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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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