United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
     vvEPA
DIRECTIVE NUMBER:  9522.03(34)

TITLE: -  Issuance of RCRA Permits to Facility Owners and
      Operators
               APPROVAL DATE::-- 7-30-84

               EFFECTIVE DATE::? 7-30-84
               ORIGINATING OFFICE

               0 FINAL

               D DRAFT

                 STATUS:*:
                Office of Solid Waste
            I  1
                           [  ]
                           [  ]
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      . i .•/• headquarters
  OSWER       OSWER      OSWER
fE    DIRECTIVE   DIRECTIVE

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PART 270  SUBPART A - GENERAL INFORMATION
                                                              DOC:  9522.03(34)
Key Words:    RCRA Permits

Regulations:  40 CFR 270.l(c), 270.10(b)

Subject:      Issuance of RCRA Permits to Facility Owners and Operators

              Regional Division Directors, Regions I-X

              John Skinner, Director, Office of Solid Waste

              #9522.03(84)

              7-30-84
Addressee:

Originator:

Source Doc:

Date:

Summary:
     All RCRA permits must be issued to both the owner and operator of a facility
even where the facility is owned by one person and operated by another.

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                          30 JUL  1984
MEMORANDUM
SUBJECTt  Issuance of RCRA Permits to Facility Owners and Operators

PROMi     John Skinner
          Director, Office of Solid Waste (WH-S63)

TOi       Regional Division Directors, Region* I-X   "v-


     This Office continue* to learn of -RCRA permits being issued
only to facility operators in those instances where the facility
operator and the facility owner are different people.  Section
270.l(c) requires that "owners and operators of hazardous waste
management units must have permits during the active life (includ-
ing closure) of the facility....*  In addition, S270.10(b)
requires the operator to apply for the permit and the owner to
sign the application along with the operator when the facility
operator and owner are different persons (see $270.10(5)).

     Please ensure in the future that all RCRA permits are issued
to both the owner and operator of the facility in those cases
where the facility is owned by one person and operated by another.
WH-563:CMiller:sed:S243:382-4692:7/23/84:Disfc  Chaz  4  *3

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