UniMdSUtes
Environmental Protection
Agency
Off.ce of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER:
9938-5
TITLE:, Enforcement Strategy for the Land Disposal
'.Restrictions First Third Rule
- -""'
1 ' , i
APPROVAL DATE: JAN 23 IS89
EFFECTIVE DATE: JAN 23 1989
ORIGINATING OFFICE: OWPE
0 FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
-08 — Signed by Office Director
-• •;• Q C —.Review & Comment
REFERENCE (other documents):
* Note to MARY ESCAWLLE and Regions. I - X
* This Directive 9938x5?;-aj^4;onlY.r6l^&sable, •"
' feis*. 552,
>exemption b (7) (E). . .>,•,.
WER QS WEfi OS WER
DIRECTIVE D!
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Washington DC 20480
OSWER Directive initiation Request
11. Direct** Number
Z. Originator Information
Name of Contact Petto*
Jim
Hays
Mail Code
OS-520
2439
QWPE/RED/GEB
Telephone Codt
475-9329
3. Title
Enfor'
First
V Strategy Land Disposal Restrictions
Rule
4. Summary of Directive (include brief statement of purpose) .... . c e j
This directive presents guidelines to use in identifying the affected
universe, targeting inspections, and reviewing soft hammer certifications
and demonstrations submitted to EPA. the strategy is intended to assure
that the most significant violations of the LDR program are addressed.
5. Keywords
inspections, Land Disposal Restrictions, soft hammer, enforcement
St. Does This Directive Supersede rrevious mrecuve(s).'
b. Does It Supplement Previous Oirective(s)?
I X I No I I Yes What directive (number. We)
No
Yes What directive (number. We)
r. 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?
—
Yes | X | No
This Request Meets OSWER Directives System Format Standards.
9. Signature oHLead Office Directives Coordinator
&&£«*. /J^g^J
10. Name and Title of Approving Official
Date
//^?
Date
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER f OSWER ' OSWER O
IE DIRECTIVE DIRECTIVE DIRECTIVE
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9938.5
ENFORCEMENT STRATEGY
LAND DISPOSAL RESTRICTIONS
FIRST THIRD RULE
Environmental Protection Agency
Office of Waste Programs Enforcement
December 16, 1988
ENFORCEMENT CONFIDENTIAL
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ENFORCEMENT 20OTENTIAL
9938-5
I. Introduction
The Hazardous and Solid Waste Amendments (HSWA) to the Resource
Conservation and Recovery Act (KCRA) enacted on November 8, 1984, included
amendments requiring EPA to evaluate all hazardous wastes according to a
strict schedule to determine whether land disposal of these wastes is
protective of human health and the environment. EPA is setting levels or
methods of treatment which substantially diminish the waste's toxicity or
reduce the likelihood that the waste's hazardous constituents will migrate.
Wastes that do not meet these treatment standards are prohibited from land
disposal.
The following strategy is intended to assist the Regions and States in
implementing the Land Disposal Restrictions (I£R) First Third Rule. This
strategy primarily provides guidelines for Regions and States to use in
identifying the affected universe, targeting inspections, and reviewing
"soft haittner" certifications/demonstrations submitted to EPA. The strategy
is also intended to assure that the most significant violations of the
land disposal restrictions program are identified and that appropriate
enforcement response is pursued.
Under HSWA, had EPA failed to promulgate treatment standards for
solvent, dioxin, or California List wastes by the applicable statutory
deadline, these wastes would have been prohibited from any land disposal .
However, where the Agency has not promulgated treatment standards for First
Third wastes, the statute allows land disposal of the wastes, provided that
if the waste is land disposed in a landfill or surface impoundment, the
following requirements are
(1) the unit in which the waste is placed must meet the minijiun -
technological requirements (i.e. double liners, leachate collection
systems, and ground water monitoring) or be exempt from such
requirements pursuant to RCRA sections 3004 (o) (2) , 3005(j) (2) or
(j)(4); and
(2) the generator most certify to the Regional Administrator that he has
made a good faith effort to locate and contract with treatment and
recovery facilities practically available which provide the greatest
environmental benefit.
These demonstrations and certifications should be submitted by -the
generator to the Region where the waste(s) is generated. In sane cases the
generator may forward the demonstration/certification to EPA Headquarters.
Headquarters will in turn, forward the information to the Region where the
generator is located. Each Region should review the certifications for
1 When such wastes are land disposed in units other than landfills and
surface iirpDundments (e.g., waste piles, land treatment units), these
requirements do not apply.
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9938.5
completeness and accuracy by evaluating the general Regional conditions and
identifying actual treatment available. The Regional office where the
specific generator is located has the responsibility for determining
whether the information meets the regulatory soft hammer provisions. A
national directory of commercial hazardous waste management facilities will
be sent to all Regions to assist in these evaluations. Information
acquired from "soft hammer" certifications/demonstrations received will be
a continuing source of information on the actual availability of treatr-ient
in a Region.
Regions should consider developing a database on treatment available
for particular industries and waste codes to supplement the national
directory. Furthermore, sharing of such information among the Regions
would be most beneficial. The Regions should also contact States and
review State or biennial reports to further identify "soft hammer"
treatment capacity available. A more detailed discussion on the "soft
hammer" certification review process will be given in section III.
II. Universe and Inspection Targeting
1. INSPECTION TARGETING
The First Third rule addresses a number of RCRA wastes which, for the
large part, are associated with particular industry segments (the exception
to this being the P and U wastes) . In targeting facilities for
inspection, it is important to consider a wide variety of factors which
determine the responsibilities of the industry, and its probable response
to the requirements of this rule. These considerations include, but are
not limited to: the status of the industry (waste generator, treater,
storage facility, or disposer) , the capability for and availability of
on-site storage, treatment and disposal of First Third wastes, and current
industry waste management practices. In many cases, information necessary
to characterize an industry may be available to the enforcement staff
through a permit or Part B permit application. Additional information on
industry characterization may be obtained if a RCRA Facility Assessment
has been completed at the facility.
This inspection strategy resulted from consideration of each of the
above-mentioned targeting considerations. The universe of affected
facilities was identified, the characteristics of wastes were investigated
(wastewater vs. ncnwastewater) , and the treatment technologies currently
employed by the affected industries were reviewed.
The type of treatment technologies currently employed is of importance
because, to the extent that existing treatment technologies will achieve
compliance with Best Demonstrated Available Technologies (BOAT) standards,
the facilities can be expected to continue their current practices, and
likely pose a lesser compliance problem. Where technologies designated as
BDftT are not currently in widespread use, and the treatment in place will
hot achieve treatment standards, industry will have to either make process
changes, or change their treatment practices (onsite or off site) . Where
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ENFORCEMENT CONFIDENTIAL
9938.5
such changes (and possibly added expenses) are incurred, the possibility of
compliance problems increase.
Table 1 lists the twelve industries primarily affected by the First
Third rule. It may be seen from this table that the number of wastes
regulated under each industry group varies from one to thirteen. However
some of these wastes may be more ubiquitous than others. For example,
bottom sediment sludges from the treatment of wastewaters from wood
preserving processes using creosote and/or pentachlorophenol (K001) is
edition to the wood preserving industry. By comparison, a relatively small
percentage of organic chemical plants generates distillation bottom tars
from the production of phenol/acetone from cumene (K022). Realizing that
thesa differences exist, the inspection strategy must be sensitive to the
number of facilities within each regulated industry. On the other hand,
large volumes of regulated wastes may be generated by a relatively few
plants. Thus, both the size of the regulated community and the volume of
wastes generated must be taken into consideration when developing and
refining inspection priorities.
The BOAT standards for wastewater categories include the following
treatment technologies: steam stripping, solvent extraction, chlorine
oxidation, and stabilization. Solvent extraction and steam stripping are
already employed by some industries for recycle/recovery purposes as the
result of internal incentives, e.g., the recovery of process residues from
the production of aniline (K103). These onsite technologies likely will
continue. Also, facility treatanent units are available for wastewater
treatment. Many facilities may be conducting onsite treatment of First
Third wastes without being subject to RCPA permitting requirements using
boilers, furnaces, distillation units, waste-water treatment tanks, etc..
If the waste introduced into these "RCRA exempt" units is restricted, then
any process residues also would be a restricted material based on the
"derived from" rule. Furthermore, the facility treating a restricted waste
in such units must comply with all LCR requirements (e.g. waste analysis,
notifications, certifications) placed on a regulated treatanent facility.
Approximately 10 to 20 percent of the organic chemical plants are
classified as Treatment, Storage and Disposal Facilities (TSDFs). The
remainder of the facilities either send the waste off-site for disposal,
manage the wastes on-site in RCEA exempt units, or claim that they are not
managing hazardous wastes.
»
Other circumstances which may modify priorities include the
characteristics of the industry and the regional distribution; for example,
a high proportion of the petroleum industry facilities are TSDFs and they
are located in significant numbers in certain Regions. These should be
given priority over other generators.
The BOAT treatment standards for nonwastewaters are largely based on
combustion technologies or stabilization. Most RCRA generators do not have
RCRA permitted or interim status incinerators and stabilization
capabilities. Therefore, the likelihood for offsite management of
nonwastewaters appears greater than for wastewaters. Considering this
fact, inspection activities should recognize the importance of inspecting
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ENFORCEMENT »!lW*i 9938.5
off site commercial facilities managing nonwastewaters. Inspectors should
also be aware of the potential for the use of onsite furnaces and "sham"
energy recovery operations for illegal disposal of restricted wastes.
2. INSMat.TJ.ON PRIORITIES
The general strategy is to conduct inspections in the order of
priority stated below, recognizing that acccnmodations must be made for
site specific conditions and circumstances. Inspectors should also
consider giving priority to facilities that generate wastes subject to the
F-solvents and/or California waste provisions of the land disposal ban, in
addition to First Third wastes. Finally, inspection priorities should be
sensitive to past compliance problems at the facilities, particularly with
respect to land ban compliance.
(a) Commercial Land Disposal Facilities
As with the earlier land ban inspection strategies, commercial land
disposal facilities remain the highest priority. First Third wastes (i.e.
"soft hammer" or wastes subject to a nationwide capacity variance or case-
by-case extension) received by a landfill or surface impoundment must be
managed in a unit in compliance with -minimum technology requirements (MTRs)
or that have received an applicable waiver from MERs. The facility must
maintain copies of all generator and treatment facility certifications
including soft hammer certifications. Inspectors should assp
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ENFORCEMENT CONFIDENTIAL
**Table 1. AFFECTED INDUSTRIES BY
WASTE CODE
9938.5
INDUSTRY
LISTING OF
WASTE CODES
NO. OODES
Electroplaters
Explosives
Ink Fonnolators
Inorganic Chemicals
Iron & Steel
Organic Chemicals
Paint Manufacturing
Pesticides
Petroleum Refining
Pharmaceuticals
Secondary T^arf
Wood Preservers
F006 1
K044, K045, K046, K047 4
K086 1
*K071, K073, K106 3
K061, K062, K087 3
K015, K016, K018, K019 13
K020, K021, K022, K024
K025, K030, KD83, K103, KL04
K004, K008 2
K036, K037, K099 3
K022, *K048, *K049, *K050, 7
*K051, *K052, K087
K101, K102 2
K069, KLOO 2
K001 1
* Indicates listed wastes which have'"received an extension from the
effective date
** Table does not include "soft hamner" waste
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ENFORCEMENT SUNHULNIIAL
9938.5
demonstrations are in fact conducting treatment as specified in the
demonstration. The inspector should also review records, and conduct tests
as necessary to ensure that the appropriate treatment standards are being
applied (wastewater vs. nonwastewater).
(d) Generators
The vast majority of handlers affected by this rule are generators.
Regions should compile lists of generators of First Third wastes and cross
reference this listing with those known to generate F-solvent and
California list wastes. In some cases wastes subject to soft hammers may
also be subject to California List Halogenated Organic Compounds (HOC)
standards. In these cases, the California List prohibition levels rather
than the soft hammer provisions would apply to the waste. Table 2
presents a list of soft hammer wastes potentially subject to the California
list HOC treatment standards. Other areas of concern include the
appropriate identification of the wastes (e.g., F-solvent or K086 solvent
wash sludge), appropriate identification of treatability group, and
completion/maintenance of certification materials. Certain types of
materials may pose special problems due to continuing controversy over
waste code definitions, e.g., K051 API separator sludge from the
petroleum industry, and K001 wood preserving sludges.
There are incentives for deliberately classifying wastes under the
wrong waste code or treatability group. Two such incentives include
differences between the wastewater and nonwastewater treatment standards,
and the availability of management practices to provide the necessary
treatment.
(e) Commercial Transfer Stations and Major
These facilities are responsible for maintaining the hazardous, waste
manifests and continuing the paper trail. In addition, if these facilities
perform management of wastes by transferring the contents of hazardous
waste containers and trucks into either bulk containers or other
containers, the transporter or transfer station is responsible for
generating a new manifest and establishing the treatment standards for the
waste based on the generator's initial information. Information gathered
from the inspection of these facilities may serve to set priorities for
inspections of generators, treaters and disposers.
3.
It is intended that the land ban inspections be conducted in
conjunction with Compliance Evaluation Inspections (CEIs) performed in
accordance with the RIP. This will ensure a strong compliance monitoring
presence while minimizing costs.
Sampling and analysis resources are limited, however Contract
Laboratory Program (CLP) support is available should analyses be needed to
support an enforcement action.
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ENFORCEMENT CONFIDENTIAL
^ , 9939- 5
Table 2
•" Wastes Potentially Subject
La List HOC Treatment Standard
K017 U029 U078
K021 U036 U129
K073 U037 U130
K085 U041 U158
P004 U043 U185
P016 U044 U192
P036 U046 U209
P037 U061 U210
P050 U066 U211
P058 U067 U227
P059 U074 U228
P123 U077 U237
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ENFOfiCEMEHT CONFIDFNTIAI
HI. "Soft Bdimei* tiaste Provision
As fH'g-ii'MM'H earlier, Regions should expect to receive "soft hammer"
certifications from facilities generating "soft hammer" wastes destined for
in landfills or surface impoundments. Each region should consider
resources and tip** available in prioritizing certification/demonstration
reviews while also considering that only approximately 6% of the land
disposed First Third wastes are actually "soft hammer" wastes. A further
consideration in review selection should also be given to a handler who
may be shipping a significant volume of "soft hammer" waste to another
Region. In this situation, both Regions should coordinate in verifying the
validity of the certification/demonstration submitted. A recommended
approach would be to selectively review specific facilities of concern.
For instance, facilities with a historically bad compliance record should
be a high priority for certification review. Some other facilities which
should be considered for review are generators which are also on-site
facilities and large commercial treatment facilities which
generate "soft hammer" residuals.
There are varying conditions in a certification/ demonstration review
to consider which could potentially invalidate a facility's "soft hammer"
certification. It should be emphasized that section 268.8 clearly
specifies that the generator must make "a good faith effort to locate and
contract with treatment and recovery facilities practically available which
provide the greatest environmental benefit." The treatment hierarchy in
the August 17, 1988 rule states that recycling/recovery is the method
achieving the greatest environmental benefit followed by destruction and
stabilization technologies. Therefore, the objective in the generators
search for adequate treatment should be to look for treatment which indeed
provides the "greatest environmental benefit" and not just any treatment at
randan. The information that the Regions should utilize in evaluating the
soft hammer certification/demonstration are the following:
1. The generator has made no effort to contact and locate alternative
treatment. This certification should clearly be invalidated.
[
2. A certification/demonstration which claims no treatment available, but
the information submitted on facilities contacted does not show any
attempt to contact treatment facilities recommended or listed in the
preferred treatment hierarchy ("which provide the greatest
environmental benefit") in the preamble. The Region could invalidate
this facility's certification on grounds that at a miniirmn the
certifiar should have contacted these facilities potentially available
to hia with treatment as listed in the hierarchy and documented
whether or not treatment was available to him. Again, the Region may
either invalidate the certification or require further information
from the certifier prior to making any determination.
3. The third situation that may occur would be when the facility
certifies to the use of treatment technology not listed in the
"Appropriate Treatment Technology" Hierarchy. For example, a
facility generating a K035 sludge (nonwastewater) certifies that
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- * -- -— 9938
steam stripping is the best technology available. The hierarchy does
not list steam stripping as an appropriate treatment technology to use
for this waste. Assuming no economic burden or other impractical ity
is claimed, the Region should first (either directly or through the
generator certification) ascertain whether other treatment
technologies (i.e., incineration, wet air oxidation, biodegradation,
ash stabilization) are actually available. If other treatment is
available which provides a greater environmental benefit, a
determination must then be made as to whether this treatment should be
required. These situations must be evaluated on a case-specific basis
considering the type and volume of waste and the environmental benefit
of requiring an alternative treatment technology.
If a certification is invalidated, the generator must r»««« disposal
of the waste and immediately notify the receiving facility (if the waste
has been sent off site) of his status. The Region should confirm this with
the receiving facility.
The regulation allows for a generator to demonstrate that treatment of
"soft hammer" waste is not a "practical" alternative to land disposal or
that it poses an economic burden, which takps into consideration the
increase in cost of transport, treatment, and disposal in an MTR unit. A
cost ratio is given in the preamble which can be applied to the generator's
specific conditions in order to determine whether treatment is or is not
"practi^dl". The cost ratio is determined by dividing the costs of
treatment, shipment and disposal by costs of shipment and Higpncai only.
In general, if the ratio is greater than 2.0, treatment would not be
practical. Likewise, if the ratio is less than 1.5, treatment generally
would be considered practical. If the ratio is between 1.5 and 2.0, EPA
will generally consider treatment to be "practical" unless the certifier
•can demonstrated why his cost should be considered not "practical". The
cost ratio and consideration of "practical" is only a basic reference tool,
and not a hard and fast rule.
In any case, a demonstration by either EPA or the certifier can be
made showing that a specific practice is or is not "practical", regardless
of the cost ratio. For instance, the example given in the preamble where
Generator A has an on-site MIR unit, while Generator B (across the street
front Generator A) must ship his "soft hammer" waste cut of state to a
commercial disposal facility, would illustrate consideration other than the
cost ratio. The costs of shipment and disposal for Generator A would be
negligible, and thus, almost any cost of treatment would be considered to
be not practical, given the ratio. In such cases the Region should
evaluate Generator A's certification and demonstration of practically
available treatment technologies by methods other than the given cost
ratio. These situations must be evaluated on a case-by-case basis
considering the Region's knowledge of available technologies and relative
financial status or size of the facility. Furthermore, the cost ratio may
not be used to discontinue current treatment practices (although certain
practices may no longer be allowed) .
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ENFORCEMENT CONFIDhNliA
9938.
IV. Enforcement
In conplying with the First Third Regulation and other LCR
regulations, it is essential for a waste to be properly characterized, in
particular, whether or not it is in the proper waste treatability group
(wastewater or nonwastewater). Wastewater treatment residuals, leachate,
and contaminated ground water derived from "soft hammer" wastes currently
are not prohibited from land disposal. Therefore, the incentive exists for
a "soft hammer" liquid waste to be classified as a "soft hairmer"
wastewater. Furthermore, a unit which receives "soft haimer" liquid wastes
would have to meet the minimum technological requirements (MTR) or have a
3005(j)(2), (j)(4), or 3004(o)(2) waiver. A unit with a 3005(j)(3) or
(j) (13) waiver from the MIR is not eligible to receive restricted wastes,
unless a demonstration has been made under 3004 (o) (2). This demonstration
states that two liners and a leachate collection system are not required if
"the Administrator finds for a landfill or surface inpoundment, that
alternative design and operating practices, together with location
characteristics, will prevent the migration of any hazardous constituent
into the ground water or surface water at least as effectively as such
liners and leachate collection systems". One treatability group may be
less stringent than the other for a specific waste (i.e. wastewater vs.
nonwastewater), possibly requiring less or no treatment for that waste.
Wastewater residues from treatment of soft hanner wastes can be
disposed of in a landfill or surface impoundment based on the rescheduling
of these wastes to the Third Third [(Section 268.12(b)]. However, these
residues must clearly meet the criteria of less than 1% Total Organic
Carbon (TOC) and less than 1% Total Suspended Solids (TSS). In addition,
these residues must result from the following list of well designed and
well operated treatment technologies that are listed in Section 268.12(b):
metals recovery, metals precipitation, cyanide destruction, carbon
adsorption, chemical oxidation, steam stripping, biodegradation, and
incineration or other direct thermal destruction. The wastewater residues
from soft hairmer wastes are to be included in the Third Third of scheduled
wastes for which EPA is to develop treatment standards. The enforcement
official should request analytical data from a facility in order to
substantiate a wastewater determination. Where such data is unavailable
and the wastewater determination is highly questionable, the enforcement
official should request additional sanpling and analysis to be performed
by the facility or EPA should perform its-own sanpling to ascertain the
waste treatability group. In any case, the burden-of-proof should be
placed on the facility making the claim.
•*
States are expected to do inspections based on their agreement
ccrnoitments. The success of this enforcement strategy will depend greatly
on coordination between State and EPA to insure that violations
appropriately identified by the States are adequately referred to EPA for
enforcement. Enforcement should reflect what is outlined in the
Enforcement Response Policy (ERP) [OSWER Policy Directive 9900.0-1A] which
stresses the importance of concentrating enforcement efforts on the most
serious violators and taking timely and aggressive enforcement action
against these violators. There are a number of violations cited in the ERP
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ENFORCEMENT CONFIDENTS
which must be given high enforcement priority by the Regions and States.
These include:
9938.5
Improper disposal of waste in violation of the LCR restrictions.
In the RCRA Enforcement Response Policy, effective 10/1/88, land
facilities that improperly dispose of wastes in
violation of the land disposal restrictions are characterized as
a high priority violator (HPV), depending upon the potential
environmental impact.
o Mixing, solidifying, or otherwise diluting waste to circumvent
the LCR regulations. Dilution of wastes to meet the treatment
standards is specifically prohibited by Section 263.3 and any
handler identified as performing dilution to circumvent the land
disposal restrictions should be classified as a high priority
violator.
o Incorrectly certifying a waste for disposal/treatment in
violation of the LCR regulations. Facilities that incorrectly
certify a restricted waste for disposal should be classified a
high priority violator, depending upon the potential
environmental iirpact.
o Failure to submit notifications/certifications as required by the
LCR regulations. Facilities that fail to submit the required
notification or certification for the restricted waste with each
manifest are classified as high priority violators, depending
upon the potential environmental iirpact.
o Deficient waste determination by the generator, treatment
facility or land disposal facility. This violation constitutes a
Class I violation, and could constitute a high priority
violation, depending upon the potential environmental impact.
Due to the LDR schedule listed in Section 268 of 40 CFR Parts 190-399,
additional requirements for facilities may be promulgated as part of the
LCR framework. Future LCR enforcement strategies will describe and
classify violations of these requirements for the Regions and States.
The National Enforcement Investigation Center (NEXC) is a useful
resource which is available to all Regions. NEIC assistance may be used to
develop judicial cases or determine LCR compliance status of large complex
facilities of g^^i concern to a Region. EPA Headquarters Enforcement
staff are al*o available to render assistance for case development or any
LCR related inspections.
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9938.
EPA Headquarters is presently developing and updating several
documents to assist EPA and State personnel in implementing and enforcing
this regulation. A revised inspection manual for First Third wastes is
being developed. This manual will include a regulatory overview, list
handler requirements, examine the "soft hammer" provision and its
implications, and discuss the major enforcement concerns with the
regulation. Along with the First Third inspection manual, a single
inspection checklist compiling all LCR requirements through the First Third
rule will be developed. Also, an up to date version of the 40 CFR
regulations containing all requirements since November 7, 1986 and
including all amendments through the First Thirds rule will be developed
and distributed. Finally, to assist the regulated community in better
understanding and complying with all the LCR Regulations, an information
booklet containing a summary of all LCR requirements will be distributed to
them through a mass mailing.
LCR conference calls will also be held on a quarterly basis. The
calls will involve Headquarters and Regional LCR contacts and will serve as
an opportunity to Hi««-»!«« any problems encountered, share ideas or
recommendations, and update on the latest LCR developments.
VI. Data Itenaganent
On May 1988, OWPE conducted a preliminary analysis of Regional LCR
Enforcement Activity. That analysis showed a substantial variation among
Regions in the detection and classification of LCR violations. A guidance
document for LCR violations classification will be developed by a Regional
workgroup to assist the Regions in proper classification and enforcement
response and ultimately result in more uniformity nationwide. In order to
fully assess Regional implementation of LCR and to determine the need for
further guidance development and/or training, a Regional LCR Enforcement
Activity update will be implemented on a quarterly basis beginning November
6, 1988. This information will be logged, tracked and evaluated by EPA
Headquarters. •
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