v>EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
TITLE: i: RCRA Permits for Superfund Sites
i
APPROVAL DATE:!: n/is/83
EFFECTIVE DATE: : n/15/83
ORIGINATING OFFICE:
0 FINAL
D DRAFT
STATUS:
osw
[ I
A- Pending OMB approval '
[ ] B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- In development or circulating
headquarters
REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE D
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Wasnmgton. uC 20*60
OSWER Directive Initiation Request
00.02 03
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Name of Contact Person
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Mail Code — Branch Telephone f«umoer
new
Acc'oveo f?r Review
Signature ot 0"'ce Director , Date
T,tie
RCRA Permits for Superfund Sites
Summary of Directive
Coordination between the RCRA and Superfund Programs is of utmost importance
for the Agency. Currently, general policy is that all CERCLA actions, in-
cluding those actions subject to a consent decree, should comply with RCRA
technical standards.
Any hazardous waste removed off-site from a CERCLA si"; must be manifested and
sent to be permitted facility or one with interim status under RCRA. Any such
facility msut have undergone a RCRA compliance inspection within the last six
months,* and violations that can adversely affect the facility's performance
must be corrected before a contract can be awarded.
It should be noted that neither Regional nor Headquarter's RCRA resources have
been budget to review and evaluate CERCLA actions for compliance with RCRA.
Therefore, Regional Superfund staff must become faciliar with RCRA regulations
in order to evaluate CERCLA sites for RCRA compliance._ SEE ATTACHED
Key Words:
Permit
vpe oi Directive iManuai. Policy Oirectme. Announcement, etc.i
Status
D
D
New
Does tnis Directive Suo«r»ea« Prtvious Oi'eetiveis,' | | Yes
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cow Plan
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Pequesi Meets OSWER Directives Svstem Format
ot Lead 0">ce Directives O'ticer
Date
'e of OSWER Directives Otdcer
• Date
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.'n.i-- i'j-...-; • • ' • • .
Wasnmgion. L/C 20460
wEPA OSWER Directive Initiation Request
Name of Contact Person
Code - Branch
Lead Office
O OERR
D OSW
G OUST
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D AA-OSWER
Review
Signature ot Office Director
One
Tills
Su.-nrnarv ot Directive
*The original memo required a compliance inspection within 12 months. This
memo was supereeded by a May 6, 1985, memorandum issued by the Office of
Waste Programs Enforcement: Procedures for Planning and Implementation off-
site Response Actions. . ,
Key Words:
ype of Directive iMgnuai. Policy Oirtctive. Announcement, etc.i
Siatus
Draft
D Pmai
L_; ,\ew
LJ Revision
Does tnis Oireedve Sup«rs*c» Prtvious Oi'eeiive:s,' [ | Yes [_J No Does it SuDO'emeni Previous Oirective
f "Yes" to Either Question. What Directive inumoer. titlei
flev>ew Plan
D AA-OSWER CD OUST
D OERR D OWPE
Li OSW D Regions
D OECM
D OGC
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D
Other ;Soeci/yl
>-s Bequest Meets OaWER Directives System Format
of Leao Off.ce Directives Officer
: Date
* of OSWER Directives Officer
Date
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NOV ! 5 1983
.SUBJECT: *CRA Permits for Suporfund Sites
/s/ ^a$£.W. McGraw
PROMi Las *. Thosnas
Assistant Administrator (WH-e cvanifested and sent to a hazardous waste
^ana^etaant ^fctfility permitted, or with interim status, under =>CSA.
PHI v rm~»>iD|i .^yil *B«fe tacllity must have undergone a RC^A compliance
inspectleti^i^ll* «h« last 12 months ancJ violations trvat c»n adversely
aff»ct the facility's performance wust t>« corrected before a contract
can b« awarded. A copy of thia metaorandum was attached to the PY
RCRA Guidance dated July 21, 1983.
It «HJ«t be recognized that neither Regional nor Headquarters
<*CRA resources have h««n budgeted to review and evaluate CEKCLA
actions for co«plianc« with RCRA. This responsibility falls to the
CEHCLA program staff as part of their norms! activities! however, I
will seek tha advice of the Office of Solid wast* in appropriate
cases whan RQDs ara presented to •• for decision,
r
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