82.  0*5-
Thursday
April 8,-:1982
Part ¥
Protection Agency

Hazardous Waste Management System;
General and EPA Administered Permit
Programs; Hazardous Waste Permit
Program; and Requirements for State v '  •
Hazardous Waste Programs; Final Rule
and Issuance of Regulation Interpretation
Memorandum

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15304         Federal Register / Vol. 47, No. 68  /  Thursday, April 8,1982 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY

40 CFR Parts 122 and 124
lSW-FRL-2039-5a]

Hazardous Waste Management
System: General and EPA
Administered Permit Programs:
Hazardous Waste Permit Progarm

AGENCY: Environmental Protection
Agency.
ACTION: Final rule.

SUMMARY: The Environmental Protection
Agency is today amending its
consolidated permit regulations to make
several minor corrections in the
regulations. The consolidated permit
regulations amended today apply to
EPA's issuance of permits to hazardous
waste management facilities,
underground injection control facilities
and facilities that discharge pollutants
to navigable waters.
  These minor changes are being made
to correct and clarify the regulations and
are also in response to settlement
negotiations on these matters in a
lawsuit on the consolidated permit
regulations.
  The Agency believes that these
amendments will minimally reduce the
annualized compliance costs to industry.
The changes should have no impact on
the environment, as they are changes in
paperwork requirements only.
EFFECTIVE DATE: April 8,1982.
FOR FURTHER INFORMATION CONTACT:
RCRA hotline at 382-3000 or toH-free at
(800) 424-934S; or Deborah Wolpe,
Office of Solid Waste tWH-563), U.S.
Environmental Protection Agency,
Washington, B.C. 20460 (202) 755-9107.
SUPPLEMENTARY INFORMATION:

I. Background
  On May 19,1980, EPA published the
consolidated permit regulations which
govern, among other programs, the
hazardous waste management program
under the Solid Waste Disposal Act, as
amended by the Resource Conservation
and Recovery Act of 1976, as amended
(RCRA), 42 U.S.C. 6901 et seq. (45 FR
33230). Parts 122 through 124 pf these
regulations (which appear in Title 40 of
the Code of Federal Regulations) spell
out in detail the requirements to obtain
a hazardous waste management permit,
the requirements for states to receive
authorization to administer their permit
programs in lieu of the Federal permit
program, and the procedures for EPA
decision-making in the permitting
process. In addition, EPA developed a
set of consolidated permit application
 forms to be used by applicants for EPA-
 administered permits. A number of
 industry groups, one State, and one
 environmental group petitioned for
 review of the consolidated permit
 regulations as they relate to RCRA
 issues. These groups raised a variety of
 issues concerning the regulations.
 Included in the RCRA-related issues
 raised by petitioners were a number of
 "common issues." Common issues are
 issues which relate to more than one
 permit program—issues which, for
 example, relate to both the hazardous
 waste management program under
 RCRA and the national pollutant
 discharge elimination system (NPDES)
 program under section 402 of the Clean
 Water Act (CWA), 33 U.S.C. 1362.
   EPA is today amending several
 sections of the regulations to clarify and
 correct them. Two of today's
 amendments apply to  all three permit
 programs. These amendments (1) correct
 a drafting error in the  section which
 requires submission of a topographic
 map, and (2) change the caption of the
 section on duty to halt or reduce
 activities to better comport with the
 substance of the section. The other four
, amendments affect only the hazardous
 waste permit program. These
 amendments (1) clarify that hazardous
 waste permittees need only provide
 "relevant" information upon request of
 the permitting authority; (2) change the
 section on inspection of, and entry to,
 hazardous waste management facilities
 to include the words "at reasonable
 times" in desqribing when EPA, or its
 authorized representative, may enter the
 permittee's premises (3) delete the
 requirement that claims of
 confidentiality on hazardous waste
 permit applications be substantiated at
 the time the application is submitted
 and (4) clarify that if a hazardous waste
 permit is consolidated for
 reconsideration in an evidentiary
 hearing with a permit for discharge to
 navigable waters, it need not always be
 stayed.
   These amendments are partially in
 response to settlement negotiations on
 these issues in "NRDC v. EPA," No. 80-
 1607 and consolidated cases (D.C. Cir.,
 filed June 2,1980). EPA has signed a
 settlement agreement for the RCRA-
 related and common issues, and has
 agreed to promulgate a regulatory
 interpretation memorandum (RIM), and
 several technical amendments, as well
 as to propose several substantive
 amendments to the consolidated permit
 regulations as expeditiously as possible.
 If EPA fulfills these obligations, and
 after notice and comment rulemaking
 (on the substantive amendments),
 promulgates regulations hi substantially
the same form as set forth in the
exhibits to the settlement agreement, the
RCRA petitioners will voluntarily
dismiss their petitions to review the
regulations in 40 CFR Parts 122-124 that.
were promulgated on May 19, ,1980 and
November 17,1980.
'  The amendments promulgated today
are technical amendments to the
regulations. Today's promulgation
fulfills EPA's obligations for all of the
issues listed in Exhibit B to the
settlement agreement. *

II. Changes to  the Regulations

A. Topographic Map

  Section 122.4(d)(7) of Title 40 of the
Code of Federal Regulations requires
that all applicants for RCRA,
underground injection control (UIC), or
NPDES permits provide a. topographic
map, using EPA's standard consolidated
permit application forms. Section
122.4(d)(7) states that the topographic ;
map must extend one mile beyond the,
property boundaries, of the facility
depicting all known wells," springs, other
surface water  bodies, and drinking
water wells "in the map area" (i.e.,
extending one mile beyond the property
boundaries). However, Item XI of the
instructions for Form 1 of the
consolidated permit application forms
states that the topographic map must
show all springs and surface water
bodies * * * plus all drinking water
wells "within  V* mile of the facility" (45
FR 33547, May 19,1980).
  EPA is today correcting this drafting
anomaly. Although the instructions for
Form 1 were correct, § 122.4(d)(7) was
wrong. This section today is amended to
require that the topographic map show
wells, springs, other surface water
bodies and drinking water wells within
%, mile of the facility property
boundaries. EPA stated in the preamble
to the consolidated permit application
forms that, in light of the slow
movement of groundwater, the _.
information within V± mile of the facility
property boundary should be sufficient
to prevent well contamination in cases
where the groundwater becomes
contaminated  through faulty waste    :
disposal or other practices. (See 45 FR
33519, May 19,1980). The regulation now
reflects this decision.
  1 EPA expects to propose the substantive
 amendments set forth in'Exhibits C and D to the
 agreement over the next few months and will
 consider carefully all public comments on the
 proposals before making its final decisions.

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              Federal Register / Vol. 47, No. 68 / Thursday,  April 8,  1982 / Rules and Regulations      15305
 B. Need To Halt or Reduce Activities
 not a Defense  •            ~
   As promulgated on May 19,1980,
 § 122.7 of EPA's consolidated permit
 regulations contains conditions
 applicable to all RCRA, UIC, NPDES
 and 404 permits (dredge and fill permits
 under Section 404 of the GWA). The
 section itself requires that the conditions
 applicable to all permits be incorporated
 in the permits either expressly or by
 reference. EPA today is making changes
 to three paragraphs of § 122.7.
   EPA is today changing the caption
 from "Duty to halt or reduce activity" to
 read "Need to halt or reduce activity not
 a defense," to better comport with the
 substance of the section, which is that a
 permittee will not be allowed to defend
 its noncompliance in an enforcement
 action on the ground that it would have
 otherwise had to halt or reduce the
 regulated activity. Section 122.7(c) deals
 only with the question of defenses to
 liability in an enforcement action, and
 not with the nature or extent of the
 remedy for permit violations. In cases
 involving civil penalties for
 noncompliance with RCRA permits, for
 example, the Agency is directed by
 Section 3008(c) of the Act to take  into
 account the seriousness of the violation
 and any good faith efforts to comply. As
 stated in the May 19,1980 preamble, 45
 FR 33303, the Agency recognizes that in
 some instances halting or reducing
 activities could have more deleterious
 effects than to continue them, that hi
 case of trivial noncompliance it might be
 inappropriate for a permittee to halt or
 reduce its operations, that it maybe
 necessary to continue operations  to
 locate the problem, or that less drastic
 means for assuring permit compliance
 may be appropriate.
   The wording and meaning^ of the
 regulations are not being changed.

 Ci Duty to Provide Information
   Section 122.7(h)r imposes an obligation
 on each EPA permittee to provide "any
 information" requested by the permit-
 issuing authority to determine if the
 permittee is in compliance or if permit
 modification, revocation and reissuance,
 or termination is appropriate.
   Today EPA is amending this section to
 clarify that RCRA permittees need only
 provide "any relevant information."   '„
 Although EPA's intent has always been
-.to request only relevant information,
 this change in language clarifies the
 Agency's intentions in writing for all
 RCRA permittees. Among other things;
 Section 3007(a) of RCRA, which is part  ..
 of the basis for this pro vision of the
 regulations, requires any person who
 handles or has handled hazardous
 waste, to "furnish information relating
- to such wastes" upon request of any
 officer, employee or representative of
 the Environmental Protection Agency.
 The change hi the language of the
 condition, in § 122.7(h) that is inserted in
 all RCRA permits; therefore, is entirely-  .
 consistent.with the underlying enabling
 authority in RCRA.

 D. Inspection and Entry
   Section 122.7(i)(lJ of the consolidated
 permit regulations currently provides
 that a permittee must allow the     .
 Director 2 or an authorized
 representative, upon the presentation of
 any documents required by law, to
 "enter upon the permittee's premises
 where a regulated facility or activity is
 located or conducted, or where records
 must be kept under the conditions  of the
 permit." EPA is today amending 40 CFR
 122.7(i)(l) to require a RCRA permit to
 include a provision stating that the
 Director or an authorized representative
 may enter the facility only "at
 reasonable times." This phrase is used
 in Section 3007(aJ of RCRA, which is the
 underlying RCRA authority for
 § 122.7(i)(l). The Agency is, amending
 the regulation as it applies to RCRA
 permittees to include these words in
 order to make the words of the
 regulation entirely consistent with the
 statute, and alleviate concern expressed
 by the regulated community over this
 matter. EPA is still not precluded from
 inspecting without notice or at any tune
 when an inspection is reasonably
 necessary to determine compliance or
 noncompliance with a RCRA permit.
 E. Confidentiality
   Section 122.19(d} of the regulations
 requires that- claims of confidentiality
 for RCRA permit application
 information be substantiated at the time -
 the application is submitted. The
 amendments today eliminate  this
 requirement for up-front substantiation
 by deleting i 122.19(d) from the
 regulations. Section, 122.19(d) was a
 special exception to the general rules .in
 § 122.19 governing the submission to
 EPA of information claimed as
 confidential by the submitter. With the
 deletion of paragraph (d), §-122.19 (a)
 and (b}(l) will govern EPA's treatment
 of information claimed to be       .  •
 confidential by RCRA permit  applicants
 and permittees. These paragraphs,  in
 accordance with EPA's general
 confidentiality regulations in 40 CFR
 Part 2, require that any claim of
 confidentiality must beasserted at the
  "As defined in § 122.3, "Director" means the EPA
 Regional Administrator or the state Director of an
 authorized program, as the circumstances require.
  time information is submitted to EPA. If.'
  no claim is made when the information
  is submitted to EPA, the Agency may
  make the information available to the
  public without further notice to the
  submitter. If a claim is assertedr EPA
  treats the information in accordance  •
  with the procedures in 40 CFR Part 2. To
  summarize those procedures briefly,
  they provide that before releasing any
  information for which a claim'of
  confidentiality has been asserted, EPA
  will give the submitter an opportunity to
  comment on particular points related to
  the claim; EPA also gives'the business
  asserting the claim notice of the
  Agency's determination of whether
  information is or is not entitled to
  confidential treatment. However, even
  confidential information may be
  disclosed, after notice, in special
  circumstances or when relevant in any
 ^proceeding under the applicable act of
  Congress (e.g., RCRA).
   When the Agency promulgated
  § 122.19{d), it believed that
  substantiation of claims of   .
  confidentiality for RCRA permit
  application information should
 • accompany the information when it was •
  submitted. The Agency believed this
  because EPA wanted to be able to make
  as much permit application information
  as possible available to the public as
  quickly as possible in order to expedite
  permitting. The regulated community
,  has complained, however, that such up-
  front substantiation is unnecessarily  .
  burdensome  to them because it requires.
.  them to substantiate claims which they
  might never be required to substantiate
  under 40 CFR Part 2. Under those •
  regulations no substantiation would be
  required if EPA never needed or wanted"
  to determine the validity of the claim,
   Although EPA still desires to make  •'
  any necessary confidentiality
  determinations as quickly as possible,
  the Agency believes that the procedures
  already contained in 40 CFR Part 2
  provide an adequate mechanism to do
  this. As noted above, me elimination of
  § 122.19[d] makes the treatment of
  claims of confidentiality under the
  RCRA permit program consistent with
  their treatment under the other permit
 •programs governed by the consolidated
 ' permit regulations, all of which rely  on
  the procedures in 4O CFRTart 2.
   It should'be noted that if obtaining
  substantiation of the confidentiality   •
  claim and determining the validity of the
  claim would take longer than the time
  estimated in the project decision
  schedule (40 CFR 124.3(g» for issuance
  of a draft permit arid an opportunity for
 public notice and comment, the decision
  schedule will be revised. This will allow

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 15306       Federal Register / Vol. 47, No. 68 / Thursday, April 8, 1982 / Rules and Regulations
  the public the opportunity to comment
  on all aspects of the permit application
  that may be disclosed under the
  provisions of 40 CFR Part 2.

  F, Stay ofRCRA Permits for New
  Facilities
    Section 124.16 governs when permit
  conditions that are being contested by a~
  permittee are, or may be, stayed. One
  particular provision in § 124.16[a) has
  been of concern to the petitioners in the
  "NRDC v. EPA" litigation.
    Section 124.16{a) provides in part that
  when a RCRA permit is consolidated
  with an NPDES permit for
  reconsideration in an evidentiary
  hearing * the effect of the contested
  permit conditions is stayed and the
  conditions are not subject to judicial
  review pending final agency action.
  Section 124.16{a) further provides that if
  the permit involves a new facility, new.
  source, new discharger, etc., the
  applicant is without a permit for the
  proposed new facility, etc., pending final
  agency action. Section 124.60(a)[l]
  reiterates that provision of § 124.1B(a).4
  However, § 124.60[a}{2) provides that
  the Presiding officer at a hearing on the
  motion of "a source" may issue an order
  authorizing the source to begin
  operation before final agency action if it
  complies with all conditions of its final
  permit (received under § 124.15) during
  the period before final agency action. If
  a party opposes the source's motion to
  begin operation, the source must make
  certain demonstrations before the
 Presiding Officer may issue an order
  authorizing operation.
   Petitioners in the "NRDC v. EPA"
 litigation have protested that although
,  § 124.60{a)(2) allows new sources, new
 dischargers and recommencing
 dischargers to begin operations under an
 order from the Presiding Officer, the
 section apparently does not allow, new
 facilities—the term for new hazardous
 waste management "sources"—to begin
 operations when a RCRA permit has
 been consolidated with an NPDES
 permit for reconsideration in an
 evidentiary hearing. They make that
 assertion because § 124.6Q[a)(2) uses the
 term "source" and does not mention the
 term "facility." They argue that it is
 unfair that a different result should
 obtain for NPDJ3S and RCRA activities.
 EPA agrees that Presiding Officers
 should have the same authority to allow
 the commencement of operations at
 already constructed RCRA and NPDES
 facilities. EPA believes that the
   'This consolidation could take place under 40
 CFR 124,74,124.82 or 124.114.
   4 Section 12-].riO(a) Is cross-referenced in
 S 124,10{a).
 introductory paragraph of § 124.60(a),
 which states that "the following
 provisions apply to NPDES permits and
 to RCRA or UIC permits to the extent
 those permits may have been
 consolidated with an NPDES permit in a
 formal hearing" authorizes Presiding
 Officers to allow RCRA facilities to
 begin operations under the terms of .
 § 124.60(a)(2). However, to clarify this
 issue, EPA is amending § 124.60(a)(2) to
 add the word "facility" after the word
 "source" each time it appears.

 III. Effective Date
   Section 3010[b) ofRCRA provides that
 EPA's hazardous waste regulations and
 revisions to the regulations take effect
 six months after promulgation. In
 addition,,Section 553(d) of the
 Administrative Procedure Act requires
 that substantive rules not become
 effective until at least 30'days after
 promulgation. The purpose of these
 requirements is to allow persons
 handling hazardous waste sufficient
 lead time to prepare to comply with
 major new regulatory requirements. For
 the technical amendments promulgated
 today, however, the Agency believes
 that an effective date of 30 days or six
 months after promulgation would cause
 unnecessary disruption in the
 implementatio'n of the regulations and
 would not be in the public interest.  •
 Because  these amendments are minor
 clarifications, there is no need to allow
 any lead time to prepare for conpliance.
 Therefore these amendments are
^effective immediately upon publication.
 IV. Final Rule
   EPA has determined  under Section
 553[b)(B) of the Administrative
 Procedure Act, 5 U.S.C. 553(b)(B), that
 notice and comment on these technical
 amendments is unnecessary.
   As explained hi the preamble, the
 amendments promulgated today are all
 very minor changes to the regulations,
 which clarify the existing regulations
 without changing the substantive
 requirements of the regulations. Notice
 and comment is unnecessary for such
 minor technical changes.
 V. Executive Order 12291
   Under Executive Order 12291, EPA
 must judge whether a regulation is
 "Major"  and therefore subject to the
 requirement of a Regulatory Impact
 Analysis (RIA). A major ride is one
 which results in (1) an annual effect on
 the economy of $100 million or more; (2)
 a major increase in costs or prices for
 consumers, individual industries,
 Federal,  State or local government
 agencies, or geographic regions; or (3)
 significant adverse effects on
 competition, employment, investment,
 productivity, innovation, or on the
 ability of United States-based
 enterprises to compete with foreign-
 based enterprises in domestic or export
 markets. The Agency does not
 anticipate that today's technical
 amendments will have any of the effects
 which characterize a rule as "major"
 under the Executive  Order and therefore
 has not prepared an  RIA on them.
   This amendment was submitted to the
 Office of Management and Budget for,
 review as required by Executive Order
 12291.

 List of Subjects in 40 CFR Part 122

   Administrative practice and  -
 procedure, Air pollution control,
 Hazardous materials, Reporting and
 recordkeeping requirements, Waste
 treatment arid disposal, Water pollution
 control, Water supply,  Confidential
 business information.

 List of Subjects on 40 CFR Part 124

   Administrative practice and -
 procedure, Air pollution control,
 Hazardous materials. Waste treatment
 and disposal, Water  pollution control,
 Water supply, Indians—lands..
   Dated: March 31,1982.
 Anne M. Gorsuch,
 Administrator.
   For the reasons set out in the
 preamble, Parts 122 and 124 of Title 40
 of the Code of Federal Regulations is
 amended as set forth below:
   1. The authority citation for Parts 122
 and 124 reads as follows:
   Authority. Resource Conservation and
 Recovery Act, 42 U.S.C. 6901 et seg.; the Safe
 Drinking Water Act, 42 U.S.C. 300[f] etseq.;
 the Clean Water Act, 33 U.S.C. 1251 et seg.;
 and the Clean Air Act, 42 U.S.C. 1857 et seg.
 PART 122— EPA ADMINISTERED
 PERMIT PROGRAM: THE NATIONAL
 POLLUTANT DISCHARGE
 ELIMINATION SYSTEM; THE
 HAZARDOUS WASTE PERMIT
 PROGRAM; AND THE UNDERGROUND
 INJECTION CONTROL PROGRAM

  2. Section 122.4(d)(7) is amended by
 removing the words "in the map area"
 and inserting in their place "within V4
 mile of the facility property boundary,"
 so that as amended, the paragraph now
 reads as follows:                    v.

-§122.4  [Amended]
   (7) A topographic map (or other map if
 a topographic map is unavailable)
 extending one mile beyond the property

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              Federal Register / Vol, 47, No. .68 /Thursday, April 8,  1982 / Rules and Regulations       15307
 boundaries of the source depicting the
 facility and each of its intake and
 discharge structures; each of its
 hazardous waste treatment, storage or
 disposal facilities; each well where
 ^fluids from the facility are injected
 imderground; and those wells, springs,
 ather surface water bodies, and drinking
 water wells listed in public records or
 otherwise known to the applicant within
 Vi mile of the facility property     "
 boundary.
   3. Section 122.7 is amended by
 revising the caption to paragraph (c) to
 read as follows:

, § 122.7  [Amended]
 *    *    *     *  -  *   -
   (c) Need to halt or reduce activity not
 a defense. * * *
   4. Section 122.7 is amended by adding
 a second sentence to paragraph (h) so
 that the paragraph reads as follows:

 § 122.7 [Amended]
 ***-'*     *     *
   (h) Duty to provide information. The
 permittee shall furnish to the Director, ,
 within-a reasonable time,  any    \
 information which the Director may
 request to determine -whether cause
 exists for modifying, revoking and
 reissuing, or terminating this permit, or
 to determine compliance with this
 permit. The permittee shall also furnish
 to the Director, upon request, copies of
 records required to-be kept by this1,
 permit. For RCRA only, this condition
 shall include the word "relevant"
 'mmediately following the word "any"
 h the preceding sentence.

   5 Section 122.7 is amended by adding,
 a second clause to paragraph (i)(l) so
 that that paragraph reads as follows:

 § 122.T  [Amended]
                 ,
   (1) Ejiter upon the permittee's
 premises where a regulated facility or
 activity is located or conducted, or
 where reP°rds must be kept under the
 conditions-of this permit; For RCRA
 only, this condition shall include the
 phrase "at reasonable times" after
 "enter";     x
 § 122.19  [Amended]
   6. Section 122.J9 is amended by
 removing paragraph (d).
   _^— -.-        '    **•       *       i
 PART 124—PROCEDURES FOR
 DECISIONMAKING-

   7. The fourth sentence, of § 124.16[a)(l)
 is removed and the'third sentence is,
 amended so that tt>e paragraph (a)(l)
 now reads as
 §124.16  [Amended]   _
   (a) Stays, (1) If a request for review of
 a RCRA or UIC permit under § 124.74 or
 § 124.114 is granted or if'conditions of a
 RCRA or UIC permit are consolidated
 for reconsideration hvari'evidentiary
 hearing on an NPDES permit under
 § 124.82 or § 124.114, the effect of the
 contested permit conditions shall be
 stayed and shall not be subject to
 judicial review pending final agency-
 action. (No stay of a PSD permit is
 available under this section.) If the
 permit involves a new facility or new
 injection well, new source; new.
 discharger or a recommencing
 discharger, the applicant shall be
 without a permit for the proposed new
 facility, injection well, source or-
 discharger pending final agency action,
 except as provided in § 124.60(a)(2).
* *    A .   *    *    *
   8. Section 124.60(a)(2) is  revised by
 adding "or facility" immediately
, following each occurance of the word
 "source" in that paragraph so that the
 paragraph now reads as fpllqwst   ,   •

 §124.60 [Amended]
 *    *    *'.#-#   .
   (a)***
   (2) Wherever a source or facility
 subject to this paragraph has received a
 final permit under § 124.15 which is the-
 subject of a hearing request under
 § 124.74 or a formal hearing under,
 §'124.75, the Presiding Officer, on motion
 by the source or facility, may issue an
 order authorizing it to begin operation
 before final agency action if it complies
• with all conditions of that final permit
 during the period until final agency
 action. The Presiding Officer may grant
 such a motion in any case where no
 party opposes the motion; where the
 source  or facility demonstrates that (i) it
 is likely to prevail on the merits; (ii)
 irreparable harm to the environment will
 not result pending final agency action if
 it is allowed to commence operations
 before final agency action;  and (iii) the
 public interest requires that the source
 or facility be allowed to commence.
 operations. All the conditions of any
 permit covered by that order shall be _
 fully effective and enforceable.
 *'*,*'*•*
 [FR Doc. 82-9397 Filed 4-7-82; 8:45 am]        '   — .-•
 BILLING CODE 6560-50-M
 4QCFRPart123   ;

 [SWFRL 2039-56]

 Requirements for State Hazardous
 Waste Programs

 AGENCY: Environmental Protection
 Agency (EPA).
 ACTION: Notice of issuance of
 regulations interpretation memorandum.

 SUMMARY: EPA is issuing today a
 Regulation Interpretation Memorandum
 ,(RIM) which provides official
 interpretation of one of the requirements
 for final authorization of State
 hazardous waste programs under the
 Resource Conservation and Recovery
 Act. Questions have been addressed to
 the Agency requesting clarification of
 the requirement in 40 CFR 123.37(d) that
 State permits issued prior to final
 authorization be reviewed by the State
 and modified or revoked and reissued to
 require compliance with the ,
 requirements of 40 CFR Part 123.
 DATE: This Regulation Interpretation
 Memorandum becomes effective April 8,
 1982.

 FOR FURTHER INFORMATION CONTACT:
 Deborah Wolpe, State Programs and
 Resource Recovery Division, Office of
 Solid Waste (WH-563), U.S. .
 Environmental Protectiori.Agency, 401 M:
 Street, SW., Washington; D.C«20460,
   RIM 123-82-1, Regulation
 Interpretation Memorandum,
 Modification of Existing State Permits
 Upon Final Authorization of State
 Hazardous Waste Programs.

 Issue •'.'

,   EPA has received questions
 concerning the interpretation of  ,  :  .
 § 123.37(d) of the Requirements for State
 Hazardous Waste Programs. That
 section provides that permits issued
 under State law prior to the date of
 approval of final authorization shall be>~^
 reviewed by tha State Director and
 modified or revoked arid reissued to
 require compliance with.the ,
 requirements of Part 123. Questions
 have been raised concerning whether
 such review and modification of permits
 must occur before a State can obtain,
 final authorization.

 Discussion

   EPA did not intend that review and
 modification of existing State permits
 necessarily occur before a State
 program is approved for final
 authorization. Rather, EPA intended that
 States seeking final authorization make
 a commitment to upgrade existing
 permits so that those permits will
 require compliance with the
 requirements of Part 123. The preamble  .
 to this section states that the State      "
 Director must review and change
 permits as necessary "after a State has
 received final authorization" (45 FR
 33396, May 19, 1980).

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15308       Federal Register / Vol. 47, No.  68 / Thursday, April 8, 1982  /  Rules and Regulations
  The State application for final
authorization will contain a
Memorandum of Agreement (MOA) to
be executed by the State Director and
the EPA Regional Administrator. Section
123.6(d)(5) requires the MOA to provide
for State review and modification of
existing permits. That section states that
"the Regional Administrator and the
State Director shall establish a time
within which this review must take
place."
  EPA intends that the schedule in the
MOA provide a reasonable time period
for the review and upgrading of existing
State permits, based on such factors as
the number of State permits and the
additional permit terms and conditions
needed to satisfy the requirements of
Part 123.
  Dated: Februaiy 23,1982.
  Approved:
Christopher J. Capper,
Acting Assistant Administrator forSotid
Waste and Emergency Response.
[HI Doe. 8J-8S57 Rkd 4-7-815 8:45 am]
BIU.INQ CODE 6560-50-H

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United States
Eiwironmontaf Protection
Agency
Washington DC 20460
Official Business
Penalty for Private Use $300
Postage and
Fees paid
EnvironrhentI
Protection
Agency
EPA 335
                                                                                                                     Third-Class

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