GAO

United States General Accounting Office

Report to Congressional Requesters

October 2000 HAZARDOUS WASTE

Effect of Proposed 

Rule’s Extra Cleanup 

Requirements Is 

Uncertain

GAO-01-57

Page 1 GAO-01-57 Hazardous Waste

United States General Accounting Office

Washington, D.C. 20548 Letr

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).
Page 2 GAO-01-57 Hazardous Waste

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 
Page 3 GAO-01-57 Hazardous Waste

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 
Page 4 GAO-01-57 Hazardous Waste

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.
Page 5 GAO-01-57 Hazardous Waste

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 

Rule, the Proposed 

Rule Adds More Waste 

Treatment and Unit 

Design Requirements 

for CAMUs

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

not be subject to RCRA’s land disposal or minimum technology 

requirements. Thus, parties could place waste generated during a cleanup 

in a CAMU without first having to treat it. EPA had hoped that the 1993 rule 

would address the disincentives that these two RCRA requirements posed 

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

According to EPA, under the 1993 rule, the agency and authorized states 

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 
Page 6 GAO-01-57 Hazardous Waste

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.
Page 7 GAO-01-57 Hazardous Waste

EPA Did Not Find 

Problems With CAMUs 

Approved Under the 

1993 Rule, but 

Environmental Groups 

Say It Is Too Early to 

Tell

In the proposed rule, EPA stated that it had not identified problems with 

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 

for which the agency had the best available information. Of these, 30 were 

intended for the permanent disposal of hazardous waste and 9 were 

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 

be approved under the terms and conditions of the proposed rule. 

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 
Page 8 GAO-01-57 Hazardous Waste

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 

on Whether the 

Proposed Amendments 

to the 1993 Rule Would 

Deter Cleanups

Although the added requirements in the proposed rule would likely 

increase the time and the costs of cleanups, determining if they would 

discourage requests for CAMUs is difficult. The stakeholders we contacted 

disagreed on the deterrent effect that the proposed rule would have on 

future cleanups under the corrective action, Superfund, and state 

programs.

EPA and the Litigants Do 

Not Expect the 

Amendments to 

Significantly Deter 

Cleanups, but Industry 

Representatives Disagree

EPA does not anticipate that the proposed amendments to the CAMU rule, 

which is expected to go into effect in January 2002, will deter cleanups. 

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

increase because any CAMU can be approved under the more flexible 

terms of the 1993 rule. While the litigants that challenged the 1993 rule 

acknowledge that the proposed rule adds requirements to those cleanups 

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.
Page 9 GAO-01-57 Hazardous Waste

States Are Less Certain of 

the Proposed Rule’s 

Deterrent Effect on the 

Cleanups They Manage

The potential impact that the proposed rule could have on state programs 

is less clear. Some state cleanup program managers said that their states 

approved cleanups under their own programs that used storage and 

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. 
Page 10 GAO-01-57 Hazardous Waste

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 
Page 11 GAO-01-57 Hazardous Waste

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.
Page 12 GAO-01-57 Hazardous Waste

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
Page 13 GAO-01-57 Hazardous Waste
Page 14 GAO-01-57 Hazardous Waste

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

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 

Protection Agency (EPA)

• Managers within the Office of Solid Waste and Emergency Response 

• Managers of the Superfund waste cleanup program 

State Environmental 

Agencies

• Policy directors from the Association of State and Territorial Solid 

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
Appendix I

Objectives, Scope, and Methodology

Page 15 GAO-01-57 Hazardous Waste

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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