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v>EPA
Wasnmgton. DC 20460
OSWER Directive Initiation Request
9502.00.4 ,
Cf'3-naior info'ma'. on
Name of Contact Person
Dave Facan
Man Coae -
WH563
Branch
Teleonone-Numoer
382-^740
Lead OHice
D OERR
LE OSW
D OUST
LJ OWPE
LJ AA-OSWER
Approved 'or Review
Signature ot O'dce Director
Oaie
Title
Implementation of RCRA Facility Assessments
Summary ot Directive
Guidance on completing RCRA Facility Assessments prior to
issuance of permits
Key Words:
RCRA Facility Assessment (RFA); Corrective Action; Permit requirements
Typ« of Directive lM»nu»l, Policy Dtrtctne. Announttmtnt. lie.)
Memo to Regions
' Status
I
D Dr.ft
IT!
Final
Lit New
LJ
Ooestriis Oirectiv« Supersede Prtvious Direcnveis;' |__j Yes
II "Yts" to Either Question. What Directive InumOer. tnlei
Ho Oo«s tt Supplement Previous
Ye*
No
Review Plan
LJ AA-OSWER
O OERR
LJ OSW
D OUST
D OWPE
LJ Regions
D OECM
D OGC
LJ OPPE
D
This Request Meets OSWER Directives Svstem Format
pf LeaC Office Directives
' Due
irectives Officer
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UNITED STATES ENVIRONMENTAL PROTECTION AGEftRSJt'i POLICY niHi-UlUt
WASHINGTON, D.C. 20460 . f* *
9502 .00- i s
AUG 2 I 1986
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Implenientatianc£_ RCRA Facility Assessments
FROM: J. Vfirftston Porter, Assistant Administrator
Office of Solid Waste and Emergency Response
TO: Hazardous Waste Division Directors, Regions I-X
The purpose of this memorandum is to clarify existing
policy and to provide further guidance on implementation of
RCRA Facility Assessments ( RFAs } in the RCRA permit and the
RCRA enforcement programs in the Regions.
As outlined in previous guidances, as well as in the
FY 86 and FY 87 RIPs, the RCRA Facility Assessment (formerly
referred to as PA/SI) is designed to be the first step in
the process of implementing the RCRA corrective action process.
The general function of the RFA is to provide the basis for
the Agency to make preliminary determinations as to Whether
or not there are, or are likely to be, releases of concern
at a facility. The RFA also assists in determining Whether
or not, and what types of, further investigations or interim
measures should be required cf the owne r /opera tor .
It is in the Agency's interest, and the public's interest,
to have made an overall assessment of actual and potential
environmental problems from all sources at a facility, and to
have determined, before issuing a permit, what investigations
must be initiated at the facility to characterize the nature
and extent of the contamination. Each of the Regions has
begun to initiate some number of RFAs. It is our understanding,
however, that the RFAs being conducted by the Regions and
States vary significantly in terms of their technical approach
and completeness. In particular, sampling and analysis,
which will often be necessary in making determinations in an
RFA, is in some cases not being done before the permit is
issued. In other cases, RFAs have not been conducted at all
prior to issuing permits.
An RFA should be completed before issuance of a RCRA
permit. A "complete" RFA will typically include a site visit
as well as any sampling and analysis required to make the
necessary determinations in the RFA. It should be understood
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that, for the purposes of SPMS tracking, only complete RFAs , .-rff.
will Jje counted as accomplishments. . ' "
If properly planned and executed, an RFA can be completed
within a relatively short time frame (three months or less).
Since RFAs can be conducted concurrently with other permit review
activities, we believe that doing RFAs prior to permitting should
have little impact on permit issuance schedules. There may be
some facilities, however, which are scheduled to receive draft
permits in the next several months (i.e., this calendar year),
but for which an RFA has not been initiated. If completing an
RFA for such facilities is likely to substantially delay issuance
of the final permit, Regions may consider having the necessary
sampling and analysis portion of the RFA done after permit
issuance, under a schedule of compliance. In such cases, however,
the Preliminary Review and Visual Site Inspection portions of the
RFA should be completed before the permit is issued.
It may also be appropriate to conduct an RFA before taking
action under RCRA Section 3008(h), the Interim Status Corrective
Action Authority. Information from the RFA can provide evidence
necessary to meet §3008(h) criteria where it is not otherwise
available, and can provide information necessary to properly
scope an order. We recognize, however, that it may not be
possible to conduct an RFA prior to issuing an order in cases
where there is a need to initiate such an action quickly or
when a facility is not a current RFA priority. RFA priorities
for FY 1987 are all operating land disposal facilities scheduled
for permit issuance by November 1988, and 30 percent of the
closing land disposal facilities.
Previous guidance has expressed a preference for requiring
owner/opera tors to perform sampling and analysis which may be
required to complete an RFA. It should be understood that while
owner/operator support, if it can be secured on a timely basis,
is encouraged, owner/operator support should not be sought if it
cannot be expected to be timely or reliable. Regions have been
provided substantial extramural funds to perform RFAs. These
funds should be used as necessary to assure timely completion
of comprehensive RFAs.
We recognize that completing RFAs prior to issuance of
permits may have some implications in terms of timing and
resources for certain facilities. We ask that Regions communicate
any concerns regarding this policy to Dave Fagan (OSW) at FTS
382-4692.
cc: Regional Hazardous Waste Branch Chiefs
Regional RCRA Permit Section Chiefs
Regional RCRA Enforcement Section Chiefs
M. Williams
G. Lucero
B. Weddle
L. Guerci
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