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          IPA
         United States Environmental Protection Agency
               Washington, DC 20460
OSWER Directive Initiation Request
                  1. Directive Number
                       9938.3
                                2. Originator Information
      Name of Contact Person
          Emily  S.  Chow
                 Mail Code
                  WH-527
Office
 OWPE,  RED
      3. Title
           RCRA  Technical  Case  Development  Guidance Document
      4. Summary of Directive (include brief statement of purpose)
            The  Technical  Case Development  Guidance Document will provide
       guidance  to RCRA inspectors, compliance officers/ case developers/ and
       other  enforcement personnel  in the development of RCRA enforcement cases
       It  includes overview of case development process/ rules of evidence/
       inspection  and on-site  sampling procedures.
      5. Keywords
         Inspector/ Enforcement Officer/ Case development/ Enforcement case,
      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)
      7. Draft Level
          A - Signed by AA/DAA
            B - Signed by Office Director
      C - For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters?
X

Yes


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. 5-87) Previous editions are obsolete.
   OSWER          OSWER              OSWER             O
YE    DIRECTIVE         DIRECTIVE        DIRECTIVE

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 MEMORANDOM

    SUBJECT:

       PROM:


         TO:
              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C. 20460
                                  I 3 1938
                                                          OFFICE OF
                                                  SOLID WASTE AND EMERGENCY RESPOf
 CRA, Technical/fl-ase Development Guidance Document
               .
      stfcn Pcrter
 issistant Administrator

Waste Management Division Directors
Environmental Services Division Directors
Regions I-X
     Attached  is  the  final  RCRA Technical Case Development
Guidance  Document.  This document is designed to assist the
Regional  and State  enforcement  personnel in developing
enforcement cases.  Besides a detailed description of the case
development procedures/  the document also included a list of the
technical resources available to the enforcement personnel.

     The  development  of  this guidance document .was assisted by a
workgroup composed  of both  technical and legal staff from the
Regions and the State/ and  staff from the Office of Enforcement
and Compliance Monitoring/  the  Office of General Counsel/ the
CERCLA Enforcement  Division/ the Environmental Response Team/ and
the National Enforcement Investigations Center.

     The document will assist RCRA inspectors and enforcement
personnel to:

     o  understand  the overall  case development process

     o  adequately  prepare  for  and conduct inspections at RCRA
        facilities

     o  properly collect appropriate evidence for potential
        enforcement actions

     o  properly handle'and organize enforcement files
     o  provide technical  assistance to legal counsels during
        enforcement actions

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                               -2-
     This guidance document  is  the first comprehensive document
that combines enforcement-related information from various
sources into a single volume.   This document provides the
enforcement personnel all the essential information needed for
developing enforcement cases/ and it complements the other
enforcement documents and guidances.      ;,

     If you have questions on the RCRA Technical Case Development
Guidance Document/ please call.Bruce Potoka (FTS-382-2270) or
Emily Chow (PTS-475-9329)/ RCRA Enforcement Division.

Attachment

cc:  Hazardous Waste Branch  Chiefs/ Regions I-X
     RCRA Enforcement Section Chiefs/ Regions I-X

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