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transporting, storing, or disposing of hazardous waste. The
Agency believes that a successful legislative process to make
targeted changes to RCRA, could make the statute an even more
effective tool in safely managing our solid and hazardous waste.
For more information on the RCRA Legislative Reform
Initiative, please contact any member of our RCRA Legislative
Reform Team: David Hockey, Team Leader, at 202 260-7596; Bob Hall
at 202 260-4498; or Judy Kertcher at 202 260-4522. Thank you for
your interest in improving RCRA.
Attachment 1 - Outreach Plan
Attachment 2 - Draft Issue Papers
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ATTACHMENT #1
SUBJECT: Outreach Plan for RCRA's Legislative Reform Initiative
«
The President's plan for developing targeted legislative
improvements to the Resource Conservation and Recovery Act (RCRA)
places an important emphasis on soliciting input from multiple
stakeholders. The process EPA is initiating today will provide
several opportunities for individuals from all major stakeholder
groups (e.g., states, regulated community, environmental
community, general public) to present their individual ideas and
suggestions for improving the solid and hazardous waste system
under RCRA.
The President's plan states that the Agency will convene a
outreach process by April 15, 1995 and will deliver to Congress a
package of legislative "rifle-shot" improvements to RCRA by
July 15, 1995. In order to gather the multi-stakeholder input
and meet the ambitious schedule, EPA is taking several approaches
to this outreach strategy.
EPA recognizes that 90 days is a relatively short time to
solicit the views of the numerous parties that may have interest
in RCRA legislative changes. Therefore, EPA will convene a
roundtable comprised of individuals who generally reflect RCRA's
major stakeholder groups. The roundtable members will each
provide the Agency with their own ideas and suggestions related
to this initiative. EPA will hold three meetings of the
roundtable that will be open to the public and each meeting will
provide time for public comments and suggestions.
The Agency also will meet, as time permits/ at the request
of individuals, groups, or coalitions who wish to present their
ideas and suggestions to the Agency. Due to the short time
period, it would be helpful for individuals of similar interests
or supporting similar ideas to work together in presenting their
ideas to the Agency. It also may be productive for groups or
coalitions to work with selected individuals of the roundtable;
the roundtable members will be announced shortly.
Additionally, EPA will be accepting written comments and
suggestions for the initiative that will be made available in a
public docket established for this process. Meeting summaries,
roundtable meeting summaries, and any other documents relevant to
the initiative also will be placed in the docket. (See Attachment
#2 for details regarding the docket.) Given the expedited
timeframe, EPA will not prepare formal responses to all comments
and suggestions placed in the docket.
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Roundtable/Public Meeting Schedule
(Specific meeting sites and times will be announced in the
Federal Register by April 24th)
Number 1
Date:
EPA Region:
City/State:
Number 2
Date:
EPA Region:
City/State:
Number 3
Date:
Place:
City/State:
May 10, 1995
EPA Region V
Chicago, IL
May 23rd, 24th, or 25th, 1995 (to be decided ASAP)
EPA Region VI
Houston, TX
June 7, 1995
EPA Headquarters
Washington, D.C.
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ATTACHMENT #2
SUBJECT: Draft Issue Papers
Attached are draft issue papers developed to serve as a
starting point for discussions to prepare a package of "rifle-
shot" reforms to the Resource Conservation and Recovery Act
(RCRA) by July 15, 1995. Each draft paper highlights a topic and
concern previously raised to the Agency by one or more
stakeholders regarding the statutory basis for managing solid and
hazardous waste.
For your convenience, we have attempted to add as background
relevant citations to applicable statutory language, regulations,
and judicial cases (where any). We caution the reader not to
infer any new EPA policy statements from these draft issue
papers. These papers are staff-level attempts to summarize
issues on which the Agency has heard concerns expressed, with
relevant citations added.
In developing the package of targeted legislative reforms
for RCRA, EPA will be following the principles for reinventing
environmental protection outlined in the President's plan:
o Protecting public health and the environment is an important
national goal, and individuals, businesses and government
must take responsibility for the impact of their actions.
o Regulation must be designed to achieve environmental goals
in a manner that minimizes costs to individuals, businesses,
and other levels of government.
o Environmental regulations must be performance-based,
providing maximum flexibility in the means of achieving our
environmental goals, but requiring accountability for the
results.
o Preventing pollution, not just controlling or cleaning it
up, is preferred.
o Market incentives should be used to achieve environmental
goals, whenever appropriate.
o Environmental regulation should be based on the best science
and economics, subject to expert and public scrutiny, and
grounded in values Americans share.
o Government regulations must be understandable to those who
are affected by them.
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o Decision making should be collaborative, not adversarial,
and decision makers must inform and involve those who must
live with the decisions.
o Federal, state, tribal and local governments must work as
partners to achieve common environmental goals, with
non-federal partners taking the lead when appropriate.
o No citizen should be subjected to unjust or disproportionate
environmental impacts.
We welcome your ideas and suggestions for improving the
Resource Conservation and Recovery Act. The public must send an
original and two copies of their comments and suggestions to the
following address, and please place the docket number
F-95-LRRA-FFFFF on your submittal.
RCRA Information Center (5305)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 204"60
You also can contact any member of the RCRA Legislative
Reform Team for more information:
David Hockey, Team Leader
phone 202 260-7596
fax 202 260-9355
Judy Kertcher
phone 202 260-4522
fax 202 260-9355
Bob Hall
phone"202 260-4498
fax 202 260-9355
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Staff Draft-Far Discussion Purposes Only 1
Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Listing Determinations
Concern When determining whether to list a waste as hazardous, the Agency
considers plausible mismanagement scenarios (e.g., management in
an unlined surface impoundment) in order to be protective. However,
if the waste in question is currently or can be managed under
enforceable, good management practices that protect human health
and the environment, then mismanagement may no longer be
plausible, and full RCRA hazardous waste requirements may not be
necessary.
Background
Statutory
Section 3001(a)--Criteria for Identification or Listing [of Hazardous Waste]
....the Administrator shall....develop and promulgate criteria
for....listing hazardous waste....
Section 1004(5)--Definition of Hazardous Waste
The term "hazardous waste" means a solid waste....which because of
its quantity, concentration, or physical, chemical, or infectious
characteristic may....pose a substantial present or potential hazard to
human health or the environment when improperly treated, stored,
transported, or disposed of, or otherwise managed.
Section 7003-lmminent Hazard Authority
[U]pon receipt of evidence that the past or present handling ... of any
solid or hazardous waste may present an imminent and substantial
endangerment to health or the environment, the Administrator may
bring suit .... [or] issute] orders as shall be necessary to protect public
health and the environment.
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Regulatory
Title 40, Code of Federal Regulation, Parts 260, 261.
Judicial
Edison Electric Institute v. U.S. EPA. 2 F.3d 438 (D.C.Cir. 1993).
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Management Requirements
Concern Once a waste is identified as hazardous, through a listing or by
exhibiting a characteristic, all of the applicable requirements for the
generator, transporter, and facility treating, storing, or disposing of
the waste apply. Thus, the regulatory implications of a decision
about whether a waste is hazardous are "all or nothing"; there is
currently no middle ground. However, it may be possible that for
certain wastes and scenarios the full hazardous waste management
requirements are not needed; the application and enforcement of
specific, tailored good management practices could negate the risk
posed for that waste, and thus the need for a hazardous waste
designation.
Background
Statutory
Section 3004(a)--Standards Applicable to Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities
...the Administrator shall promulgate regulations establishing such
performance standards, applicable to owners and operators of
facilities for the treatment, storage, and disposal of hazardous waste
identified or listed under this subtitle as necessary to protect human
health and the environment.... Such standards shall include, but need
not be limited to, requirements respecting- (1) maintaining records...
(2) satisfactory reporting, monitoring, and inspection and compliance
with the manifest system... (3) operating methods, techniques, and
practices as may be satisfactory... (4) location, design, and
construction... (5) contingency plans... (6) maintenance of
operation... qualifications as to ownership, continuity of operation,
training for personnel, and financial responsibility (7) compliance with
[permit] requirements...
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Section 3005(a)--Permit Requirements
the Administrator shall....[require] each person owning or operating
an existing or planning to construct a new facility for the treatment,
storage, or disposal of hazardous waste to have a permit....
Section 3005(c)--Permit Issuance
Upon a determination....of compliance....for which a permit is applied
for under this section with the requirements of this section and
section 3004, the Administrator shall issue a permit for such facilities.
Section 3004(m)(1) and (2)--Treatment Standards for Wastes Subject to
Land Disposal Prohibitions
(1) ....the Administrator shall....promulgate regulations specifying
those levels or methods of treatment, if any, which substantially
diminish the toxicity of the waste or substantially reduce the
likelihood of migration of hazardous constituents from the waste so
that short-term and long-term threats to human health and the
environment are minimized.
Section 3004(u)--Continuing Releases at Permitted Facilities
Standards promulgated under this section shall require, and a permit
issued....by the Administrator or state shall require, corrective action
of all releases of hazardous waste or constituents from any solid
waste management unit at a treatment, storage, or disposal facility
seeking a permit under this subtitle, regardless of when the waste
was placed in such unit. Permits issued under section 3005 shall
contain schedules of compliance for such corrective action (which
such corrective action cannot be completed prior to issuance of a
permit) and assurances of financial responsibility for completing such
corrective action.
Regulatory
Title 40, Code of Federal Regulation, Parts 264, 265, 266, 267, 268, 270.
Judicial
No specific cites.
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic RCRA Permits
Concern For low-risk hazardous waste management facilities (e.g., storage-
only facilities), the requirement to obtain a RCRA permit (and to meet
associated management requirements) can in some cases lead to high
administrative costs while resulting in little or no increased
environmental benefit. Cumbersome permit requirements can also
delay the transition from less stringent interim status standards to
other, more appropriate, management standards.
Background
Statutory
Section 3005(a)--Permit Requirements
the Administrator shall....[require] each person owning or operating
an existing or planning to construct a new facility for the treatment,
storage, or disposal of hazardous waste to have a permit....
Section 3005(c)--Permit Issuance
Upon a determination....of compliance....for which a permit is applied
for under this section with the requirements of this section and
section 3004, the Administrator shall issue a permit for such facilities.
Section 3004(u)--Corrective Action
[A] permit issued after November 8, 1984, ... shall require corrective
action for all releases of hazardous waste or constituents from any
solid waste management unit....
Regulatory
Title 40, Code of Federal Regulation, Part 270; sec. 264.101
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Judicial
No specific cites.
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Prescriptive Requirements
Concern The RCRA requirements governing certain hazardous wastes can be
prescriptive and may be impractical to implement in certain situations
(e.g., radioactive waste mixed with hazardous waste). In addition,
certain RCRA requirements may be economically unreasonable to
implement, where they have a major impact on the regulated entity
without a corresponding environmental benefit (e.g., small businesses
that do not meet the technical requirements for the small quantity
generator exemption from most RCRA requirements).
Background
Statutory (Principally, the following examples have been mentioned)
Section 3004(a)--Standards Applicable to Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities
...the Administrator shall promulgate regulations establishing such
performance standards, applicable to owners and operators of
facilities for the treatment, storage, and disposal of hazardous waste
identified or listed under this subtitle.... Such standards shall include,
but need not be limited to, requirements respecting--. (1) maintaining
records... (2) satisfactory reporting, monitoring, and inspection and
compliance with the manifest system... (3) operating methods,
techniques, and practices as may be satisfactory... (4) location,
design, and construction... (5) contingency plans... (6) maintenance
. of operation... qualifications as to ownership, continuity of operation,
training for personnel, and financial responsibility (7) compliance with
[permit] requirements...
Section 3004(m)(1) and (2)--Treatment Standards for Wastes Subject to
Land Disposal Prohibitions
(1) ....the Administrator shall....promulgate regulations specifying
those levels or methods of treatment, if any, which substantially
diminish the toxicity of the waste or substantially reduce the
likelihood of migration of hazardous constituents from
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f Staff Draft-For Discussion Purposes Only 1
the waste so that short-term and long-term threats to human health
and the environment are minimized.
Section 3004(u)--Continuing Releases at Permitted Facilities
Standards promulgated under this section shall require, and a permit
issued....by the Administrator or state shall require, corrective action
of all releases of hazardous waste or constituents from any solid
waste management unit at a treatment, storage, or disposal facility
seeking a permit under this subtitle, regardless of when the waste
was placed in such unit. Permits issued under section 3005 shall
contain schedules of compliance for such corrective action (which
such corrective action cannot be completed prior to issuance of a
permit) and assurances of financial responsibility for completing such
corrective action.
Regulatory
Title 40, Code of Federal Regulation, Parts 260, 262, 263, 264, 265, 266,
267, 268.
Judicial
No specific cites.
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Land Disposal Restrictions
Concern The land disposal restrictions prevent the disposal of hazardous waste
on the land until levels of treatment are met which ensure that short-
term and long-term threats to human health and the environment are
minimized. For some wastes, this provision could be interpreted to
require the treatment of the waste's hazardous constituents to levels
below those which the Agency would consider necessary to protect
human health and the environment.
Background
Statutory
Section 3004(m){1) and (2)--Treatment Standards for Wastes Subject to
Land Disposal Prohibitions
(1) ....the Administrator shall....promulgate regulations specifying
those levels or methods of treatment, if any, which substantially
diminish the toxicity of the waste or substantially reduce the
likelihood of migration of hazardous constituents from the waste so
that short-term and long-term threats to human health and the
environment are minimized.
(2) If such hazardous waste has been treated to the level or by a
method specified....such waste or residue thereof....may be disposed
of in a land disposal facility.
Regulatory
Title 40, Code of Federal Regulation, Part 268
Judicial
Hazardous Waste Treatment Council v; U.S. EPA (HWTC III). 886 F.2d 355
at 361-65 (D.C. Cir. 1989)
Chemical Waste Management v. U.S. EPA ("Third-Third" case), 976 F.2d 2,
at 14, 31-32 (D.C.Cir. 1992).
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Treatment Requirements
Concern The land disposal restrictions require the treatment of waste to
specified levels or with a specified technology before the waste can
be dispose on the land. However, under some circumstances, the
process of treating certain wastes to meet LDR requirements may
itself pose a greater risk to human health and the environment than
land disposal or other alternative management practices.
Background
Statutory
Section 3004(m)(1) and (2)-Treatment Standards for Wastes Subject to
Land Disposal Prohibitions
(1) ....the Administrator shall....promulgate regulations specifying
those levels or methods of treatment, if any, which substantially
diminish the toxicity of the waste or substantially reduce the
likelihood of migration of hazardous constituents from the waste so
that short-term and long-term threats to human health and the
environment are minimized.
(2) If such hazardous waste has been treated to the level or by a
method specified....such waste or residue thereof....may be disposed
of in a land disposal facility.
Regulatory
Title 40, Code of Federal Regulation, Part 268
Judicial
American Petroleum Institute v. U.S. EPA. 906 F.2d 729, at 735-36 and
738 (D.C.Cir. 1990)
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i
Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Untreated Waste Disposal
Concern The RCRA requirements preventing the disposal of untreated waste
on the land unless it can be proven that the waste will not migrate
from the unit as long as the waste remains hazardous (potentially
thousands of years), may prevent the safe disposal of low-risk
untreated or partially treated waste in certain land based units (i.e.,
deep well injection).
Background
Statutory
3004(d)(1)--Prohibitions on Land Disposal of Specified Wastes
....a method of land disposal [for a specified untreated hazardous
waste] may not be determined to be protective of human health and
the environment.... unless,....it has been demonstrated to the
Administrator, to a reasonable degree of certainty, that there will be
no migration of hazardous constituents from the disposal unit or
injection zone for as long as the waste remain hazardous.
Regulatory
Title 40, Code of Federal Regulation, section 268.6
Judicial
Brent Kav v. U.S. EPA. C.A. No. 6:90 CV582 (Aug. 3, 1993) (unpublished)
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Deferral of RCRA Requirements
Concern Court opinions addressing the management of hazardous wastes
under alternative protective authorities (e.g., Clean Water Act), in lieu
of RCRA Subtitle C, have left EPA's authority to defer to these
authorities unclear.
Background
Statutory
Section 1006(b)--lntegration with Other Acts
The Administrator shall integrate all provisions of this Act....and shall
avoid duplication, to the maximum extent practicable, with the
appropriate provisions of [the Clean Air Act, Federal Water Pollution
Control Act, Federal Insecticide, Fungicide, and Rodenticide Act, Safe
Drinking Water Act, the Marine Protection, Research and Sanctuaries
Act,] and following and such other Acts of Congress as grant
regulatory authority to the Administrator. Such integration shall be
effected only at the extent that it can be done in a manner consistent
with the goals and policies expressed in this Act and in the other acts
referred to in this subsection.
Regulatory
No specific cite in the Code of Federal Regulations.
Judicial
Edison Electric Institute v. U.S. EPA. 2 F.3d 438 (D.C.Cir. 1993).
Chemical Waste Management v. U.S. EPA ("Third-Third" case), 976 F.2d 2,
at 25 (D.C.Cir. 1992).
State of Colorado v. U.S. Department of the Armv. 707 F.Supp. 1562, at
1566-67 (D.Colo. 1989).
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Indian Tribal Program Approval
Concern EPA has explicit statutory authority to authorize states to implement
hazardous and solid waste management programs. RCRA does not
explicitly mention Indian Tribes in its discussion of authorization
authorities; this omission has led some to challenge EPA's authority
to approve qualified Tribal programs.
Background
Statutory
Section 3006(b)--Authorization of State Programs
Any State which seeks to administer and enforce a hazardous waste
program....may develop and....submit to the Administrator [a]n
application....for authorization for such program.
Section 4005(c)(1)(C)--Upgrading of Open Dumps-Control of Hazardous
Disposal
The Administrator shall determine whether each State has developed
an adequate [permit program to assure that solid waste management
facilities within such State which may receive hazardous household
waste or small quantity generator waste will be in compliance with
the upgraded open dumping criteria].
Regulatory
Title 40, Code of Federal Regulation Parts 258, 271, 272
Judicial
No specific cites.
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Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Recycling of Hazardous Waste
Concern Facilities treating or storing a hazardous waste need to obtain a
permit and comply with all applicable management standards (e.g.,
land disposal restrictions, facility-wide corrective action, financial
assurance). However, some facilities that recycle hazardous waste
may not pose significant risks to human health and the environment
or may need less than full RCRA hazardous waste regulation to
ensure safe handling of waste. The need to comply with the full
panoply of hazardous waste requirements may discourage the
potential safe recycling of hazardous wastes. To better encourage
appropriate recycling, certain of these wastes may not need to be
defined and regulated as a solid waste under RCRA.
Background
Statutory
Section 1004(34)-Definition of Treatment
....any method, technique, or process....designed to change
the....character or composition of any hazardous waste so as to
....render, such waste....amenable for recovery....
Section 3005{a)-Permit Requirements
the Administrator shall....[require] each person owning or operating
an existing or planning to construct a new facility for the treatment,
storage, or disposal of hazardous waste to have a permit....
Section 3005(c)--Permit Issuance
Upon a determination....of compliance....for which a permit is applied
for under this section with the requirements of this section and
section 3004, the Administrator shall issue a permit for such facilities.
Section 3004(u)--Continuing Releases at Permitted Facilities
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[ Staff Draft-For Discussion Purposes Only 1
Standards promulgated under this section shall require, and a permit
issued....by the Administrator or state shall require, corrective action
of all releases of hazardous waste or constituents from any solid
waste management unit at a treatment, storage, or disposal facility
seeking a permit under this subtitle, regardless of when the waste
was placed in such unit. Permits issued under section 3005 shall
contain schedules of compliance for such corrective action (which
such corrective action cannot be completed prior to issuance of a
permit) and assurances of financial responsibility for completing such
corrective action.
Regulatory
Title 40, Code of Federal Regulation, Parts 260, 261, 262, 263, 264, 266,
268, 270.
Judicial
American Mining Congress v. EPA (AMC I). 824 F.2d 1177 (D.C.Cir. 1987)
American Petroleum Institute v. EPA (API). 906 F.2d 729 (D.C.Cir. 1990)
American Mining Congress v. EPA (AMC II). 907 F.2d 1179 (D.C.Cir. 1990)
Steel Manufacturers Association v. EPA. 27 F.3d 642 (D.C.Cir. 1994)
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[ Staff Draft-For Discussion Purposes Only 1
Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Corrective Action
Concern Under current RCRA requirements, hazardous wastes from cleanup
activities (e.g., corrective action and related activities) are subject to
the same permitting, treatment, disposal and other requirements as
newly generated and managed hazardous waste. However, many of
the requirements for as-generated hazardous wastes are inappropriate
for soil and groundwater contaminated with such wastes, and EPA
may lack sufficient authority to modify these requirements. The
application of full RCRA hazardous waste requirements to cleanup
wastes may act as a disincentive for cleanup, eliminate practical and
effective remedies from consideration, deter the use of innovative
technologies, and result in excessively costly cleanups.
Background
Statutory
Section 3004(m)(1) and (2)~Treatment Standards for Wastes Subject to
Land Disposal Prohibitions
(1) ....the Administrator shall....promulgate regulations specifying
those levels or methods of treatment, if any, which substantially
diminish the toxicity of the waste or substantially reduce the
likelihood of migration of hazardous constituents from the waste so
that short-term and long-term threats to human health and the
environment are minimized.
Section 3004(u)--Continuing Releases at Permitted Facilities
Standards promulgated under this section shall require, and a permit
issued....by the Administrator or state shall require, corrective action
of all releases of hazardous waste or constituents from any solid
waste management unit at a treatment, storage, or disposal facility
seeking a permit under this subtitle, regardless of when the waste
was placed in such unit. Permits issued under section 3005 shall
contain schedules of compliance for such corrective action (which
such corrective action cannot be completed prior to issuance of a
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[ Staff Draft-For Discussion Purposes Only 1
permit) and assurances of financial responsibility for completing such
corrective action.
Regulatory
Title 40, Code of Federal Regulation, Parts 264, 265, 266, 267, 270, 271
Judicial
No specific cites.
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[ Staff Draft-For Discussion Purposes Only 1
t
Resource Conservation and Recovery Act
Issue for Discussion Regarding
Legislative Action
Topic Hazardous Waste Manifest
Concern EPA may lack clear statutory authority to provide flexibility to the
manifest system in order to provide significant reductions in paper
work burdens.
Background
Statutory
Section 3002(a)(5)--Standards Applicable to Generators of Hazardous Waste
Such standards shall establish requirements respecting—....use of a
manifest system or any other reasonable means necessary to assure that all
such hazardous waste generated is designated for treatment, storage, or
disposal in and arrives at, treatment, storage, or disposal facilities (other
than facilities on the premises where the waste is generated) for which a
permit has been issued as provided in this subtitle...
Regulatory
Title 40, Code of Federal Regulation, Parts 262.
Judicial
No specific cites.
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