
record which contains much information basic to the receipt and
disposition of hazardous wastes received. This record is not
required to be submitted to EPA, but must be open for inspection
at all reasonable times by any duly authorized employee or agent
of the Agency. The following information is required as part
of the operating record:
• quantity and description of hazardous waste
received
• location and quantity of hazardous waste within
the facility
o records and results of waste analyses
• summary reports and records of all incidents that
require implementing the contingency plan
a records and results of inspections (which must be
kept for only three years)
o monitoring data
e closure cost estimates and, for disposal facilities,
the estimate of annual post-closure care
With the exception of inspection records, the operating
record must be maintained by the facility through its active life
For disposal facilities, it must be maintained also through the
post-closure care period. EPA has not set precise format re-
quirements for the operating record but permits flexibility such
that many normal business records can be used. For example, the
operating record can include series of documents generated at
different locations within facilities and need not be a single
record located only at one place. Additionally, information
contained in automated data processing systems is acceptable as
part of the operating record.
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Training Recordkeeping
The purpose of the proposed training requirements is
to reduce the potential for mistakes which might threaten the
public or the off-site environment by insuring that facility
personnel acquire expertise in the areas to which they are
assigned. The main concern of the training standards is to
insure the protection of public health and the environment
beyond the facility's property line because the Occupational
Safety and Health Administration (OSHA) is responsible for
promulgating standards which insure worker safety within the
property line. However, in so much as these regulations
are designed to prevent all forms of accidents, workers are
generally protected incidentally to protecting public health.
Some facilities may have already established training programs
in compliance with existing OSHA requirements. Due to a lack
of data on these existing programs, they were not considered
as offsets to the cost of implementing RCRA requirements.
Consequently, compliance costs with RCRA requirements are
overstated to the extent that facilities have already im-
plemented training programs under OSHA.
The proposed training standards include requirements
which specify the time by which facility personnel must obtain
the training necessary to do their jobs, the records to be
maintained at the facility of the training received by its
employees, and the minimum frequency with which the initial
training received by the employees must be reviewed. In
addition, the proposed rules require facility personnel to be
familiar with the facility's contingency plans.
Following are the documents and records which must be
maintained by the facility but need not be submitted to EPA
unless requested as part of complaince monitoring:
• the job title for each position at the facility and
the name of the person filling the job;
• a written job description for each position;
• a written description of the type and amount of
both introductory and continuing training that
will be given to each person;
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• records that document the training or job experience
that has been given to, and completed by, facility
personnel.
Training records on current personnel must be maintained
until closure of the facility; training records on former
personnel must be maintained for at least three years.
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Technical Requirements and Special Waste
Interim standards proposed by EPA impose additional
technical requirements for certain types of storage (i.e., containers,
tanks, surface impoundments, waste piles, land treatment, landfills,
and incinerators). These requirements supply more precision to
what is already required in general terms of all facilities. No
new reporting or recordkeeping requirements are established.
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Additional Justification-Practical Utility Considerations
The Resource Conservation and Recovery Act resulted in part
from a finding of the Congress that "disposal of solid waste and
hazardous waste in or on the land without careful planning and
management can present a danger to human health and the environ-
ment." Congress was concerned that hazardous waste presented
special dangers to health, thus requiring a greater degree of
regulation than non-hazardous solid waste. The Act focuses on
establishing criteria for facilities which can dispose of hazard-
ous waste through a permit system and making generators respon-
sible for insuring their waste disposed of off-site reaches such
permitted facilities. Some of the practical utility considera-
tions have been addressed above as part of regulatory program
description. Additional considerations are highlighted in this
section.
The manifest system. The use of manifest system is required
by RCRA which states that EPA shall establish requirement respect-
ing "use of a manifest system to assure that all such hazardous
wastes generated is designated for treatment, storage, or disposal
in treatment, storage, or disposal facilities (other than facili-
ties on the premises where the waste is generated) for which a
permit has been issued ..." The manifest system permits the
generator to track the waste from its site to the disposal facili-
ty to insure that none is disposed of in a way that would endanger
health or the environment. In designing its manifest system, EPA
has piggy-backed on the system already in use by the Department
of Transportation with one critical difference. The Department
of Transportation regulations do not require the return of the
manifest to the generator as confirmation that the shipment has
been delivered. Because the generator must know when and where
its waste ends up, EPA requires the disposal facility to return a
signed copy of the manifest to the generator within 30 days. By
using a largely pre-existing system and not requiring additional
forms, EPA has been able to minimize the information burden on
the public.
The need for the identification numbers ties into
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Section 3010 of the Act which states that "no identified or
listed hazardous waste subject to this subtitle may be trans-
ported, treated, stored, or disposed of unless notification has
been given as required under this subsection." The EPA identifi-
cation number, assigned after this notification has been given,
serves several purposes. First, it insures that those involved
in the hazardous waste management process are in compliance with
the law. Secondly, it assists in the identification of firms for
the purposes of tracking hazardous waste shipments through the
transportation system and to assist EPA in its enforcement efforts.
Note that the identification numbering system used by EPA will be
the Dun and Bradstreet universal numbering system with which
firms are already familiar.
Exception reporting. In order to enforce the provisions of
the law and insure that shipments were delivered as required, EPA
initially considered requiring that a copy of each manifest be
forwarded to the Agency. However, it was quickly realized that
the Agency had inadequate resources to deal with this flood of
paperwork. The Agency then considered a quarterly report covering
all manifests outstanding at the end of the quarter, but realized
that this would require reporting from many firms which may have
only recently shipped their wastes and would not be expected to
have received the confirmation of delivery from the facility.
Based on these considerations, EPA has designed an exception
reporting system to highlight only those instances where special
action on the part of the Agency might be required. EPA considers
that most hazardous wastes should be delivered within several
weeks after shipment and provides for a 30-day period for the
facility to return a confirmation copy of the manifest.
In addition, facilities are expected to report to EPA any
discrepancies in either quantity or description of hazardous
waste received which have not been resolved within 15 days. This
will permit EPA to review compliance with manifest system require-
ments and take appropriate action. Although generators do not
have to accept unmanifested waste for which a manifest is required,
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EPA permits them to do so in order to minimize the possibility
that such waste is disposed of along the roadside. EPA feels it
is important to keep informed of any such shipments received to
ensure the waste is properly handled at the facility and to
identify any patterns in the shipment of unmanifested waste for
possible enforcement action.
Annual Report. RCRA requires facilities to submit reports
to the Administrator covering facility activities during the
previous calendar year. Little is known about the generation,
transportation, and disposal of hazardous waste. In order for
EPA to both fulfill the reporting requirements established by law
and intelligently evaluate the effectiveness of its hazardous
waste management regulations, EPA needs to know what hazardous
wastes are being stored or disposed of, in what quantities, where
they are being disposed of, and what treatment or disposal
methods are being used. In addition to providing information for
planning and evaluation, periodic reporting by generators can help
in setting priorities for enforcement activities and permitting in
much the same way as the Internal Revenue Service identifies tax
returns for audit. Facility reports will indicate those firms
which are reporting much less hazardous waste than is typical for
other firms of their size in a particular industry; and can also
show up any major increases or decreases in hazardous waste gen-
eration as a potential area for investigation. Initially, EPA is
only requiring reporting on an annual basis rather than quarterly
or semi-annually. The Agency plans to fully evaluate the annual
reporting requirements after the first two such reports are
received (mid-1982) to determine whether any burden-reduction
changes in the format are appropriate and whether some kind of
sampling procedures could be instituted without affecting either
enforcement or program planning data.
Recordkeeping. The Act calls for the establishment of
"recordkeeping practices that accurately identify the quantities
of such hazardous waste generated, the constituents thereof which
-------
are significant in quantity or in potential harm to human health
or the environment, and the disposition of such wastes." In
response to the Act, EPA is requiring that facilities maintain
records concerning their receipt of hazardous wastes, verification
of the types of wastes received, where such wastes are disposed
of and what methods are being used, and how these methods are
being monitored. In addition, records of employee training in
the area of hazardous waste management and disposal are to be
kept.
In general, records p^e\taining to the receipt of manifested
wastes are required for a three-year period to provide an appro-
priate record trail to be used in the event of enforcement pro-
ceedings. EPA plans to review the three-year requirement in the
future in terms of actual program experience. Operating records
which cover what happens to the waste once it is received by the
facility are generally required to be maintained for the life of
the facility. These records will be used as the basis of peri-
odic compliance reviews by EPA. In addition, it is important in
the event of an emergency, new technical knowledge about the
nature of wastes, or the closure of a facility, to have knowledge
of what wastes are being stored, how they were disposed of, and
where. Storage and treatment facilities need not keep records
past their closure, however disposal facilities are expected to
maintain their records through the post-closure period because
the wastes remain hazardous during this time.
Planning requirements. Plans required of facilities by
Section 3004 regulations impose a significant information burden.
These costs represent a one-time expenditure with minimal annual
updating requirements. Plans are required to ensure that facili-
ties have developed adequate procedures in the areas of waste
analysis, inspection, handling emergencies, closure, post-closure
(for disposal facilities), and training. The plans are required
of facilities which have registered for interim status, but need
not be submitted at that time. Even though EPA does not have the
resources to review the adequacy of the plans at the outset, the
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Agency feels it is important for facilities to have plans in
place to cover critical areas of operations which have direct
bearing on the safety and potential environmental impact of the
facilities. Adequacy of facility plans will be review by EPA as
part of Part B of the permit granting process over the next few
i
years.
- 24 -
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CONSULTATION OUTSIDE EPA
The Environmental Protection Agency made every effort to
consult with the public and appropriate Federal agencies during
the development of the hazardous waste regulations. This effort
started in November 1976, immediately after the law was enacted
and well before the first regulations were published for comment.
On May 2, 1977, EPA published an Advance Notice of Proposed
Rulemaking (42 FR 22332) notifying the public of their intent
to develop regulations under the Resource Conservation and
Recovery Act.
Proposed regulations on standards applicable to owners and
operators of hazardous waste treatment, storage and disposal
facilities appeared for public review and comment in the Federal
Register of December 18, 1978 (43 FR 58969). The Agency sub-
sequently held 5 public hearings on these proposals. A listing
of the hearings, their dates, and the number of persons attending
follows:
LOCATION DATE No. of Attendees
New York City Feb. 7-9, 1979 307
St. Louis, Missouri Feb. 14-16, 1979 271
Denver, Colorado Mar. 7-9, 1979 no count
Washington, D. C. Feb. 22-23, 1979 195
San Francisco, Calif. Mar. 13, 1979 258
EPA received a substantial number of written comments in
addition to those received at the hearings. In all, over 1,000
comments were received pertaining to RCRA proposed regulations.
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The public comment period closed for regulations applicable to
owners and operators of facilities on March 16, 1979. Comments
received by EPA at its hearings, in consultation with other
parties and by letter were carefully considered in terms of two
criteria. First, the need to establish a hazardous waste management
program consistent with the intent of Congress and the Resourc-
Conservation and Recovery Act. Second, the need to .develop requirements
which implement the Act with a minimum burden on those affected
and the business community. As a result of comments received,
EPA has made a number of modifications to its original regulations
which reduce the reporting and recordkeeping burden imposed on
the public. These are described below in the "Consideration
of Alternatives"section.
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CONSIDERATION OF ALTERNATIVES TO REDUCE REPORTING BURDENS
The Environmental Protection Agency has attempted to
minimize reporting and recordkeeping burdens imposed on the public
by its Hazardous Waste Regulations. As part of this process,
EPA has analyzed a series of alternatives and selected approaches
to reduce private sector costs while maintaining the integrity
of the program envisaged by Congress. The major alternatives
considered by EPA are summarized below with a more detailed
listing following.
Selection of Material for Coverage'. A major part of the
compliance burden relates to the type of materials which must be
tracked and recorded from generation to ultimate disposition.
Reductions in both the types of material and small volume amounts
can reduce recordkeeping for owners or operators of hazardous
waste facilities. EPA has exempted pesticides used by farmers
from coverage under the Act provided certain criteria are met.
Other types
of waste excluded from the regulations include fly ash, sewage
sludge from publicly-owned treatment works, in-situ mining wastes,
and other types of wastes or discharges described in 40 CFR Part
261.4. In addition, small quantities of waste will be exempt
from EPA tracking system requirements. The threshold for such
small quantitites may range up to 1,000 kilograms per month and
would reduce the costs to facilities of compliance \vith manifest
system requirements.
Selection of Facilities for Coverage. EPA has given
special consideration to reducing the regulatory burden for storage,
treatment and disposal facilities handling small quantities of
hazardous waste. Threshold below which compliance with the
hazardous waste regulations are not required may range up to
1,000 kg/mo for some wastes.
- 27 -
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Eliminating Duplication with Other Federal Regulations. EPA
has eliminated duplication with other Federal laws and regulations
by exempting facilities already covered by these.
These include: industrial waste
water discharges, which are point sources subject to permits under
the Clean Water Act; special nuclear or by-product material defined
by the Atomic Energy Act. and point source air emissions regulated
under the Clean Air Act. In addition, EPA has closely coordinated
its development of hazardous waste manifest regulations with the
Department of Transportation1^ regulations on transporting hazardous-
materials .
Eliminating Duplication with State Regulation. The
Resource Conservation and Recovery Act calls for close coordination
of Federal and State regulatory programs. EPA will encourage
the authorization of States to operate their own hazardous waste
programs to eliminate any unnecessary duplication or overlap be-
tween Federal or State reouirements. States which are so authorized
will carry out the program in lieu of the Federal program and the
private sector will not be subject to two separate sets of regu-
latory requirements.
Eliminating Duplication with Normal Operating Procedures.
Although RCRA must, by law, impose new requirements, EPA has made
efforts to minimize the disruption of normal operating procedures.
An example is the manifest system for tracking waste from "cradle
to grave." The manifest was initially conceived by EPA as a
separate required form. After public consultation, EPA has agreed
to permit the use of normal manifest documents -- merely requiring
the addition of certain minimal information. Another example
is the operating record which forms the nucleus of ongoing infor-
mation and recordkeeping requirements imposed by RCRA. EPA has
made every effort to provide flexibility in these recordkeeping
requirements so that normal commercial records, including computerized
- 28 -
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information systems, may be used to satisfy regulatory requirements.
Use of Standard Identification Numbers. EPA received
several comments from the public concerning the additional burden
of ever-increasing different identification numbers used by
Federal and State agencies. To minimize this burden, EPA has
selected the Dun and Bradstreet Data Universal Numbering System
as a uniform national identification numbering system. These
numbers are already entered in business recordkeeping systems
and should facilitate compliance with EPA regulations.
Cutting Unnecessary Information Requirements. EPA has
carefully reviewed information requirements to delete any that
appear unnecessary at this time. It must be remembered, however,
that RCRA is a new Act and the number of facilities, amounts of
waste, and possible behavior of those involved in waste disposal
is as yet unknown. An example of a modification to reduce unnecessary
reporting is found in the ground-water monitoring requirement.
Initially, this was conceived as a quarterly reporting system,
but has been shifted to an annual requirement once base levels
for ground-water have been established. Another example is the
discrepancy reporting requirement. Initially, these reports
were to be provided for all discrepancies in which the manifest
description did not match what was actually received. Now,
reports are only required if the discrepancy cannot be resolved
within a 15-day period, which has both reduced the number of
potential exception reports and improved EPA's enforcement ability.
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CHANGES THE ENVIRONMENTAL PROTECTION AGENCY HAS MADE
TO DECREASE THE REPORTING AND RECORDKEEPING BURDEN
Standards Applicable to Owners and Operators of Hazardous
Waste Treatment, Storage and Disposal Facilities
1. EPA has excluded waste generated by retail estab-
lishments, and has allowed special considerations for small in-
dustrial firms, based upon the amount of waste generated. The ex-
clusion limits will be described in the final Part 261 regulations
These exclusions will reduce the paperwork burden on off-
site hazardous waste facilities, which otherwise \vould have
had to handle numerous small waste shipments.
2. The number of infectious wastes from hospitals
considered to be hazardous wastes has been reduced substan-
tially from those initially proposed. Thus, hospitals will
have a smaller manifest and recordkeeping burden and the
number of smaller shipments which must be processed by
facilities will be decreased.
3. Recordkeeping and reporting requirements were
initially designed for intermittent and batched treatment
and disposal of solid wastes at industrial waste water
treatment plants. They were inappropriate for the continuous
production of sludges and solid wastes. The final regula-
tions clarify that facilities now have the option to use
different recordkeeping systems more appropriate to their
operations. The concept of the operating log in the pro-
posed regulations has been broadened in the final regulations
so it is consistent with both an automatic data processing
system and continuous recording of unit processing operations.
4. Initially, the rules required that each manifest
be signed by the person responsible for the overall operation
of the facility, such as a plant manager or superintendent.
However, EPA no longer feels it is necessary that manifests
be signed by a person of such high rank and has changed the
proposed requirement so that the signature must be obtained
of "an owner or operator or his agent."
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5. A report on any discrepancies between the type
and quantity of hazardous waste actually received and its
description on the manifest was required to be immediately
sent to the EPA Regional Administrator. EPA has since modified
its requirements to substantially reduce the reporting burden.
For bulk shipments, any variation within plus or minus ten
percent of the manifest waste amount need not be reported.
EPA no longer requires the reporting of all discrepancies,
but only those which cannot be resolved satisfactorily with
the generator or transporter. The facility is given 15
days in which to resolve these discrepancies after which
time they must be reported to the Regional Administrator.
6. EPA has designed flexible recordkeeping require-
ments which will let facilities adapt or extend their
present recordkeeping, billing practices, operating logs,
and report to state, local, and other federal agencies in
order to meet the incremental burden of RCRA.
7. EPA originally required maintenance of an
"operating log." However, the log concept did not provide
adequate flexibility for the use of an ADP system. Further,
the large area of some facilities and the variety of the
functions they perform would make it very unlikely that all
required information would be recorded in one operating log
at only one location. EPA has changed the term "operating
log" to "operating record," which more accurately reflects
Agency intention and provides flexibility for existing commer-
cial practices.
8. In the proposed regulations, recordkeeping require-
ments were keyed to manifest information to which management
data were added. Waste descriptions required the use of
Department of Transportation shipping descriptions and
Department of Transportation hazard classes, as well as EPA
waste names and characteristics. The rules applied to both
on-site and off-site facilities, even though on-site faci-
- 31 -
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lities do not use manifests and, thus, recordkeeping based
on DOT nomenclature is not appropriate for them. To simplify
the rules and avoid confusion between on-site and off-site
facility recordkeeping requirements, EPA has decided to base
all facility recordkeeping and reporting on EPA nomenclature
for waste names and characteristics.
9. For on-site disposal, exact quantity measures of
waste would not be possible without expensive flow-meters
and weighing hoppers for which there would be no benefit
other than RCRA-required recordkeeping. For off-site dis-
posal, truck scales or other measuring devices are typically
already available. EPA recognises that where no manifest is
used Ci.e., at on-site facilities) manifest-reported quanti-
ties will be non-existent. The agency therefore is permitting
the use of estimated quantities at on-site facilities as an
alternative to manifest-reported quantities. However,
owners or operators of on-site facilities will be required
to certify the accuracy of these estimates in their annual
reports to EPA.
10. The proposed rules required that proof of compliance
with regular facility inspections should be retained as a part
of the operating log until closure of the facility. The
agency recognizes that these records are now needed primarily
for compliance reviews and the retention period has been
reduced to three years in the final rule.
11. The proposed requirement that facilities turn over
waste management and landfill disposal location records to
EPA upon closure was particularly burdensome for larger
establishments. As a result, the agency will now receive
the waste management information (waste description, quantity,
and management method) on an annual basis via the annual report
and will no longer require the owner or operator to resubmit
cumulative records of this information upon facility closure.
However, waste disposal location records must still be turned
over to EPA upon closure.
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12. The proposed rules contained separate sections for
waste managed on-site and waste managed off-site. Because
standards were similar in each section, EPA has simplified
the final rules by combining requirements for on-site and
off-site waste management in a single section.
13. The annual report was originally required within 4
weeks of the end of the reporting year. To permit facilities
more time to assemble the necessary data for the annual report,
the due date has been extended to March 1.
14. To provide greater flexibility for facility owners
or operators, EPA has changed its final rules to permit
reporting of quantities of waste in either metric units or
English units.
15. Facility owners or operators are allowed to accept
unmanifested hazardous waste. Proposed rules required that
facilities submit a quarterly report to the EPA Regional
Administrator identifying any such shipments. This require-
ment has been modified to reduce the reporting burden on
facilities. Facilities need no longer provide information
which may be impossible to collect, such as the source of
the unmanifested waste. EPA has also changed the frequency
of filing from quarterly to submission on a case-by-case
basis within 15 days of receipt of the waste.
16. The proposed regulations required that owners or
operators report fires, explosions, or releases of hazardous
waste immediately. EPA has modified this requirement to
include only such conditions when they occur outside the
facility.
17. Ground water monitoring data was initially required
to be submitted to EPA on a quarterly basis. In response to
comments received on this issue, the frequency of reporting
has been reduced to an annual basis after the first year.
18. EPA has adopted the Dun and Bradstreet Universal
Numbering System as a uniform national identifiation system.
These numbers are already entered in business recordkeeping
systems and should facilitate compliance with EPA regulations.
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TIME SCHEDULE FOR INFORMATION REQUIREMENTS
Phase I
There will be three phases to promulgating and implementing
regulations applicable to owners and operators of treatment,
storage and disposal facilities. The first phase of regulations,
expected to be published as final in April, 1980, includes the
complete package of interim status standards and most of the
final administrative and non-technical standards. Some of the
technical standards, particularly those dealing with monitoring
and closure and post-closure care, are included. The following
regulations are being promulgated in full as part of Phase I
(i.e., both interim status and general standards):
1. Purpose, scope and applicability and other general
standards.
2. Waste analysis requirements.
3. Security.
4. Inspections.
5. Training.
6. Preparedness and prevention.
7. Contingency plans and emergency procedures.
8. Manifest system, recordkeeping, and reporting.
9. Ground-water monitoring.
10. Closure and post-closure care.
In addition, the following regulations include only those
which apply during the interim status period;
1. Financial requirements.
2. Use and management of containers.
3. Tanks.
4. Surface impoundments.
5. Waste piles.
6. Land treatment.
7. Landfills.
8. Incinerators.
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These regulations under Section 3004 will become effective
in two stages. Initially, the interim status standards (40 CFR
Part 265) will apply to all facilities required to be registered
under Part 3010 of the Act until these facilities receive an
official EPA permit. Once the permit is granted, facilities
will be expected to comply with the final standards for owners
and operators of hazardous waste treatment, storage and
disposal facilities (40 CFR Part 264).
The regulations under Phase I are expected to be
published as final in April 1980. However, they will not
become effective until six months after the promulgation
of 40 CFR Part 261 dealing with the identification and listing
of hazardous waste. Under the Court Order, Section 261 must
be promulgated by the end of April 1980, thus the regulations
are expected to take force by October 1980.
Phase II
EPA believes it will take an extended period to resolve
some of the issues surrounding the more complex technical
regulations for some types of facilities. Therefore, as an
interim measure, EPA will publish by October of 1980 a set of
technical regulations which will allow permits to be processed
based on the Agency's best engineering judgement. These
regulations will contain, at a minimum, a set of factors
(e.g., temperature, distance to ground water, waste mobility,
etc.) which must be analyzed to evaluate the effect of the
facilitv on the environment. In addition, financial respon-
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sibility requirements for permitted facilities will also be
issued at this time. This will constitute Phase II of the
regulatory program for hazardous waste management facilities.
Phase III
The third phase of this regulatory program will involve
re-proposing and ultimately promulgating more definitive
technical standards, as the technical issues are resolved.
Over a period of time (estimated at 5 years), these definitive
technical standards for incinerators, landfills, etc., will
supplant the Phase II factors in the permitting program and
provide more certainty to the permitting process.
New Information Burdens
The 3-phase regulatory strategy will give maximum pro-
tection to human health and the environment without imposing
the more complex regulations before the controversial issues
surrounding them can be fully investigated. Because the stan-
dards to be promulgated under Phases II and III will provide
technical refinements in already existing requirements, no
significant new reporting requirements are anticipated. Like-
wise, the promulgation of financial requirements, many of which
are already imposed on facilities under the interim status regu-
lations, should not add major new information burdens.
36 -
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TABULATION AND PUBLICATION PLANS
The Environmental Protection Agency is developing tabulation
and publication plans for the various RCRA information requirements.
Because of the significant information requirements, EPA is focusing
ADP systems development on those activities which will be implemented
first. ADP plans are being phased in three steps, concentrating
first on the required notification process which will take place
following promulgation of the regulations, second on the permittig
process which will be initiated immediately following notification,
and thirdly on other information requirements including annual reports
received of generators, transporters, and facilities. Data collec-
ted from the annual report required by 40 CFR Parts 264 and 265
will be tabulated by computer for use by EPA in its enforcement
and internal program planning efforts. Although EPA originally
anticipated receiving information so it could track every movement
of hazardous waste, this level of detail has been sacrificed in
the interest of lessening the reporting burden on the public. The
annual report will provide EPA with an overview of facility opera-
tions and highlight problem areas, but will spare the heavy repor-
ting burden associated with the tracking of each shipment. In
addition, the tabulated data will be used to support the Agency's
annual report to Congress.
Data collected from the unminifested waste report and
discrepancy report will be used primarily by the enforcement pro-
gram staff to ensure compliance with RCRA requirements. Notifica-
tions to EPA of receipt of international shipments will be tab-
ulated to provide data on the quantity and kinds of waste being
imported for abroad. Because these reports may be few in number,
it has not yet been determined whether they need be computerized.
The agency is integrating its tabulation plans for data
collected under Parts 264 and 265 with those for the data required
by the other parts of the RCRA regulations. Thus, detailed tabula-
tion plans will not be available until April 1980 when the final
version of the remaining regulations has been agreed upon.
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SENSITIVE QUESTIONS
It is not anticipated that EPA information requirements
of owners or operators of hazardardous waste treatment, storage,
and disposal facilities will involve questions of a sensitive
nature such as sex behavior and attitudes, religious beliefs, etc.
It is anticipated that some facilities may wish to maintain the
confidentiality of certain information concerning the types of
hazardous waste they handle. This is provided for in Section
3007(b) of the Resource Conservation and Recovery Act, and is
also expressed in 40 CFR Part 2 which establishes EPA's overall
policy regarding public disclosure of information. Because it
is duplicative to state EPA's policy in every regulation pro-
mulgated under RCRA, the Agency has decided to include a regulation
concerning confidentiality of information in Part 260 of the
final rules which covers general matters applicable to all aspects
of the hazardous system. Thus, the Agency's policy is stated in
the general section of the final rules but not in the Section
3004 regulations.
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COST REDUCTIONS
EPA's Draft of Reports Impact Analysis (March 19, 1979),
estimated that the cost of reporting and recordlceeping requirements
imposed by RCRA's Section 3004 would affect 30,000 treatment,
storage and disposal facilities, and that it will amount to 2,353,000
burden hours and $73,440,000. The above analysis was limited to
the following five functions: (1) development and reporting data;
(2) monitoring reports; (3) development of systems for recordkeeping,
monitoring and reporting; (4) manifest .handling, and (5) storage
and maintenance of data.
Because 3004 regulations revised as of January 25, 1980,
identify fourteen functional areas involving recordkeeping and re-
porting, the total information costs associated with these
functional areas amount to 3.7 million hours ($61.4 million). Of
this total, 1.4 million hours ($32.2 million) are one-time costs
and 2.3 million ($29.2 million) are recurring costs.
Detailed supporting analysis of these cost estimates
follow in the remainder of this section.
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Population of Facilities Affected
Section 3004 of RCRA regulations establishes minimum national
standards which define the acceptable management of hazardous waste.
It applies to owners and operators of facilities which treat, store
and dispose of hazardous waste (HW)•
Standards spelled out in Section 3004 do not apply to
TSDF's disposing HW by means of underground injection, except in
cases when the TSDF treats and/or stores HW above ground before
underground injection.
They do not apply to HW disposal by means of ocean dumping,
except in instances when the TSDF treats and/or stores HW ashore
before it is loaded into a vessel to be disposed at sea.
Of the 969 Publicly Owned Treatment Works (POTW's), only
about 100 are covered by Section 3004 regulations, and these are
required to use manifests and report annually only.
It is estimated that only about IOC hospitals and labor-
atories, out of a total of about 7.00C will be included in the
management control system constructed under Section 3004.
Most, if not all of the 110 off-site TSDF's indentified
by the ADL study and the 5,400 TSDF's identified by WAPORA for the
Notification Process under Section 3010 are likely to come under
the system and are considered in calculations of the recordkeeping
and reporting requirements.
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Figure 1, based on Section 5004 of RCRA regulations revised as
of January 25, 1980, presents a flow chart identifying the
exclusions and exceptions to the exclusions.
ttfura I
30041 rsar't nan auxr - ttccanturmcn
baupcad [providing
26S.i(b) 1
fgiv'f "" °* K»«l'«»t *^*
Not* Minlfasc Ola-
cripaaelai
Annual laporc
•.•port UnBanllaatcd
UH1VEJISE OF *S3P'a '^
rotW* 1 '•
o
265,1
^ OCMd G
j
^
i
(b)(2)
lapeaal
£«*^*i«fi 1
Scorti and
Prior to *
poaal
1
r1" | . -i
Trtata, Storts and/ [__
or dlapoaM KU ip«l-p
ftad In 2&1.4(a)*(b) |
(MO)
26}. Kb) (I)
Olapoati HV by ito-
dcriround ln)«tloo
(cm\
n
a)(2)
Traaci
:aaa Ola-
Scorta ana Trtata riV
abova |T9und prior
ta underground to-
)KClo«
i
r"
LJ
i
(1) Any of HVI llatad In 261.13 (a) or (h)
(3) Quantity iraaiar Chan 10 k|/M ol HV llaeid undat 261.33(c)
(1) Quant Hr inaccr than 100 VI/M Hsttd uadar 261.33(d)
-------
State Programs
The January 1979 GAO report on hazardous waste management,
citing fragmentary 1977 EPA statistics, stated that:
"...although 25 (States) had provisions for a permit sys-
tem or standards requiring a permit system, only one had
a requirement that covered all parties in the waste dis-
posal chain (treats, stores and disposes)."
EPA data as recent as December 1979 suggests that as many
as ten States, with an estimated 6,700 on-site and off-site treat-
ment, storage and disposal facilities (TSDF's) had regulations
with requirements for recordkeeping, reporting, monitoring, inspec'
tion, manifest systems, operating methods, contingency plans,
training, post-closure financing and financial responsibility.
TABLE I identifies both on-site and off-site facilities
in 50 States and the District of Columbia.
State
Alabama
Alaska
Araiona
Arkansas
California
Colorado
Connecticut
Delaware
0. C.
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Caasas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Veraont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
U.S. TOTAL
Sources: EPA.
TA3L3 I
STATE HAZARDOUS -AST! PROGRAM SHE
Treatment. Storage I Ouposal facilities
Total No. On-Site Off-Site WAPORA est. of
Off ind On-Site
133
6
14
28
519
336
137
25
63
123
65
37
21
:s6
121
56
26
142
52
33
43
218
255
12S
9
189
7
63
13
34
178
9
412
55
8
291
33
55
418
49
32
12
50
199
IS
24
SO
141
35
69
1
5.423
Revised March I. 1971.
ft *» fcrnffeilBW Ilfci-lf'-'l'l*'""*****" _
Preliminary data from the Section 3010 Inventory Mof.f'.caticn
Sriten "•»«tnamgai Services Contract (WAPORA figures]
160
30
70
2,985
755
680
12S
90
415
325
US
105
1.425
60S
280
130
370
170
165
215
1.105
1.295
625
45
330
JS
31S
65
170
925
45
2.100
US
40
1,555
175
290
Z.Z4S
265
160
60
2SO
1.070
75
120
429
800
175
350
10
25.125
I2S
24
56
112
Z.338
604
544
100
72
492
260
148
84
1.140
484
224
104
296
216
132
172
884
1.036
500
36
264
28
2S2
52
136
740
36
1.680
22S
32
1.244
140
232
1,796
212
iza
48
200
856
60
96
336
640
140
SO
!
20,103
:«it Sumnarv f*i
32
6
14
28
537
151
136
25
IS
123
65
37
21
:ss
121
56
26
74
54
33
43
221
!S9
125
9
66
7
63
13
34
185
9
420
57
8
311
35
58
449
S3
32
12
50
214
15
24
84
160
35
70
2
s.o:s
*S1 . *evi
-------
TABLE II identifies TSDF's in States with regulations covering
not only the permit requirement but also the recordkeeping and
reporting requirements.
TABLE II
Stctlea 300*: Trtataaat. Stan«« and/or 01.QQ..1 7aeilltl.«
teuciftf Stat. lafulatlaa.
S.
^«.
STATZ Xy^
S« J«..y
Illlnaai
Ohio
Cillfinu
Maw Yark
Klcatgaa
TafUM.H*
North Carolina
dryland
Laulaiana
South Caraliiu
Ulacoojin
C«ac|la
Kancucky
rsor'a
On-Slt.
Ma
740
i.ltO
u:<.t
i.oao
1.036
200
!23
172
216
280
260
216
?tnlc rrocraa
T
ft.
S
0
Y.. | T..
1 T««
i
?.» T*>
T«
t.*/E
Yii/E
TM
1
1 Tt>
Y«.
Ttl/E
r«
T../E
l
1
T«*;E
T«*/C
Of f -Slta
Ha
IB)
lit
~ili
~4»
420
359
SO
57
43
i4
32
70
6i
i*
?tr«ie Prairaa
I
T.a
faa
S I °
Y«. | T»
1 "••
1
Y" 1 *"
1
1
1 1
Y.a
!
!•• T*»
l.a/E T*«/E t*a/E
1 1
l
T»/E
Y«»/E f YCB/E:
•
1
1
/////////I//////M'*
I/I
|S/*|
L | L , L
: i
i T
a'/RJ I/R. r/tj a/i|
I/R
I/R
I/R
La|»4: - !*«• Identical, •quIvaUnt, conatsttnc TCI
B/R Iraad aucharlty/Ravitv ri«« Ittlt
1 L.II than RC&A T
I/I ila .ipUcit iuchar!ty/t«v(ev rtf* S
L/I Laaa than ICtA/D.vl.w r.|l 0
: l i
I/R | |
B/R I/i, «/E|
1 a/«, a/u.
! 1 '
1 i i !
1 1 !
JB/«I
1
, I/R
9/R, SCI
1
1
1
t
S/*
J/R
II/R
l
:
J/R
1
1
1
States with oaraCc projrJB
Statil uich eacra
-------
TABLE III develops percentage figures for the universe of TSDF's
not covered by State regulations. These will be used in order to
determine the incremental cost of RCRA regulations spelled out
in Section 3004 as they affect the entire universe of TSDF's.
TABLE III
taatloa 3004: Tru
cmac. Sta»t«. tad/or Disposal /Militia
Cov«r*d by Seats tafuUcloai
Tiawcioa--".^^^ 1 Ststss by Sues rsfulacloas Covsrsd
pacardkMplaf { 10 3.
Lsportlai ' *•
taalcarlBf * ! *•
Tnsp«etion , 6 I 3-
773 U.O
830 ' 19. J
Hoc Cov«r«a
77. a
360 1 13.* . *^»
Xcalfesc Syscsa ' ' 6.33J 26. o
jdparsclaf Kscnods U a.
Coatla|«aey i 1 z-
,-ii 34.4 **.J.
'Tr>lnia, , 4 ; 4.190 • 16.; , «J.J
^est-Closurs Flitaneiag 4 3
71auclal (upensl!>lllcy 10 4
[n.s. t«t.i so » i ! 23
J33 i «-l «'•»
.30 , ZS.'
1
lac* ApproxlMt.lr 20.160 'SOf'i or 80.23 p.rctnt at th« anlvmii
of 23,123 •aOT't ««noe eev«i«d by txl*cla| Stiti risuUclaaa.
- 44 -
-------
On-Site Versus Off-Site Facilities
Data presented by the Arthur D. Little, Inc. (ADL) Study entitled Draft Economic
Impact Analysis (January 1979), in Tables VI-7 and VI-8 is summarized as follows:
TABLE IV
Hazardous Waste Disposal
Manufacturing Plants (17 industries)
Plants
No
% of
Total
Universe of plants 119,622 100.00
Plants disposing HW on-site
5,632
Plants disposing HW off-site 13,940
Plants covered by State regulations
Plants not covered by State regulations
8,862
28.96
Volume of 1
Hazardous Waste !
Millions of
tons (metric)
21.27
16.85
71.04 ; 4.42
45.16 .
10,760 -54.84
% of |
Total j
100.00
79.20'
20.80
-
—
The TRW study entitled, Technical Environment^. Impacts(December 10, 1979),
p. 3-14, states that the percentage of the small generators (manufacturing) using
on-site disposal and the percentage of the waste handled at on-site facilities is
22.1 percent and 22.6 percent each. There are 83,183 generators of HW in the manu-
facturirg industries with a monthly output of HW in excess of 100 kg. Of these,
49,805 are small facilities generating less than 5,000 kg of HW per month and
33,378 generators in the above 5,000 kg/mo range of HW output.
3y applying the on-site disposal percentages of 22.1 percent for small
generators and 28.96 percent for large generators to the universes of 49,805 and
33,183 generators respectively, we arrive at a total of 20,673 generators disposing
their HW on-site. This figure approximates the 20,100 generators disposing on-site,
identified in the EPA study entitled, Resource Requirement Summary (RRS), revised
March 1, 1979.
Note: Although chemical plants constituted only 12.5 percent (2,458 facilities) of
the universe of 19,622 plants analyzed by ADL, they accounted for 28.3 percent of HW dis-
posed either on- or off-site. Specifically, on-site disposal was practiced by
1,072 plants involving approximately 5 million tons of HW, and 1,386 plants shipped
about 1 million tons of HW to off-site facilities.
- 45 -
-------
Program Reporting and Recordkeeping Costs
A review of the existing estimates of both on-site and
off-site TSDF's concluded that there are about 26,400 such faci-
lities that may be affected by RCRA's Section 3004 regulations.
Using ADL unit costs developed for 17 industries, we have construe
ted TABLE V which develops estimates of costs and also takes into
consideration reductions affected by existing State regulations.
- 46 -
-------
TABLE V
Section 3004: Treatment, Storage and Disposal Facilities (TSOF's)
Recordkeeping and Reporting Requirements
..,,-lro-n,,
Foielon 4M|»«nlt Report
Nodllctllun of Be- Omen
Vfatle Antlyl It f Itn
Intprciloti Schedule
It ainlng Record
Conl Ingency Pljn
IWBI yencr Reporl
(Unlfetl
""Handling
2 nitcrepincy Report
— 1 — UnMMFMtia Bltlt
Queriilng Record
1 Quantity. NMtgewnl
A lucilloji Method
I Ujtte/Anelrtlt/lilalt
1 fMMjfniy Record
4 Monitoring D«lt
4 Cloture/Pnit
Clotuic teporlt
6 Impeillon log
\imuil Rcpurt
1 Rttlc Inroilllqn
1 Hun II or Ing Data
1 Clotiire/l'ail-
Cloiuie Repoiit
Ciound Utter Muni lor Ing
j S j an 1 log/Ana lytli Plio
2 Monitoring Outline
1 Nnnllarlng Pltn
4 Ground Uiler Aittiiaenl
Clolure PUn
1 Pltn
2 Certification
) Sl(b)
(11(2)
(bill)
(b|(6|
Stile
Col (7) /rnuliewnii
(8) i <«l
1 400
568'
611.6001
IJ1*4«\
MIAMI
_MJ2J1.02S_
JSLfiS
100 0'.
loo o:
84 ii
81 P.
92 o;
1.894.116' 74 01
194.704*
— iror
11.141.627
129.022
164 .511
100 01
"16661
64 IT
-
65 21
64 21
r.65«.77f | 65 2!
lot. 511
940.400
4.250.400
^619.201)
202.40(1
1.705.846
1.705. 846
2.214.461
1.704.846
5.971.94)
19.981
19.381
19.00)
151,747
7.49C
15.606
JW U6 787
—aciJ-jsrAras
65 21
84 61
80 71
80 71
80 7!
8)31
8) »
8) 11
81 11
61.11
81 11
81 It
81 II
81 It
100 01
ion o:
^ ^--,,
loltl turden Reduced by
Sltle Rrqulremilt
Itoori " OolllrT '
Col (61 • Col (») Ci-l (8) • Col (91
(Ml
SO
H.J20
67. OU)
81.945
178.417
160.208
24.118
MM
996.142
M.476
17.71)
161.469
17.71)
100. MS
271.700
01 219
10.657
65. 9M
64.974
87.964
65.974
1)5.614
1.S4I
1.541
1.S4I
11.668
9)1
1..48
^V'g.j'j.
(M)
1 400
468
611.600
1.518.967
701.118
18,617.441
2.881.661
194.704
19.472
11.764,140
475.127
217.661
4.990.887
2)7.661
804.0)8
1.4B.OI1
I.W.H4
16).))!
1.470.970
1.470.970
1.B94.676
1.120.970
4.844,668
11.696
11.696
11.696
784.757
7.496
14.606
16L.417JI5D.
Inlllil «l. Annul 1 Burden
Hour i
1 nit It)
117)
...
...
14,120
67.001
...
776,417
...
...
...
...
...
—
...
...
...
...
...
6S.*M
6S.974
87.965
6S.974
1)4.614
1.541
I.MI
1.511
11.868
917
1.74.
Annul
ID)
SO
M
...
...
8J.965
671
MO. 206
24.118
7.414
998,142
14.476
11.21)
161,469
17.711
100.405
771. TOO
•«.7I»
10.647
...
...
...
...
...
...
...
...
...
...
—
JJMJU- LJM.JZu
ft
Inll'tl
no
1
...
611,600
I.5IB.06?
...
18,612.441
—
.. •
...
—
...
...
...
...
...
...
...
1.470.9/0
1.470.970
1.894.626
1.470.970
4.844.1«a
11.696
11.696
11.696
284.761
7,496
14.606
iujiQ.au
"Innut)
(151
I 400
546
...
...
701.718
16.151
7.881.661
194.704
1). 184. 140
475.112
4.990.8W
717.661
804.018
1.410.071
I.H1.!»"
161.117
...
...
...
...
...
...
...
...
...
...
us.Uo.aai
"*
Milt IOIAIS MAI Hfll ACRII Nil 10 RailllJlHG
-------
Footnotes for Table V
I/ Assumes that approximately 100 shipments of hazardous waste will enter
~~ this country from abroad annually.
2/ Assumes that 2.5 percent of all TSDF's will change ownership annually.
y Assumes that approximately 10 percent of the universe of 26,400 TSDF's
will have a waste analysis plan.
4_/ Assumes that there will be 225 emergencies requiring a report to the
' Regional Administrator.
5/ to 7/ TRW/EPA estimates that the 66,845 generators with hazardous
waste output of more than 1,000 kg/mo will fill out 1,947,068 manifests.
Projection of these ficures on the universe of 5,700 off-site TSDF's
suggest a manifest handling task of about 342 manifests per Tacility.
It is estimated that discrepancies may occur in 5 percent (97,353) of
the manifests and that 0.5 percent (9,735) of shipments may not be
manifested.
8/ Certification, Survey Plat/Records, and Deed Notice requirements affect
disposal facilities only.
9/ TRW estimates that about 7.1 percent of the hazardous waste is land-
spread.
- 43 -
-------
EVALUATION PLAN
Our evaluation plan for the paperwork involved in adminis-
tering the RCRA program is being designed to address uncertainties
and take advantage of experiences over the next two years. At
that time, we will be fully prepared to seek appropriate modi-
fications to these clearance requests. Indeed, we may seek some
modifications in advance of the two years because we will be
making evaluations of the program on a continuing basis, with each
step being taken as soon as we have the necessary information to
make an informed judgement.
There are several reasons why an evaluation plan is important
to the RCRA program. First, it is a new program so that our
plans and assumptions about how well the various parts of the
program will work and interact will be evaluated on the basis of
experience. For example, we have not specified the nature or
form of records required for materials testing. In the future,
we may find such stipulations necessary. Second, there are many
uncertainties about the number of people involved and burden es-
timates. Third, we can expect still further legislative develop-
ments (see Appendix II) which will affect how the RCRA program
should be run.
The evaluation plan for the RCRA regulatory segments is
currently under design. Their evaluation will be completed in
five years or as required by E.G. 12044. The paperwork require-
ments will be evaluated within two years as required by E.G. 12174,
and then reevaluated as part of the total program of the five
ye'ar work.
The evaluation plan will have a series of steps, each to
be taken as soon as the facts are available to make an informal
judgement on whether any changes are necessary. The results of
the evaluations completed during each year will be included in
the annual report to the Congress and the President on the RCRA
program.
- 49 -
-------
Included in the evaluation plan will be the following:
1. Extent to which the annual report of facilities may
be cut by using a sample. Once a file exists of what
hazardous wastes each facility handles annual changes
in quantity may be needed on a statistical basis only.
2. Item by item analysis of the practical utility for
each data element on the annual report.
3. The desirability of the exemptions and thresholds for
chemicals and waste facilities in reducing burden
while covering major hazardous waste problems.
4. The appropriateness of three-year record retention
requirements in view of needs to support inspection and
enforcement activities.
6. The use of the manifest discrepancy report and whether
its contribution to the enforcement program warrants
the burden it places on the public.
7. The use of the unmanifested waste report in view of how
frequently is it submitted and whether it contributes
to the enforcement program or knowledge about the move-
ment of unmanifested waste.
8. The need for informing EPA about international shipments
in view of the information this contributes about the
importation of waste.
9. Requirements for items to be included in plans required
of facilities should be reviewed as these plans are
submitted as part of the Permitting process.
10. The RCRA program and its paperwork requirements should
be reexamined in light of new and related legislated
programs and the impact of State-run hazardous waste
programs.
11. The need for each type of operating record required
to be maintained during the life and post-closure
period of the facility should be reviewed in terms of
use and need.
- 50 -
-------
RCRA FORM BEING SUBMITTED FOR CLEARANCE
- 51 -
-------
ase onnt or type *itfi ELITE type ttiefiaracnn per >nenl.
OS4 Ha. !2345-XX
farm Aoom*ta OM3
ISS *00xx
U.A. CMVIROMMCNTAb *I»OTCCTION
HAZARDOUS WASTE REPORT
TYPE A BENERATOR - OFF-SITE SHIPMC.N TS ONV.Y
THIS
is ro» TMC
CNOINS occ.n.
TYPE 3:JANNUALfFACH.ITY/REPORT
PLEASE PLACE LABEL IN THIS SPACE
THIS HCPORT IS POM THC YCAN CNOINC OCC. 11.1
TTPS C. UNMANIFEST63 WASTS REPORT
TMH REPORT is ran AI
flltt do, mo nth. A yearil
iSTHUCTICNS. -You may nave received * orcenntto laoei anacnee te in* from of tnu aamonlet: »«i» it in tnt dnignatea IHO; aoove—i«rt. If any at we
formation on me l*o*l it incorrect, enm * dnc tnreuqn n ana tueoiy :nc correct information in tnt •ooroonate MCtion 3*iTKt. leave Scetioni II. 111. ana IV beiow blank. If you Old not receive a areormtea laoei. eomolett ill saeuont. "InsaiUtion" meant t ungie sue wnere
ixaroou* wane it genaraiM. created, norca war ditooteo o( ?leai* refer to tne loceifie inttructioni lor generator! or faeifitiet before comoieting tan
urn. The information reouened herein n reeuireo Sv law ISeaion 3002/300* af a»t ftaoum Cansrrvaoofl *n<3 Htcartry Aetl.
1 1
1 I
I rrri
I
I
1 1
t
1
1
1
/. INSTALLATION MAILING AOORE55
»T»etT OR f O BOX
LOCATION OF INSTALLATION
- 1
il I
I
1
CIT
T C
IK
TO
WH
S
T.
ZIP
t
CODE
1
NAMC OoMt on* ftitrj
1
1
PMOMC NO. tana eoa*
H
H
4 no.i
\ \
/!(. TRANSPORTATION SEflVtCES USED //of Typg A noons only!.
Un me £?A laentif ication Numoert for tnose iranioorten ««nase icrvieei
uteo Ourin; Tie reoortm) year regreieniea 3v :nis reeon.
/ ctmry under pena/ry of />•* ffnt I tare penanaily etmntmed m€ am familiar men Tre information suOmitsed in Oia amt til tntentd aocumeaa. tna . .
aoe0 an my mouiry of oloa i/io*ividkiju immediately maonna/e for oUaimng srte informtoan. I batten cnar trie ajomirno' mformioon a me. xx-jrtn.
tna came/ere. / am jmre 9iJf aiere tre agmreant pe/ta/oet for siomirtuig .'atw mfamtaoon. including o>e ooaitHliry of fine and im0/uonmeni
A. PfllHT OR TT*C NAME
C. OATt SICMCO
Form 3700-13 12-80)
PACE.
.OF
- 52 -
-------
orinT or rvoe win SLITS rvoe ' J 2 c.iaraetsn atr mcnl
GSA No. 1224S-XX
Fttrm Aooroved OMB Ho JS3-3QOXX
SEPA
U 3. ENVIRONMENTAL PROTECTION ACCNCY
HAZARDOUS WASTE REPORT (Pan 81
FOR
USE ONLY
f/trifu / «td 21
1. OATT
•^••^^^•••OM
ICIIVED4
t. TYPC OP VCXMIT
IX. FAOLITY-S EPA I.O. NO.
FL
EPA I O.
Cc
OH AOQHESS Ittrtft ar ? C.
tv, irate. 81
XI. GENERATOR NAME fsOKifvl.
XIII. WASTE IDENTIFICATION
e
1
:
3
a
5
6
8
9
10
11
12
A. WASTE DESCRIPTION
I. DESCRIPTION OF WASTE
X. (PA
HAZARDOUS
WAST!
NUMBER
(at trumienoful
1
1 ' •
•
— '
. . .
1 ' ' 1 ' ' '
' *
' •
-' ' '
i 1
. . . • | - • -
- ' '
!• - 11
1 * ' .
• ' ' '
8.
HANO*
UING
METHOD
ftnttr
codti
c.
AMOUNT
OF WASTE
»• • *• * •• • *l 1 i« -•»••• - '•
1IINIT Of
MITASIIIIC P
|. iifi-l ttillf)
J'
i
1
1
. t
i
i— n
INITIAb.3 OF CERTIFr-
EPA rarm 3700-133 13-301
PAGE
.OF
- S3 -
-------
FOR INTERNAL USE ONLY Draft
3/14/80
GENERAL INSTRUCTIONS
HAZARDOUS WASTE REPORT
IMPORTANT; READ ALL INSTRUCTIONS BEFORE COMPLETING THIS FORM
Section TYPE OF HAZARDOUS WASTE REPORT:
I.
Type A. Genera-tor - Off-site Shipments Only
CSee Part 262 of this Chapter for instructions.]
Type B; Facility Annual Report
For owners or operators cf on-site or off-
site facilities that treat:, store, or dispose
of hazardous waste; fill in the four Soxes
with the reporting year for this report
(e.g., 1984).
Type C; Unmanifested Waste Report
For facility owners or operators who accept
for treatment, storage, or disposal any hazard-
ous waste from an off-site source without an
accompanying manifest; fill in the date the
waste was received at the facility (e.g., 06-
14-1984).
Section INSTALLATION I.D. NUMBER, NAME OF INSTALLATION,
II.
thru INSTALLATION MAILING ADDRESS, LOCATION OF INSTAL-
Section
VI. LATION AND INSTALLATION CONTACT:
If you received a preprinted label from SPA,
attach it in the space provided and leave
Sections II through VI blank. If there is an
error or omission on the label, cross out the
- 34 -
-------
FOR INTERNAL USE ONLY Draft
3/14/80
incorrect information and fill in the appro-
priate item(s). If you did not receive a
preprinted label, complete Sections II tnrough
VI.
Section TRANSPORTATION SERVICES USED (For Type-A, Reports Only)
CSee Part 262 of this Chapter for instructions.]
VII.
Section CERTIFICATION
The owner or operator of the facility or his
authorized representative must review the
report, read the certification, and sign and
date the certification where indicated. The
printed or typed name of the owner or operator
or his authorized representative must also
be included where indicated.
NOTE: Since more than one page is required for each report,
indicate the number of each sheet in the lower right
corner where indicated and indicate the total number
of pages.
TYPE-A REPORT
[See Part 262 of this Chapter for instructions.]
TYPS-3 REPORT
INSTRUCTIONS
Facility Annual Report for owners or operators of on-site or
off-site facilities that treat, store, or dispose of hazardous
waste. Use EPA For^is 3700-13 and 8700-133.
IMPORTANT: READ ALL INSTRUCTIONS BEFORE COMPLETING THIS FORM.
- 55 -
-------
FOR INTERNAL USE ONLY Draft
3/14/80
Section FACILITY'S SPA IDENTIFICATION NUMBER
IX.
Enter the EPA identification number for your
facility.
[Comment; The EPA identification number requested here for
private, municipal, and State-owned facilities is the Data
Universal Numbering System (DUNS) Numbe-- developed by Dunn
and Bradstreet, Inc. Most business establishments in the
United States have already been assigned DUNS numbers, includ-
ing all types and sizes of business establishments, branches,
factories, distribution centers, and purchasing units. State
and municipal facilities, including publicly-owned treatment
works, have also been assigned DUNS numbers.
All facilities engaged in the generation, transport, or
treatment, storage, or disposal of hazardous waste will be
assigned an E?A identification number under the authority of
Section 3010 of RCRA as part of the Hazardous Waste
Notification program.
If you need an EPA identification number for your facility,
call the nearest EPA regional office.
For Federal facilities, the General Services Administration
(G5A) real property number should be used. All Federal facili-
ties have already been assigned a real property number by C-SA.
If you don't know your nunber, call the nearest local office of
GSA.
Fill in the number as follows:
o STATE CODE - In the first two positions of the number
insert the U.S. Postal Service Stats Ccr.e for the
- 56 -
-------
FOR INTERNAL USE ONLY Draft
3/14/80
appropriate Stats or territory in which the facility
is located, such as PA, MD, NJ, NY, or MA;
o DUHS or GSA Identifier and Number - In the remaining
positions aftar the State code insert a "D" for a
private, municipal, or Stats-owned facility followed
by the nine-digit DUNS number; OR insert a "G" for
a Federally-owned facility followed by the GSA
number .
EXAMPLES
1. Private facility _ PAD784621383 in Pennsylvania.
2. Federal facility IT"^ 843 70 155 in New Yor
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FOR INTERNAL USE ONLY
Draft
3/14/80
Section
XI.
Section
XII.
Section
XIII.
GENERATOR'S NAME
Enter the name of the generator corresponding
to the generator's EPA identification number
in Section X. Co not use colloquial names as
a substitute for the generator's official r.ane.
If the waste was generated and treated,
stored, or disposed of at the same installation,
enter "ON-SITE."
If the waste came from a foreign generator,
enter the name of the importer corresponding
to the EPA identification number in Section X.
GENERATOR'S ADDRESS
Enter the address of the generator corresponding
to the generator's S?A identification number in
Section X. If the waste was generated and
treatad, stored, or disposed of at the same
installation, leave this section blank. If the
waste came from a foreign generator, en-ter the
address of the importer corresponding to the SPA
identification number in Section X.
WASTE IDENTIFICATION
All information in this section must be entered
by line number. Each line entry must describe
a different waste or different amounts of the
same waste which wera in a different status at
the end of the reporting year.
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FOR INTERNAL USE ONLY Draft
3/14/80
Section WASTE DESCRIPTION: DESCRIPTION OF WASTE
XIII-A-1
On each line, enter a description of each
different waste, from the generator identified
in Sections X-XII. that your facility received
during the reporting year. Use a separate line
to describe different amounts of the same waste
which were in a different status at the end of
the reporting year.
For hazardous wastes that are listed
under Part 261, Subpart D, of this Chapter,
enter the listed name, abbreviated if necessary.
Where mixtures of listed wastes were received,
enter the listed name of the principal component
of the mixture. For unlisted hazardous waste
identified under Part 261, Subpart C, of this
Chapter, describe each waste or waste mixture
by the common name of the waste: the exact
chemical or generic chemical name of the
waste, if known; and the specific manufacturing
or other process generating the waste.
Section WASTE DESCRIPTION: EPA HAZARDOUS WASTE NUMBER
XIII-A-2
For each line, for listed waste, enter the
four-'iigit EPA Hazardous Waste dumber from
Table 1* which identifies the waste.
For a mixture of more than one listed waste,
enter the principal EPA Hazardous Waste dumber
- 59 -
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FOR INTERNAL USE ONLY Draft
3/14/80
in the upper left hand corner, and up to three
other applicable SPA Hazardous Wasta lumbers in
the remaining spaces.
For unlisted wastes, and for mixtures of
listed and unlisted wastes, enter the principal
EPA Hazardous Wasta Sunber from Table 2* appli-
cable to the waste in the upper left hand corner,
and up to three other applicable SPA Hazardous
Waste Numbers in the remaining spaces.
If a waste PCS or PCS Item meets the des-
cription of any other hazardous waste (e.g.,
used engine oils contaminated with more than
50 ppra PC3), enter the SPA Hazardous Waste
Number for the PC3 or PCS Item.
(*Tables 1 and 2 will be included in these
instructions at the time Part 261 of this
chapter is promulgated.)
Section HANDLING METHOD
XIII-3
Enter one SPA handling code for each waste line
entry, EPA handling codes are given in
Appendix I of this Part. Report only the
handling code representing the waste's status
at the end of the reporting year.
Section AMOUNT OF WASTE
XIII-C
For each line, enter the total amount of that
waste received by your facility during the
reporting year corresponding to the unit -sf
- 60 -
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?OR INTERNAL USE ONLY Draft
3/14/80
measure chosen for reporting in Section XIII-D.
if more than 999,999,999 units of the waste
are reported, enter 999,999,999 in the boxes,
and report the line number and the correct
amount with the unit of measure in Section
XlV-Ccmntents.
Section UNIT OF MEASURE
XIII-0
Enter the unit of measure code for the amount
of the waste described on each line. Unit of
measures which must be used in this report and
the corresponding codes are:
Unit of Measure Code
Pound P
Short Ton (2000 las) T
Kilogram X
Tonne (1000 kg) M
Units of volume may not be used for reporting
but must be converted into one of the above
units of weight, taking into account the
appropriate density or specific gravity of the
waste.
Section COMMENTS
XIV
Enter the most recent closure cost estimate under
§265.141, and for disposal facilities, the most
recent post-closure cost estimate under §265.143.
This space may also be used with a cross reference
to the appropriate Section number to explain
or clarify any an-ry.
- 61 -
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FOR INTERNAL USE ONLY Dra.ft
3/14/30
CERTIFYING OFFICIAL INITIALS AND PAGE COUNT
The responsible official certifying the cover
sheet must initial each attachment:. Each
attached sheet must be numbered as the second
of two, the second or the third of thrse, and
so on, so that all sheets are sequentially
identified.
MONITORING DATA
Where required, attach to this report ground-
water monitoring data under §255 .94(b) ( 2) and
TYPE-C REPORT
INSTRUCTIONS
Unnanif ssted Waste Report for facility owners or operators who
accept for treatment, storage, or disposal any hazardous waste
frcm an off -site source without an accompanying manifest . Use
EPA Fornis 8700-13 and 3700-133.
IMPORTANT; READ ALL INSTRUCTIONS BEFORE COMPLETING THIS FORM.
For the Unmanifested Waste Report, SPA Form 8700-133
must be filled our according to the diractions for the Type-3
Facility Annual Report except, that: (!) blocks for which
information is not available to the owner or operator of the
reporting facility may be marked "UNKNOWN, " and (2) the follow-
ing special instructions apply:
Section XIII-A-1 DESCRIPTION OF MASTS
Use as many line numbers as are needed to
describe the waste.
- 62 -
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FOR INTERNAL USE ONLY Dliaf ~
3/14/30
Section X11I-B HANDLING METHOD
Enter the handling code which describes
the status of the waste on the date the
report is filed.
Section XIII-C AMOUNT OF WASTE
Enter the amount of waste received, rather
than a total annual aggregate.
Section XIV COMMENTS
a. Enter the SPA Identification number,
name, and address of the transporter,
if known. If the transporter is not
known to you, enter the name and chauf-
feur license number of the driver
and the State and license number of
the transporting vehicle which
presented the waste to your facility,
if ?
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APPENDIX I
Resource Conservation and Recovery Act of 1976
(Public Law 9^-530)
Parts Relating to Generators and Transporters of Hazardous Wastes
Congressional Findings
Section 1002. (a) Solid Waste - The Congress finds with respect to
solid waste -•
(1) that the continuing technological progress and improve-
ment in methods of manufacture, packaging, and marketing of
consuaer products has resulted in an ever-mounting increase, and
in a change in the characteristics, of the mass material discarded
by the purchaser of such products;
(2) that the economic and population growth of our Nation,
and the improvements in the standard of living enjoyed by our
peculation, have required increased industrial production to meet
our needs, and have made necessary the demolition of old build-
ings, the construction of new buildings, and the provision of high-
ways and other avenues of transportation, which, together with
related industrial, commercial, and agricultural operations, have
resulted in a rising tide of scrap, discarded, and waste materials;
(3) that the continuing concentration of our population in
expanding metropolitan and other urban areas has presented these
communities with serious financial, management, intergovern-
mental, and technical problems in the disposal of solid wastes
resulting from the industrial, commercial, domestic, and other
activities carried en in such areas;
(U) that while the collection and disposal of solid wastes
should continue to be primarily the function of State, regional,
and local agencies, the problems of waste disposal as set forth
above have become a matter national in scope and in concern and
necessitate Federal action through financial and technical assist-
ance and leadership in the development, demonstration, and appli-
cation of new and improved methods and processes to reduce the
proper and economical solid-waste disposal practices.
(b) Environment and Health - The Congress finds with respect to the
environment and health, that -
(1) although land is too valuable a national resource to be
needlessly polluted by discarded materials, most solid waste is dis-
posed of on land in open dumps and sanitary landfills;
(2) disposal of solid waste and hazardous waste ir. or or. the
land without careful planning and management can present a
danger to human health and the environment;
(3) as a result of the Clean Air Act, the Water Pollution Con-
trol Act, and other Federal and State laws respecting public
health and the environment, greater amcur.ts of solid waste (in
the form of sludge and other pollution treatment residues) have
been created. Similarly, inadequate ar.d environmentally unsound.
-------
practices for the disposal or use of solid waste have created greater
amounts of air and vater pollution and other problems for the
environnent and for health;
(U) open dumping is particularly haraful to health, contami-
nates drinking vater from underground and surface supplies, and
pollutes the air and the land;
(5) hazardous vaste presents, in addition to the problems asso-
ciated with non-hazardous solid waste, special dangers to health
and requires a greater degree of regulation than does non-hazard-
ous solid waste;
Objectives
Section 1003. The objectives of this Act are to promote the protection
of health and the environment and to conserve valuable material and energy
resources by -
(3) prohibiting future open dumping on the iand and requir-
ing the" conversion of existing open dumps to facilities which do
not pose a danger to the environment or to health;
(U) regulating the treatment, storage, transportation, and dis-
posal of hazardous wastes which have adverse effects on health
and the environment;
(5) providing for the promulgation of guidelines for solid
waste collection, transport, separation, recovery, and disposal
practices and systems;
SU3?IT1Z C - rIAZ.AP.2CUS VAST! MAJIAGg-SiT
Identification and listing of Hazardous waste
Section 3001. (a) Criteria for identification or listing - Not later
than eighteen months after the date of the enactment of this Act, the
Administrator shall, after notice and opportunity for public nearing,
and after consultation with appropriate Federal and State agencies,
develop and Dromulgate criteria for identifying the characteristics of
hazardous waste, and for listing hazardous waste, wnich should be subject
to the provisions of this subtitle, taking into account toxicity, persistence,
and degradability in nature, potential for accumulation in tissue, and other
related factors such as flammability , ccrrosiveness , and other hazardous
characteristics. Such criteris shall be revised from time to time as may
be appropriate.
(b) Identification and listing - Not later thar. eighteen months
after the date of enactment of this section, and after notice and opportunity
for Dublic hearing, the Administrator shall promulgate regulations
identifying the characteristics of hazardous waste, and listing particular
hazardous wastes (within the meaning of section 100U(5)), which shall be
subject to the provisions of this subtitle. Such regulations shall be based
on the criteria" promulgated under subsection (a) and shall be revised from time
to time thereafter as may be appropriate.
(c) Petition by State Governor - At any time after the date eighteen
months after the enactment of this title, the Governor of any State may
petition the Administrator to identify or list a material as a hazardous
Appdx I -2
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waste. The Administrator shall act upon such petition vithin ninety days
following his receipt thereof and shall notify the Governor of such action.
If the Administrator denies such petition because of financial considerations,
in providing such notice to the Governor he shall include a statement
concerning such considerations.
Standards Applicable to Ovners and Operators cf Hazardous Waste Treatment,
Storage and Disposal Facilities
Section 300^. Not later than eighteen months after the date of enact-
ment of this section, and after opportunity for public hearings and after
consultation with appropriate Federal and State agencies, the Administrator
shall promulgate regulations establishing such performance standards, applicable
to owners and operators of facilities for the treatment, storage, or disposal
of hazardous vaste identified or listed under this subtitle, as may be necessary
to protect human health and the environment. Such standards shall include:
(1) maintaining records of all hazardous wastes identified or
listed under this title which is treated, stored, or disposed of,
as the case say be, and the manner in vr.ich such wastes were treated,
stored, or disposed of;
(2) satisfactory reporting, monitoring, and inspection and
compliance with the manifest system referred to in section 3002(5);
(3) treatment, storage, or disposal of all such waste received
by the facility pursuant to such operating methods, techniques,
and practices as nay be satisfactory ta the Administrator;
(U) the location, design, and construction of such hazardous
waste treatment, disposal, or storage facilities;
(5) contingency plans for effective action to minimize unan-
ticipated damage from any treatment, storage, or disposal of any
such hazardous waste;
(6) the maintenance of operation of such facilities and requir-
irgsuch additional qualifications as to ownership, continuity of
operation, training "for personnel, and financial responsibility as
may be necessary or desirable; and
(7) compliance with the requirements of section 3005 respect-
ing permits for treatment, storage, or disposal.
Mo private entity shall be precluded by rsascn of criteria established
under paragraph (6) from the ownership or operation of facilities providing
hazardous waste treatment, storage or disposal services where such entity
can provide assurances of financial responsibility and continuity of oper-
ation consistent with the degree and duration of risks associated with
the treatment, storage, or disposal of specified hazardous waste.
Appdx 1-3
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APPENDIX II
Partial Listing of Pending Legislation Affecting Hazardous Waste
Senate
S. 1325 - Hazardous Waste Post-Closure Liability Ac- (ia Senate
Environment and Public Works Committee - last hearing
held September 28, 1979, more scheduled soon)
S. 131*! - Oil, Hazardous Substance and Hazardous Waste Response
Liability and Compensation Act (in Senate Environment
and Public Works Committee - last hearing held September
28, 1979. acre scheduled soon)
S. 1-SO - Environmental Emergency Response Act (in Senate
Environment and Public Works Committee - last hearing
held September 28, 1979, nore scheduled soon)
S. 1156 - Solid Waste Disposal Act Amendments (passed the Senate on
June !*, 1979; Senate reauested a conference on March ^,
1980, the House responded on MArch 10 but conferees have
not yet met)
House
HH 3991* - Resource Conservation and Recovery Act Amendments (passed
the House on February 20, I960 and vas laid aside in favc:
of S. 1156)
HR 5790 - Hazardous Waste Response 7und Act (Super ~-^r.d) (in
House Interstate and Foreign Commerce Cccmittee, hearings
scheduled soon)
-------
APPENDIX III
Bibliography
I. Federal Sources
A. United States Departae.it of Transportation
"Display of Hazardous Materials Identification Nunbers; Improved
Emergency Response Capability; Proposed Rule," in Federal Register,
Vol. lik, Ho. ill, June 7, 1979= 32972 - 33019, Part IV
Eighth Annual Report en Hazardous Materials Transport at i or., Materials
Transportation Bureau, Washington, D. C., CY 1977
Guide for Hazardous Materials Shipping Pagers , Materials Transpor-
tation Bureau, 1979 (DMT-^3)
Guide for Preparing Hazardous Materials Incident Reports. Materials
Transportation Bureau, January, 1979 (revised
Hazardous Materials Transrortaticr. - Guide for Brokers, "orvardlng
Agents, Freight Forwarders and Warehouseaen, Materials Transportation
Bureau, May 1978
Hazardous Material Transportation - Hazardous Materials -ef ir.itions,
Materials Transportation Bureau, January 1979 (DMT-^3)
Hazardous Materials Transportation - Marking Guide. Materials
Transportation Bureau, May 1973.
Hazardous Materials Warning labels, Materials Transportation Bureau,
1977 (Chart k)
Hazardous Materials Warning Placards. Materials Transport at icr. Bureau,
1977 (Chart 5)
"Improved Descriptions of Hazardous Materials for laergency Response.
(Notice of Proposed Ruleaaking)," Docket No. HM-1265; Notice 79-1^,
in Federal Register. Vol. kk, No. 213, November 8, 1979
Proposal to Require Display of Hazardous Materials Identification
Hunbers, Materials Transportation Bureau (EM-126A)
"Transportation of Hazardous Substances," in Federal Register. Vol.
kk, no". 37, February 22, 1979= 1C676 - 10695, Part IV
-------
3. United States Environmental Protection Agency
1. Federal Register
"Consolidated Permit Regulations: RCRA Hazardous Waste:
SDWA Underground Injection Control; CAA Prevention..."
in Federal Register, Vol. l»lt, No. 116, June lU, 1979:
- 31*31*11, Section 3005
.,
"Criteria for Classification of Solid Waste Disposal
Facilities and Practices; Final, Interim Final, and
Proposed Regulations (as corrected in the FR of September
21, 1979)," in Federal Register, Vol. Ui* , No. 179,
September 13, 1979^ 53^30 - 53^63
"Hazardous Waste Guidelines and Regulations," in Federal
Register, Vol. UU, No. 16U, August 22, 1979: Il91*02 -
, Part II
"Hazardous Waste: Proposed Guidelines and Regulations and
Proposal on Identification and Listing," in Federal Register.
Vol". 73, No. 2l»3, December 13, 197S: 539^6 - 59023
"Identification of Regions and Agencies for Solid Waste
Management, " in Federal Register. Vol. 1*2, No. 91* , -May la,
19777 9U926 - 2U930, Part V
"Implementation of the Resource Conservation and Recovery
Act" of 1976: Interim Regulations," in Federal Register.
Vol i*2, No. 203, October 20, 1977: 56050 - 56056, Part 17
"Preliminary Notification of Hazardous Waste Activities:
Pro-nosed Procedures," in Federal Register, Vol. -3, No. 133,
July 11, 1973: 29908 - 29916, Part IV
"Standards Aurlicable to Transporters of Hazardous Wastes,"
in Federal Register, Vol. 1*3," No. 33, April 28, 1973:
13506 - 13512, Part IV
Appdx III -2
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2. Other EPA Studies
Controlling Wastes for Public Safety and Resource Censer-
vat ion, May, 1979, OPA ok/9, SW-799
Developing a State Resource Conservation and Recovery Program,
Office of Water and Waste Management, October, 1979, 5W-79I
Environmental Information: Hazardous Waste Facts, Office of
Public Awareness, Maryca, 1979, OPA 57/9
A Guide to the Consolidated Application Fora, Office of Water
Enforcement, June, 1979, C-7
A Guide to the Dredge or Fill Permit Program, Office of
Wastes Planning and Standards, July, 1979, C-6
Hazardous Waste: A Guide for Obtaining Permits and Authori-
zation for State Programs, Office of Water and Waste Manage-
ment, 1979, C-5, SW-765
Proposed Hazardous Waste Guidelines and Regulations, Report
to the Regulatory Review Group Submitted by the Council on
Wage and Price Stability, ^arch 16, 1979
Safe Storage and Disposal of Pesticides, May, 1977
Solid Waste Facts: A Statistical Handbook, Office of Water
and Waste Management, 1978, 3W-69U
3. Industry Studies fcr EPA
Draft Economic Impact Analysis for Subtitle C, Resource
Conservation and Recovery Act of 1976. Arthur D. Little, Inc.,
January, 1979 (EPA Contract)
Economic Impacts of RCRA Approaches to the regulation of
Generators of Small Volumes of Hazardous Wastes. Lexington,
Massachusetts, Temple, Barker 4 Sloane, Inc., December 12, 1979
(SPA Contract - Draft)
Economic Impacts of RCRA Approaches to the Regulation of
Generators of Small Volumes of Hazardous Wastes. Lexington,
Massachusetts, Temple, Barker 4 Slcane, Inc., January 5, 1980
(SPA Contract)
Appdx III -3
-------
Technical Environmental Impacts of Various Approaches for
Regulating Small Volume Hazardous Vaste Generators. Vol. I.
Technical Analysis; Vol. II. Appendices.TEW, lac., December
10, 1979 (EPA Contract)
1*. Drafts of Regulations, etc.
Hazardous Waste Guidelines and Peculations - Part 250, (Draft)
August 31, 1979
Reports Impact Analysis, Resource Conservation and Recovery
Act, Subtitle C - Hazardous Waste Mar.ager.ent, Implementation
Branch, Office of Solid Waste, March 19, 19?9
Revised Resource Requirement Summary (?RS) and Sac:Around.
Document for Incorporation in RCRA Dccxet, Hazardous Vaste
Management Division, March 1, 1979
Standards Applicable to Trans-porters of Hazardous Waste,
December 13, 1979 (Draft regulations)
Standards Applicable to Generators of Hazardous Vaste, Decem-
ber 13, 1979 (Draft regulations)
Steering Committee Drafts for 3C?A Regulations Covering Hazardous
Waste Generators and Transporters, December 1-, 1979
5. EPA Memoranda, etc.
California Hazardous Vaste Program, Memorandum: Schaua to
Drayton, November 7, 1979
Coordination of Hazardous Waste Projects, Memorandum: Schaum
to Solid Waste Analytical Team, November 15, 1979
Draft Description of Regulations for Economic Impact Analysis,
Memorandum: 3uc to Branch Chiefs, December 3, 1979
Engacement Plan, Memorandum: Schaum to Draytcn, November 6,
1979"
Memorandum of Understanding: Department of Transportation and
Environmental Protection Agency, June, 1979
Notification of Hazardous Waste Activity Form, Memorandum:
Plehn to Howell, November 29, 1979
RC3A Reports impact Analysis, Memorandum: Melone to 3eal,
November 21, 1979
Appdx III -
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C. National Academy of Sciences
Forum en Nuclear Waste, November 19, 1979, Media Advisory
D. United States Congress
Resource Conservation and Recovery Act of 1976, ?.L. 9^-530
Resource Conservation and Recovery Act of 1976, Report of
the Committee on Interstate and Foreign Commerce, U.S. House
of Representatives, on H.R. 1^96, House Report 9U-1U91
Solid Waste Utilization Act of 1976, Report of the Senate
Committee on Public Works on S. 2150, Senate Report 9U-369
Z. United States Nuclear Regulatory Commission
Draft Regulator:/ Guide ar.d Value/Impact Statement, (Reporting
of Safeguards Events), October, 1979, Division 5, Task SG 901-i*.
Transport of Hazardous Materials: (Irradiated Fuel)
H. Nonfederal Sources
American Petroleum Institute, Assessment of Petroleum Industry
Cost of Cogpliar.ee vith Proposed Hazardous Waste Regulations,
Reston, Virginia, SCS Engineers, April, 1979 I for API)
American Petroleum Institute, Hazardous Waste Guidelines and
Regulations, Comments, API, May 15, 1979, Part I- Comments
and Part II- Appendices
American Petroleum Institute, Status of RCHA regulations,,
Dallas, Texas, API - HPRA Conference, January 31 - February
1, 1980
National Association of Manufacturers, Proposed Hazardous
Waste Guidelines and Regulations; Stagemer.t by the :IAM to
the EPA, Marcn lo, 1979
III. Additional Sources
A. U.S. Environmental Protection Agency
Annual Report to Congress Jan. - Dec. 1973 on the Administration
of the Marine Protection. Researc.i, ar.d sanctuaries Act cf 1972,
as Amended (P.L. 92-532) and Irslesentir.g the International Ocean
Dumping Csnventicr., June 197?
Appdx III - 5
-------
Author!saticr. of Sta-e Hazardous Waste rrograns, Section 3006,
Draft, Jan. 2k., 196 0
Hazardous Waste Management: Overview and Defir.i-ior.s (1*0 CF?. 260),
Internal Use Cniy, Jan. ii, i960
Far- 122 - ZPA Administered Perait Prcsrass: -he National Pollu-ar.-s
Discharge Slisir.aticn Sys-ea; the Hazardous Was^e ?erjl~ Program:
and the Underground Injection Control Program, Section 3005, Draft,
Feb. 8, I960
Part 123 - Sta-e Prograa ?equirer.ents - Section 3006, Draft, Feb.
7, I9SO "~~~
Part 26l - Hazardous Waste Management Sys'ea: Identification and
Listing of Hazardous Vas-e, Draft, Jan. 26, I960
Part 262 - Standards Applicable to Generators of Hazardous Waste,
Internal Use Only, Jan. 11, I960
Part 263 - Standards Applicable to Trans-porters of Hazardous Waste,
Irrcerr-al Use Only, Jan. 11, I960
Part 26U - Standards for Owners and Operators of Hazardous Was^e
Trea^aent, Stcrase. ar.d Disrosal Facilities, Draft, Jan. 25, I960
Ocean Dusroir.g ir. the United States, Six^h Annual Repor- of the
IP A on Adninistra-ion Title I, NG=?.S Act of 1972, Jan. - Dec. 1977,
July 12, 1973.
Section 30Qli - Standards Applicable "o Cvners and Or;era-rors of
Hazardous Vas^e Treatser.t. Storage, and Dis-sosal FaciliLies,
Draft - Preanble RCRA, Subtitle C - Hazardous WasT:e Manaeezent,
Jan. 25, I960
Standards Applicable to Generators of Hazardous Waste, (Docket
JIo. 3002), Internal Use Only, Jan. 11, I960
Standards Applicable to Transporters cf :-.s.zardcus Was-e, (Docket
No. 3003), Internal Use Only, Jan. 11, I960
Support Document ?re=anufacture Motifiea-ion P.eauiresents and
Reviev Procedures, Office of Toxic Substances, Jan. 1979
Appdx III -6
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3. Industry Studies for Z?A
Arthur D. Little, Inc., Sstimated Cos-cs fcr Preparation and Sub-
mission of Reprsposed Premanufactura Notice Fora, Prepared for
Office of Toxic Substances, U.S. Z?A, Sept. 1979
Fred. C. Kart Assoc., Inc., HCRA Enforcement Management System,
Prepared for Office of Enforcement, U.S. SPA, Nov. IT, 1976
Performance Development Institute, Reviev cf FCPA Strategy
Writeups, Feb. 6, i960
Versar, Inc., Classifying Solid Waste Disposal Facilities, A
Guidance Manual - Draft, Prepared fcr Office of Solid Waste, U.S.
SPA, 1979
C. Other Sources
American Tracking Association. Hazardous Waste Guidelines and
Heeulations; Connects of ATA, Inc., Marca io, 1979
Gener'l '^"tric, Proposed Rules »*0 CF? 250 Suboart 3 - Standards
etc.; Consents by G.Z. on Section 2001, 3002, 300^, March lU, 1979
National Solid Waste Management Asscciation, Various Cacaents on
Section 2001. 3C02. 300^ of HCRA. January, March and September 1979.
Appdx III -
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