United States
             Environmental Protection
             Agency
               OH.ce of
               Soi
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          United States environmental Protection Agency
                Washington. DC 20460
OSWER Directive initiation Request
                                                              1. Directive Number

                                                                 9936.3
                                2. Originator Information
      Name of Contact Person
       Nancy Parkinson
                 Mail Code
                  OS-520
Office
  OWPE
Telephone Code
475-9325
      3. Title
        Enforcement of  Authorized State Laws Pursuant to 40 CFR Section  271.1
        Formal Comments on State Requirements Applicable to Facility  Permits
      4. Summary o( Directive (include bnef statement of purpose)                                 .     ,
        To encourage  the  Regions to submit comment letters on State  issued
        permits under 40  CFR 271.19 if a State permit condition  is  inconsistent
        with the approved State RCRA program, and to provide guidance  on
        drafting the  comment letters.
      5. Keywords
         271.19 comment  letters, permit by ambush
      6a. Does This Directive Supersede Previous Directive(s)?
      b. Does It Supplement Previous Directive(s)?
                                          No
                                          No
                                Yes   What directive (number, title)
                                Yes   What directive (number, title)
      rjDratt Level
          A - Signed by AATOAA
            B - Signed by Office Director
      C - For Review & Comment
         > - th D«vetepment
8. Document to be distributed to States by Headquarters?


Yes
X

No
This Request Meets OSWER- Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
10. Name and
Title of Approving Official
Date
Date
     EPA Form 1315-17 (Rev. 5-47) Previous editions are obsolete.
   OSWER           OSWER              OSWER              O
VE     DIRECTIVE         DIRECTIVE        DIRECTIVE

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             WASHINGTON, D.C. 20460
                               JW24W
                                                              -ifs-i-s -s

                                                      SOL'D ,VA3" A
 MEMORANDUM

 SUBJECT:    Enforcement of Authorized State Laws Pursuant to
            40 CFR Section 271.19 - Formal Comments  on State
            Requirements Applicable to Facility Permits
 FROM:       Bruce M.  Diamond, Directors;
              Office of Waste Programs Enforcement

 TO:         Hazardous Waste Division Directors
            Regions I-X

     We have recently had several inquiries into EPA's enforcement
 capabilities pursuant to 40 CFR Section 271.19(e)(2).   That section
 states  "the Regional Administrator may take action under Section
 3008(a)(3)  of RCRA against a holder of a State-issued  permit at any
 time on the ground that the permittee is not complying with a
 condition that the Regional Administrator in commenting on the
 permit  application or draft permit stated was necessary to
 implement approved State program requirements."   This  section
 applies whether or not the condition colnmented on by the Region was
 included in the final permit.   Because Section 271.19  is a very
 important and little understood provision,  we would like to provide
 some initial guidance on how that section should be interpreted and
 implemented.

     We want to encourage the Regions to provide comment letters as
 required under Section 271.19 if a State permit  condition is
 inconsistent with the approved State RCRA program (i.e., the
 conditions  imposed by the State in the permit do not address, or
 fail to address adequately,  specific Authorized  State
 requirements).   We expect that in most cases, the Region will be
 able to work with the State to resolve the inconsistency.  If,
however,  the State issues the final*'permit without including the
requirement commented on by EPA,  the Agency has  the right to
enforce  the State law requiring that condition pursuant to 40 CFR
Section  271.19(e)(2).

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                                 -2-

      The comment letters must be written and  submitted to the State
 during the comment period of the draft permit in order for EPA to
 preserve its right in the future to take action to enforce the
 State requirements that the draft permit fails to adequately
 address.  The letter also serves to advise  the State as to how EPA
 believes the permit could be modified so that a facility complying
 with the permit also would comply with the  identified State
 requirements.  If a State drafts a permit and EPA does not submit a
 comment letter pursuant to Section 271.19,  then, after the final
 permit is issued, EPA is estopped from taking an enforcement action
 against that facility for a violation of a  requirement that is not
 a condition of the permit (even if the facility is in violation of
 State law).  This is commonly referred to as  "permit-as-shield,"
 pursuant to 40 CFR Section 270.4(a).

      The comment letters must be carefully  worded because EPA's
 position is that the letters are not final  agency actions, but
 merely preliminary interpretations of State law.  The letters do
 not  by themselves impose anv requirements on  the facility.  The
 sole effect of the letter, with one possible  exception noted below,
 is to preserve EPA's ability to enforce underlying State
 requirements against State-issued permit holders.  Thus, the
 letters are merely preliminary enforcement  interpretations, not
 rising to the level of even a notice of violation.

      It is,  therefore, important to remember  several things in
 drafting the comment letters.  First,  EPA is  not enforcing the
 comments (on the permit)  contained in the comment letter.  EPA, in
 issuing a Section 3008(a)  action subsequent to permit issuance,
 will  be enforcing the State laws that are identified in the letter
 which are equivalent to the Federal laws.1

      Second,  because EPA will be enforcing  State laws, the comment
 letters should cite the equivalent authorized State laws. The
 letters should indicate why EPA believes that the facility would
 not comply with the State requirements even  if the facility complies
 with  the terms of the draft permit.
        Recent judicial  and administrative decisions support the
position that EPA  can  enforce State law.   See Conservation Chemical
Co. of Illinois v.  EPA.  660 F.  SUPP.  1236  fN.D.  Ind. 19871.  and In
the Matter of CID-Chemical  Waste Management of Illinois.  Inc.
(Appeal No. 87-11)  (indicating that authorized State programs,
including the regulations issued to implement such programs, are
requirements of Subtitle C  of RCRA within  the meaning of Section
3008(a)(1), and that EPA retains authority to enforce such
requirements pursuant  to Section 3008(a)(2)).

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                                 -3-

      Third, in the comment letter,  EPA should  not  cite to 40 CFR
 Part 265 and authorized equivalent  requirements.   Interim status
 requirements do not apply to permit holders  and the  potential
 violations identified in the comment letter  can be only violations
 of applicable permit-holder requirements.

      Fourth, EPA's action in preserving its  enforcement authority
 may be subjected to legal challenge.  We are currently awaiting the
 outcome of such a case in Region V, which may  affect many of our
 positions on the scope and applicability of  the Section 271.19
 regulations.2   Thus,  EPA should  compile  at the time the letter is
 drafted sufficient .information to.form. an_administrative _record_on_
 which to defend EPA's preliminary interpretation of  State
 requirements.

      Although the letter itself is  preliminary, related actions may
 have definite impacts on the facility and be ripe  for review.
 Examples of such actions would be the issuance of  a  compliance
 order premised upon retained enforcement authority pursuant to the
 Section 271.19 letter,  and off-site policy determinations under
 Superfund for violations of State regulations  identified in the
 Section 271.19 letter.   The Section 271.19 letter  would become part
 of the record for these related actions.  Furthermore, once EPA has
 taken one of these actions,  the owner or operator  of the affected
 facility may succeed in arguing that the Section 271.19 letter
 itself is ripe for review.   Again,  EPA will  be in  a  better position
 to defend against these types of challenges  if it  has prepared a
 record to support its finding that  the permit  is inconsistent with
 underlying State law.
         In that  case, Waste Management of Illinois,  Inc.  (WMI)  has
filed a  motion in U.S.  District Court*seeking a declaratory
judgment that EPA cannot  impose conditions on the facility pursuant
to a Section 271.19  comment letter ^and could not take an
enforcement action based  upon  comments in such a letter.   The suit
also claims that the Section 271.19  procedure violates WMI's rights
to due process under State  and Federal law.   EPA has not  yet taken
an enforcement action,  although Region V has written a letter
commenting on the draft permit,  pursuant to Section  271.19.  The
State responded  by providing a contrary interpretation of State
requirements and by  issuing the permit containing the terms of the
draft.   EPA has  claimed that WMI's challenge of EPA's potential
exercise of enforcement authority to enforce State law after
comment pursuant to  Section 271.19 is not ripe for judicial review,
and may not be ripe  until EPA  has initiated an enforcement action
against WMI.

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                                 -4-

      In  the off-site policy example, a Section 271.19 letter may be
needed to  establish that a  facility  is ineligible to receive wastes
under the  off-site policy.   If  a facility is in compliance with'its
permit and no  longer subject to interim status requirements,
technically no violations can be enforced by EPA at the facility
even  though the facility may have been in violation of interim
status requirements and may currently be in violation of state
permitting requirements.  Thus,  if a 271.19 letter is not
submitted,  the facility may be  eligible to .receive off-site waste
even  though it is  in violation  of State permitting requirements
(because it is in  compliance with its permit) .

      Because of impacts on  future enforcement cases and off-site
determinations,  the Region  should, when reviewing draft permits,
determine  whether  the permit conditions are consistent with the
underlying State permit regulations, and file a timely comment
letter where inconsistencies occur.  After filing the comment, the
Region should  review both the final  permit and any actions taken by
the facility to comply with the identified underlying permit
requirements,  and  should keep these  reviews in mind when
considering enforcement and off-site policy decisions and the
facility's  transition from  interim to permitted status.

     The above are preliminary  considerations on comment letters
and enforcement actions pursuant to  40 CFR Section 271.19.  We will
keep the Regions advised of any upcoming changes or new insights
resulting  from a decision in the WMI case.  In the meantime,  if you
have any questions,  please  call me or contact Nancy Parkinson
(OWPE, 475-9325) or Josh Sarnoff (OGC, 382-7706).

cc:  Regional  Counsels
  /   Regions I-X

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