'MISCELLANEOUS . DOC: 9560.oi(85)
Key Words: RSI, HSWA'
Regulations:
Subject: The Use and Nature of RSIs
Addressee: N/A
Originator: Bruce R. Weddle, Director, Permits and State Program Division
Source Doc: #9560.01(85)
Date: 1-8-85
Summary:
RCRA Reauthorization Statutory Interpretations (RSIs) embody both a system
and a type of communications tool. The RSI system consists of a series of
policy memoranda that summarize the major policy decisions related to specific
areas of reauthorization implementation. There are three purposes of the
system:
1) To ensure that the same key people routinely receive reauthorization
instructions;
2) To ensure that these policy instructions can be tracked so that, if
and when they are superseded (or supplemented) by subsequent guidance,
the recipient understands the linkage; and
3) To provide a mechanism for tracking the distribution of technical
guidance as well as policy guidance so that, when subsequent guidance
is published which overrides an earlier document, it can be noted.
In addition to traditional policy guidance, RSIs will accompany technical
guidance documents in order to explain the policy decisions that "implement the
technical documents.
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UNITED ST« JVIRONMENTAL PROTECTION AGENCY 9560.01 (85)
. .5HINGTON, D.C. 20460
*-*to OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: RCRA Reautharization Statutory Interpretations
FROM: Bruce R. Wdddle
Director
Permits and State Programs Division (WH-563)
TO: • Addressees
Several questions have been raised concerning implementation
of Lee Thomas's December 5 memo on RCRA Reauthorization Statutory
Interpretation's. The purpose of this memorandum is to clarify
the use and'nature'of RSI's.
The December 5 memorandum from Lee Thomas outlines both a
system and a type of communications tool, designed to ensure
that interpretations and guidance reach the right people v/itn
needed information. The purpose of the system is threefold:
1. To ensure that the same key people routinely
receive reauthorization instructions;
2. -To ensure that these policy instructions can be tracked
so that if and when they are superceded (or supplemented)
by subsequent guidance the recipient understands the
the linkage.
3. To provide a mechanism for tracking the distribution of
technical guidance as well as policy guidance, so that
when subsequent guidance is published which overrides
an earlier document it can be so noted.
The system is similar in nature to that employed in
distributing Program Implementation Guidance (PIG's), an!
includes'numbering, dating, and distribution to a routine
mailing list. Truett DeGeare is the contact within the Permits
and State Program Division-for assigning a number for RSI's
that are ready to be issued, and for obtaining a distribution
list.
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Ail policy statements .major and minor) signed by .the
Assistant Administrator (or the Administrator) should be part
of the RSI system. These statements //ill vary in length (frcrr,
one page to twenty) and in scope (a single issue, or several
issues under a single generic topic). They will have in common,
however, that they implement an aspect of RCRA reauthorization.
The new communications tool that we are creating with the
RSI system is a series of policy memoranda that suc'cincrly
summarize the major policy decisions related to specific areas
of reauthorization implementation. When the policy memorandum
is a free standing document (an independent guidance document,
such as one on Joint Permitting), it is simply policy guidance
in a memorandum format. It is no different than numerous policy
memoranda the agency has traditionally mailed to Regions and
States, except that it is called a Reauthorization Statutory
Interpretation and is numbered and tracked as such.
When the policy memoranda is associated with or accompanies
a technical guidance a new kind of policy document is created.
This document is designed to achieve two objectives:
0 To focus attention on the policy decisions that
are implicit or explicit_ln technical guidance, as
well as those other policy decisions that implement
the technical guidance; and
0 To recognize that there are differing (if overlapping)
audiences for technical and policy guidance and to
ensure effective communication with those audiences
most concerned with implementing policy.
The .RSI does not simply "transmit" the technical document, but
also .explains the policy decisions that implement the technical
document. For example, the technical document on minimum technology
requirements describes-how to construct a double 'liner (including
the preferred composit liner, the required leachate collection
recovery system, and a derailed quality assurance plan). The
accompanying-RSI (not yet released in draft form) will address
important policy decisions (applicability of provisions, implementa-
tion of good faith installation of liners, variances, notification
requirements,.etc.). In addition the RSI will summarize the
policy decision inherent in the technical guidance (e.g. the
performance standard that the technical guidance must meet, and
the preference" for a composit liner as the means of meeting that
standard).
Addressees: OSW Senior Staff
OSW/OWPE Branch Chiefs
OSW/OWPE Program Managers
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