Hazardous Waste: Effect of Proposed Rule's Extra Cleanup Requirements Is
Uncertain (Letter Report, 10/20/2000, GAO/GAO-01-57).

The Environmental Protection Agency (EPA) proposed several amendments to
its 1993 Corrective Action Management Unit (CAMU) rule. The CAMU rule
currently allows agencies to set aside a portion of its hazardous waste
site to deposit wastes without triggering the requirements of the
Recovery Conservation and Recovery Act (RCRA). EPA's action is in
response to a lawsuit that alleges that CAMU rule would allow for the
management of wastes in violation of RCRA's land disposal restrictions.
The 1993 and proposed rules that govern the treatment, storage, and
disposal of hazardous waste onsite in CAMU differ primarily in the
requirements for waste treatment and facility design. According to the
EPA, the proposed rules will increase the time and the costs of site
cleanups using CAMUs because it is less flexible than the 1993 rule and
adds technical and process requirements. Several state representatives
expressed concern that the proposed requirements could end up being
applied to cleanups conducted under their programs, regardless of
whether they were using CAMUs, thereby deterring the progress states
have been making in cleaning up sites.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-57
     TITLE:  Hazardous Waste: Effect of Proposed Rule's Extra Cleanup
	     Requirements Is Uncertain
      DATE:  10/20/2000
   SUBJECT:  Environmental policies
	     Waste management
	     Waste disposal
	     Hazardous substances
	     Industrial wastes
	     Pollution control
	     Federal/state relations
	     Environmental law
IDENTIFIER:  EPA Corrective Action Management Unit
	     Superfund Program

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GAO-01-57

Report to Congressional Requesters

October 2000 HAZARDOUS WASTE Effect of Proposed Rule's Extra Cleanup
Requirements Is Uncertain

GAO- 01- 57

Lett er

October 20, 2000 The Honorable Michael Oxley Chairman The Honorable Edolphus
Towns Ranking Minority Member Subcommittee on Finance and

Hazardous Materials Committee on Commerce House of Representatives

The Resource Conservation and Recovery Act (RCRA) of 1976, as amended,
established three key requirements governing the treatment, storage, and
disposal of hazardous waste. First, under the land disposal requirements,
this waste usually must be treated to minimize threats to

human health and the environment before it is disposed of on land. Second,
under the minimum technology requirements, certain facilities (such as
landfills) that treat, store, or dispose of this waste must meet certain
design

standards, such as installing a double liner under the landfill to protect
soil and water from contamination. Finally, facilities that treat, store, or
dispose of hazardous waste must typically obtain a permit to do so. In
general, a facility that has an ongoing industrial activity and is
requesting a permit to treat, store, or dispose of hazardous waste is
required to clean up all parts of its property that were contaminated by its
past industrial operations. Under its “corrective action”
program, the Environmental Protection Agency (EPA) seeks to ensure that the
operating facilities that pose a potential risk to human health or the
environment are cleaned up.

We previously reported that these three requirements of RCRA were successful
at ensuring that process waste- that is, waste newly generated by currently
operating industrial facilities- was being managed safely. 1 However, these
requirements also had the unintended consequence of deterring the cleanup of
sites whose property was contaminated with old, previously generated waste.
Such sites included not only operating facilities conducting cleanups under
the corrective action program but also

abandoned sites posing high risks that are subject to EPA's Superfund
program. RCRA's requirements also deterred the cleanup of other sites,

1 Hazardous Waste: Remediation Waste Requirements Can Increase the Time and
Cost of Cleanups (GAO/ RCED- 98- 4, Oct. 6, 1997) and Hazardous Waste: EPA
Has Removed Some Barriers to Cleanups (GAO/ RCED- 00- 224, Aug. 31, 2000).

frequently less risky, that states are addressing under their own cleanup
programs. This deterrent effect occurred because the parties planning to
treat, store, or dispose of remediation waste- that is, waste generated
during the cleanup of a site- had to comply with RCRA's requirements
designed for process waste. These requirements are frequently more stringent
and costly than necessary for cleaning up some hazardous waste,

especially waste that poses less risk. Thus, even if treating or permanently
removing the waste was the preferred option, parties sometimes decided not
to clean up certain sites or sought to leave the waste in place at others.

EPA has undertaken a number of initiatives to try to address the barriers
that these three RCRA requirements have posed to managing remediation waste.
For example, in February 1993, EPA issued the Corrective Action Management
Unit (CAMU) rule, which generally provided that the agency could designate a
portion of a site, such as an old landfill, as a CAMU.

Parties could then temporarily or permanently deposit waste in the CAMU
without triggering RCRA's land disposal and minimum technology requirements,
as long as this disposal did not pose a significant risk to human health or
the environment. Managing waste in this manner could

save tens of millions of dollars at some sites, according to EPA program
managers. Later that year, however, certain industry groups involved in
environmental and hazardous waste treatment sued EPA. Among other things,
they alleged that the CAMU rule allows for the management of hazardous waste
in violation of RCRA's land disposal restrictions and, therefore, that such
waste might not remain safe over the long term. To settle this lawsuit, in
February 2000, EPA agreed to propose amendments to the 1993 rule by

imposing some waste treatment and design requirements. EPA published its
proposed amendments on August 22, 2000, has solicited public comments on
them, and plans to take final action on the proposal in October 2001.

Because of your interest in the progress of cleaning up hazardous waste
sites, you asked us to (1) describe the major differences between the 1993
and the most recently proposed CAMU rules; (2) determine what data are
available to demonstrate that CAMUs approved under the 1993 rule remain
protective of human health and the environment; and (3) determine

stakeholders' views on the possible deterrent effects that the proposed CAMU
rule could have on corrective action, Superfund, and state cleanups. To help
us determine the possible effects of the proposed rule, we contacted
officials responsible for managing hazardous waste cleanup

programs in EPA and in a number of states and Fortune 500 companies, as well
as the national associations that represent both state environmental
agencies and industries involved in cleanups. We also contacted directors in
charge of cleanup issues at the two environmental groups most directly
involved in the CAMU lawsuit. Our detailed scope and methodology are in
appendix I.

Results in Brief The 1993 and proposed rules that govern the treatment,
storage, and disposal of hazardous waste onsite in CAMUs differ primarily in
the

requirements for waste treatment and facility design that they place on the
use of CAMUs. The 1993 rule did not establish specific treatment or design
requirements, although its preamble stated that using treatment, as
appropriate, would enhance the long- term effectiveness of a cleanup.

Instead, the rule provided EPA and states with the flexibility to decide,
according to the risks posed by the waste and the site's unique conditions,
what treatment or design features would be necessary. In contrast, the
proposed rule would generally require that the contaminants posing the
greatest potential risk be treated before being placed in a CAMU.
Furthermore, any new, replaced, or expanded units must be constructed to
meet certain design standards, such as having a liner under the waste to
prevent its leakage and migration.

Relying on an EPA study of the CAMUs approved under the 1993 rule, EPA
maintained that the rule was working well and that the CAMUs were protective
of human health and the environment. For example, even though

the rule did not require that hazardous waste be treated before placement in
a CAMU, some waste was treated at about 70 percent of the CAMUs. The groups
that challenged EPA over the rule maintain that it does not ensure

that the CAMUs will remain safe over the long term and that they have not
been operating long enough to experience problems. However, these groups did
not know of instances where problems had occurred at CAMUs

approved under the 1993 rule. According to EPA, the proposed rule will
increase the time and the costs of site cleanups using CAMUs because it is
less flexible than the 1993 rule and adds technical and process
requirements. Although EPA and several environmental representatives did not
expect the added requirements to be a significant deterrent, several
industry representatives predicted that these changes would be burdensome
enough to deter some parties from

using CAMUs. It is uncertain how the proposed rule would affect cleanups
managed under state programs. EPA said that the proposed rule would

apply only to those site cleanups where parties want to use a CAMU; to date,
EPA's experience shows these have primarily been sites being cleaned up
under the corrective action and (to a lesser extent) Superfund programs.
Nevertheless, several state representatives expressed concern that the
requirements under the proposed rule could end up being applied to cleanups
conducted under their programs, regardless of whether they were using CAMUs,
thereby deterring the progress states have been making in cleaning up sites.

Background In our prior reports on the management of remediation waste under
RCRA, we identified three RCRA requirements- land disposal, minimum

technology, and permitting requirements- that, while effective at
controlling contamination from newly generated waste, posed barriers to
managing remediation waste, thereby discouraging some cleanups. The land
disposal requirements posed barriers because, even though some hazardous
waste is lightly contaminated, the only way to meet these

requirements was by incineration, one of the most costly treatment methods.
Furthermore, RCRA's requirements did not account for the fact that new
technologies, such as using organisms to decompose waste in place, could
result in cleanups with reduced risks at much lower costs. The minimum
technology requirements posed barriers because it was

unnecessary and too costly to require that certain waste, which did not pose
a significant risk to human health or the environment, be placed in a
disposal facility that met RCRA's design requirements rather than in less
costly facilities. Finally, because the permitting process required large
volumes of information and could take several years, the process slowed
cleanups, thereby jeopardizing the redevelopment and reuse of some sites. To
avoid triggering any of these RCRA requirements, parties did not clean up
some sites or chose to leave the waste in place at others rather than
permanently remove it, which is the preferred option in some cases.
Recognizing that these three RCRA requirements were a disincentive to some
cleanups, EPA issued a number of regulations and policies that parties could
use under certain circumstances to avoid triggering these requirements,
including the 1993 CAMU rule. For example, under EPA's “area of
contamination” policy, if waste lies within contiguous contaminated
areas of a property, EPA interprets RCRA to allow parties to

consolidate the waste within the area without having to meet RCRA's
requirements.

Under RCRA, a state may enact its own hazardous waste cleanup program and
receive authorization from EPA to operate it in lieu of the federal program.
As of August 2000, 35 states were authorized to implement the corrective
action program, and 22 were authorized to implement the 1993 CAMU rule. EPA
implements the corrective action program in the remaining states.

Compared to the 1993 The 1993 rule established that hazardous waste managed
in a CAMU would

Rule, the Proposed not be subject to RCRA's land disposal or minimum
technology

requirements. Thus, parties could place waste generated during a cleanup
Rule Adds More Waste

in a CAMU without first having to treat it. EPA had hoped that the 1993 rule
Treatment and Unit would address the disincentives that these two RCRA
requirements posed

Design Requirements to some cleanups and would lead to more efficient and
faster cleanups.

According to EPA, under the 1993 rule, the agency and authorized states for
CAMUs had more flexibility to manage hazardous waste and design a CAMU
according to the risks the waste posed. For example, if the parties treated
the waste so it no longer posed a significant risk, they may not have to put

it in a CAMU with a liner. Similarly, if the parties intended to place waste
that was only lightly contaminated in a lined facility, they might not
necessarily need to treat it first.

However, certain environmental groups and the waste treatment industry group
were concerned that the 1993 rule gave EPA and the states too much
discretion and did not ensure that CAMUs would remain safe over the long
term. They firmly believed that EPA should establish nationwide, minimum
baseline standards requiring that the most hazardous waste be treated and
that the CAMUs accepting that waste have protective design features.

In 1997, we reported that EPA wanted to settle the lawsuit to remove the
legal uncertainty that deterred some parties from choosing a CAMU as a
cleanup option. EPA negotiated a compromise settlement with the
environmental and waste treatment industry groups and agreed to propose
amendments to the CAMU rule. The proposed rule, which was published in
August 2000, is more stringent than the 1993 rule but not as stringent as
the

original land disposal and minimum technology requirements RCRA established.
For example:

The proposed rule requires that certain wastes be treated, but to a lesser
extent than under RCRA's land disposal requirements. Under the latter,
according to EPA, waste has to be treated until the concentration of its
contaminants is reduced to the levels achievable by the best available

technologies. For some contaminants, these concentration levels- known as
universal treatment standards (UTS)- are so low that those contaminants must
virtually be eliminated. Under the proposed rule, parties must identify the
contaminants that pose the greatest risk to human health and the environment
and treat the waste containing them

until their amounts or concentrations are reduced to a certain level, but
one that is less stringent than the UTS. According to EPA, for a large site
with multiple contaminants, treatment might be required for only a few,
rather than all of them, as could be the case under the land disposal
requirements. Furthermore, parties most likely could select less costly
treatment options than incineration. 2 The proposed rule requires new,
replaced, or expanded CAMUs to meet design standards, but the standards are
less stringent than the minimum

technology requirements for landfills. For example, the technology
requirements generally specify that a landfill have a thick soil bottom, two
synthetic liners, and two leachate collection systems. In contrast, under
the proposed rule, CAMUs generally would only need a composite layer and one
synthetic liner and one leachate collection system. According to EPA, this
is because the contaminants posing a significant health risk would have been
treated and thus would pose a reduced risk if the CAMU failed and they
leaked and migrated.

The proposed rule also provides for adjusting requirements for a CAMU
according to site- specific factors under certain circumstances. For
example, if waste at a particular site is not likely to migrate or if it is
technically impracticable to meet RCRA's treatment requirements, parties

can request to adjust them. Certain stakeholders acknowledged that, with
this provision, some parties might be able to achieve the same type of CAMU
under the proposed rule as they would have achieved under the more flexible
1993 rule. However, the process to request and obtain approval for these
adjustments would increase the time and the costs of

those cleanups. 2 According to EPA, prior to the proposed amendments to the
CAMU rule, the agency had issued new cleanup standards for contaminated soil
that, in effect, allowed parties to select treatment options other than
incineration for this medium. The proposed CAMU rule would achieve this same
effect for other media.

EPA Did Not Find In the proposed rule, EPA stated that it had not identified
problems with Problems With CAMUs

the CAMUs approved under the 1993 rule. EPA based this on a study of 39
CAMUs that were either approved or near approval under the 1993 rule and
Approved Under the for which the agency had the best available information.
Of these, 30 were 1993 Rule, but

intended for the permanent disposal of hazardous waste and 9 were
Environmental Groups approved to operate until treatment or storage
activities at the unit had been completed. EPA reported that almost all of
the 39 CAMUs would also

Say It Is Too Early to be approved under the terms and conditions of the
proposed rule. Tell

Furthermore, waste in about 70 percent of the CAMUs had undergone some
treatment, even though the 1993 rule did not specifically require it. EPA
pointed out that, nevertheless, it agreed to partly amend the 1993 rule to
resolve the legal uncertainty resulting from the lawsuit, as well as to
clarify and make public the agency's general expectations for CAMUs. None of
the representatives of the groups that challenged EPA over the 1993 rule was
aware of instances where CAMUs approved under this rule had any operational
problems that posed a significant risk to human health or the environment.
Several state and industry representatives pointed out

that, because EPA or an authorized state agency must approve requests for
CAMUs, they help ensure that problems do not arise. Executives with one of
the two environmental groups and with the waste treatment industry group
that challenged EPA over the 1993 rule said that they were not surprised at
the lack of problems with CAMUs approved

under this rule for two reasons. First, according to the environmental
executives, these CAMUs were relatively new and it was too early to see such
problems as leaking and migrating contaminants. Not wanting to wait to see
if problems would arise, these three groups wanted to be proactive and set
minimum requirements for treating hazardous waste and designing CAMUs to
avoid potential problems. Second, according to the waste treatment industry
executives, because of the legal uncertainty regarding the 1993 rule, in
general, parties using CAMUs had not used the full flexibility it provided.
These industry executives believed that parties

conducting cleanups were concerned that if they did so, and EPA lost the
lawsuit, they would need to take additional cleanup actions at their CAMUs,
which would be costly. According to these executives, parties were
conservative and incorporated some of the treatment and design requirements
into operating their CAMUs, even if the 1993 rule did not require them to do
so. The executives believed this strategy would help

ensure that their CAMUs would remain safe over the long term. The three
groups were concerned that, without the lawsuit and amendments to the

rule, the parties conducting cleanups would not treat certain hazardous
waste or line the units and that problems would occur in the future.

Stakeholders Disagree Although the added requirements in the proposed rule
would likely on Whether the

increase the time and the costs of cleanups, determining if they would
discourage requests for CAMUs is difficult. The stakeholders we contacted
Proposed Amendments

disagreed on the deterrent effect that the proposed rule would have on to
the 1993 Rule Would

future cleanups under the corrective action, Superfund, and state Deter
Cleanups

programs. EPA and the Litigants Do

EPA does not anticipate that the proposed amendments to the CAMU rule, Not
Expect the which is expected to go into effect in January 2002, will deter
cleanups. Amendments to

Until then, EPA thinks that the number of requests for CAMUs might
Significantly Deter

increase because any CAMU can be approved under the more flexible Cleanups,
but Industry terms of the 1993 rule. While the litigants that challenged the
1993 rule acknowledge that the proposed rule adds requirements to those
cleanups Representatives Disagree

using a CAMU, they believe the additional requirements are necessary and
will not be significant enough to discourage parties from using CAMUs.

In contrast, industry representatives, some of whose companies are involved
in large corrective action cleanups, believe the additional requirements are
not justified, are unnecessarily redundant and costly, and will discourage
some parties from conducting cleanup activities. These representatives gave
EPA credit for soliciting their views during settlement

negotiations, but they believe the agency gave up too much of the
flexibility provided under the 1993 rule. They believe that rule was working
and provided for safe but cost- effective CAMUs. EPA program managers, who
set policy on requirements for Superfund cleanups, do not expect the
proposed rule to significantly deter the use of CAMUs at such cleanups
because not many parties have used CAMUs as an

option. The managers reported that parties were using EPA's other policy
options, such as the “area of contamination” policy, to avoid
triggering some of RCRA's requirements, such as the land disposal and
minimum technology requirements, and the managers expected that those
parties would be able to continue to use these options. Likewise, officials
at the departments of Defense and Energy who are involved in Superfund

cleanups at their facilities did not expect the proposed rule to have a
significant negative effect on these cleanups.

States Are Less Certain of The potential impact that the proposed rule could
have on state programs

the Proposed Rule's is less clear. Some state cleanup program managers said
that their states Deterrent Effect on the approved cleanups under their own
programs that used storage and

Cleanups They Manage disposal methods similar to those that would be used
under a CAMU but

did not go through the formal process to approve these activities as CAMUs.
States based their actions on language in the preamble to the 1993 rule that
outlined how they could use their own authorities to waive RCRA's hazardous
waste requirements, as necessary, to authorize these “CAMUlike”

activities. Several state program managers and executives of the two
associations representing state cleanup agencies were concerned that because
the proposed rule is less flexible and more stringent than the 1993 rule, it
would be harder for states to justify using CAMU- like activities, thus

deterring cleanups under state programs. Representatives from one of the
state associations also explained that parties conducting cleanups under
state programs sometimes avoided triggering RCRA's hazardous waste
management requirements by following one of EPA's alternative options, the
“source of contamination” policy. Under this policy, a party
must make a good- faith effort to determine the source of a site's hazardous
waste. Knowing its source allows parties to determine whether the waste is
on the list of wastes that EPA has deemed

hazardous under RCRA. When no records exist to document the source, EPA
allows the agency managing the cleanup to presume that the waste is not
subject to RCRA's requirements. However, the state representatives believe
the proposed CAMU rule has more extensive requirements than this for parties
to identify the contaminants that pose the greatest risk and thus are
concerned that it will be harder to use this policy alternative, thereby
deterring cleanups. EPA stated that it expects parties will make the same

good- faith effort to identify hazardous waste under the proposed rule as
under the source of contamination policy. Also, the agency does not intend
for the proposed rule to change any policies, other than those relating to
CAMUs, that the states already have been using to achieve cleanups or for it
to have a negative impact on state programs. Because the amendments in the
proposed rule are more stringent than the 1993 rule, states are concerned
that they might have to go through a long and burdensome process to be
authorized to implement the amendments. However, the proposed rule provides
that if a state is already authorized to implement the 1993 rule and meets
certain other criteria, that state could

receive 3- year interim authority from EPA to implement the proposed rule.
In the meantime, the state could go through its own rulemaking authority to
make the amendments a permanent part of its own cleanup program.

EPA estimated that, as of the August 22 publication of the proposed
amendments, 19 of the 22 states currently authorized to implement the 1993
rule would meet the criteria for this interim authorization. According to
EPA, the remaining three states, if they resolve certain issues before the
proposed rule is final, would also qualify for interim authorization.

EPA also expected that some of the 13 states authorized to implement the
corrective action program but not the 1993 CAMU rule would want to be
authorized to implement the proposed rule. The legal uncertainty over CAMUs
would be resolved and they could be a cost- effective cleanup tool. EPA
thereby proposed a more streamlined process for such states to obtain this
authorization, for example, requiring fewer data submissions. Also, EPA
noted that states often adopt federal regulations verbatim or incorporate
them by reference into their own regulations. The agency believed that if
any of the 13 states did this, the state could quickly receive authorization
to implement the proposed rule.

Conclusion EPA intended the 1993 CAMU rule to provide regulatory relief from
RCRA's three requirements that were disincentives to some hazardous waste
cleanups. The agency also expected the rule to provide parties with the
flexibility to design CAMUs according to site- specific circumstances rather
than to “one- size- fits- all” requirements, which can increase
the time and costs of some cleanups. EPA expected the rule to lead to faster
and more efficient, but equally safe, cleanups under the corrective action
and Superfund programs. However, the legal challenge to the 1993 rule
discouraged some parties from requesting CAMUs or using the full flexibility
afforded by the rule. Therefore, relatively few CAMUs were requested under
this rule. The proposed rule is intended to resolve, among

other things, the legal uncertainty over the 1993 rule. However, this
proposed rule would add requirements and processes. Certain groups believe
these changes are necessary to help ensure the future safety of CAMUs. Other
groups believe the changes would unnecessarily reduce the

flexibility intended by the 1993 rule, which would increase the time and
costs of some cleanups, and could discourage requests for CAMUs after the
proposed rule is issued. Agency Comments We provided a draft copy of this
report to EPA for its review and comment. EPA generally agreed with the
report and provided technical and clarifying comments, which have been
incorporated as appropriate. The agency also

wanted to emphasize two points. First, it was concerned that our discussion
of the 1993 CAMU rule might lead to the conclusion that, under the rule,
parties did not have to consider treating hazardous waste at all. Therefore,
the agency wanted to restate that, while the 1993 rule did not contain any
explicit or specific, detailed requirements that parties treat this waste,
it did state in the preamble that treatment should be used, as appropriate,
to enhance the long- term effectiveness of cleanups. EPA also wanted to
reemphasize that it did not have any intention for the proposed rule to
affect any cleanups managed under state programs, other than those cleanups
that wanted to use a CAMU. For example, one concern

was that the requirements in the proposed rule- that parties must provide
information on the source of waste and identify the principle hazards of
concern in that waste when requesting a CAMU- would make it difficult for
states to continue to use the source of contamination policy to avoid
automatically triggering RCRA's requirements. EPA stated that the

proposed rule should not interfere with the use of this policy. The agency
assumed that, even under this policy, at the beginning of any cleanup,
parties would go through some level of activity to determine whether
hazardous waste was present, and, if so, what kind and at what concentration
levels. According to EPA, parties conducting cleanups need

to do this to determine what cleanup standards they will be required to meet
at the site. Therefore, EPA assumed that the waste identification and
characterization requirements in the proposed rule would not impose
additional requirements on cleanups, especially those that are not using a
CAMU. We clarified our report to address these concerns.

Unless you announce its contents earlier, we plan no further distribution of
this report until 10 days after the date of this letter. At that time, we
will send copies of the report to appropriate congressional committees and
interested Members of Congress. We will also send copies of this report to
the Honorable Carol M. Browner, Administrator, EPA, and the Honorable

Jacob J. Lew, Director, Office of Management and Budget. In addition, we
will make copies available to others on request.

We conducted this review from March through September 2000 in accordance
with generally accepted government auditing standards. Key contributors to
this report were Rich Johnson and Eileen Larence. If you or your staff have
any questions about this report, please contact me at (202) 512- 6111.

David G. Wood Director, Natural Resources

and the Environment

Appendi Appendi xes x I

Objectives, Scope, and Methodology Our overall objectives were to (1)
describe the major differences between the 1993 and proposed Corrective
Action Management Unit (CAMU) rules, (2) determine what data are available
to demonstrate that CAMUs approved under the 1993 rule remain protective of
human health and the environment, and (3) determine stakeholders' views on
the possible deterrent effects that the proposed CAMU rule could have on
corrective action, Superfund, or state cleanups. To respond to these
objectives, we reviewed applicable statutory excerpts, the 1993 and proposed
CAMU rules, certain cleanup policies, and other documents related to these
issues. We also interviewed representatives from EPA and all major
stakeholder groups that have been actively involved in the development of
the CAMU rule and the proposed amendments. These groups include the

following: The Environmental

Managers within the Office of Solid Waste and Emergency Response Protection
Agency (EPA) Managers of the Superfund waste cleanup program

State Environmental Policy directors from the Association of State and
Territorial Solid

Agencies Waste Management Officials and the Environmental Council of States,

as well as officials from associations representing managers of state
cleanup programs Managers in eight states responsible for overseeing
cleanups under the

corrective action program or their own state cleanup programs (We selected
five of the states- California, Illinois, New Jersey, New York, and
Pennsylvania- because they collectively generate about 35 percent of the
nation's remediation waste. The remaining three states- Texas,

Washington, and Wisconsin- were selected for geographic diversity.) Industry
Groups Attorneys and cleanup managers from major corporations who are

members of the following three national associations that represent
industries involved in conducting cleanups: the RCRA Corrective Action
Project, the Technical Group, and the Risk- Based Corrective Action
Leadership Council Executive officers of the Environmental Technology
Council, which

represents private waste companies

Environmental Groups A principal attorney from Environmental Defense, a
nonprofit environmental advocacy organization The former and current
principal attorneys from the Natural Resources Defense Council

We conducted our review from March through September 2000 in accordance with
generally accepted government auditing standards.

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Appendix I

Appendix I Objectives, Scope, and Methodology

Page 15 GAO- 01- 57 Hazardous Waste

United States General Accounting Office Washington, D. C. 20548- 0001

Official Business Penalty for Private Use $300

Address Correction Requested Bulk Rate

Postage & Fees Paid GAO Permit No. GI00
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