Hazardous Waste
Collection
v>EPA
Wasnmgton. OC 20460
OSWER Directive Initiation Request
9b02.00-5
Originator Informavon
Name of Contact Person
David Pagan
Mail Code - Branch
WH-563
Telepnone-Num
oneTJumoer
382-4740
Lead OHice
D OERR
Q) OSW
D OUST
Lj OWPE
U AA-OSWER
Approved lor Pewew
Signature ol Office Director
Date
Title
RCRA Facility Assessment Guidance
Summary ot Directive
Transmits RCRA Facility Assessment Guidance to Regions and discusses definition
of a solid waste management unit
Key Words:
RCRA Facility Assessment, RFA, Solid Waste Management Unit
Type of Directive (Manual. Policy Directive. Announcement, etc.!
•
.Guidance Manual Transmission Memo
' Status
i
I
D Draft
fj Final
D Nev»
LJ Revision
Do*»this Directive Supersede Previous Directive^;' I I Yes |X| No Does It Supplement Previous Directive^)' | I *«» r* J No
If "Yes" to Either Question. What Directive (number, title)
Review Plan
D AA-OSWER D OUST
D OERR O OWPE
DOSW D
D OECM
D OGC
D OPPE
D
Other (Specify!
LJ OSW LJ Regions LJ 0
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
Signature of OSWER Directives Officer
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
f WASHINGTON, D.C. 20460
*C^
«0^
flTT - 0 (OAR OST'SP. Policy Directive
^ *™ 9502.00-5 "
OFFICE OF
MEMORANDUM SOLIO .VASTS AND EMERGENCY RESPONSE
SUBJECT: RCRA Facility Assessment Guidance
6AX J/c'^
FROM: j. Winston'Porter, Assistant Administrator
Office of Solid Waste and Emergency Response
TO: Addressees
Attached you will find guidance on conducting RCRA Facility
Assessments (RFAs). This document replaces the draft guidance
(then called "PA/SI" guidance) which was distributed in August,
1985. The guidance in this final document does not fundamentally
alter the scope or approach to conducting RFAs that was outlined
in the draft document. Most revisions have been made to clarify
or strengthen certain features of the guidance to reflect what
.has been learned from experience with conducting RFAs over the
past year. Some revisions have also been made to reflect new
policy developments associated with implementing the RCRA corrective
action program.
I wish to make clear several important points which have
been raised by Regions and others regarding RFAs. The RFA is
meant to provide the basis for decisions regarding the necessary
follow-on steps in implementing corrective action at facilities.
VThile it is important to do a thorough RFA, the approach and
scope of an RFA will vary according to site specific conditions.
Many of the suggested steps or investigations outlined in the
guidance will be unnecessary at a given facility. RFA decisions
will often require applying professional judgment to the infor-
mation collected during the RFA.
It should be understood that it will often be necessary
to prioritize the releases and/or units which will be examined
as part of an RFA. Certain releases or units at a facility
which are of relatively lower priority may be addressed, as
appropriate, as part of a compliance schedule in the order or
permit, by requiring owner/operators to perform preliminary,
RFA-type investigations.
In terms of the scope of RFA investigations, highest priority
should be on assessing the discernible solid waste management
units at the facility. It may be appropriate in some cases to
assign a relatively lower priority to certain solid waste management
units at a facility, such as a solid waste management unit which
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USTJER Policv Directive
9502.00-5
cannot be located without substantial samplincj or other invest-
igations. Likewise, releases or areas of facilities which are
not solid waste management units, but which are nevertheless
potentially subject to corrective action under RCRA [e.g., §3008(h)]
or other authorities, should also be considered to be of relatively
lower priority in conducting RFAs. A discussion of these other
types of releases, and how they may be addressed, is presented
below.
Some guestions have been raised regarding the definition of
the term "solid waste management unit", which is relevant to
determining which units at a facility should be assessed in an
RFA. The Final Codification Rule (July 15, 1985) identified the
types of discernible units which are considered solid waste
management units to include landfills, surface impoundments,
waste piles, land treatment units, incinerators, tanks, container
storage units, injection wells and other physical, chemical and
biological treatment units. In addition, the Agency has inter-
preted the term to apply to areas associated with production
processes at facilities which have become contaminated as a
result of routine, systematic and deliberate releases of wastes
or constituents (a product may become a waste if it is discarded
or abandoned). An example of this type of solid waste management
unit would be a wood preservative "kickback" area, where drippage
of preservative fluids onto soils from pressure-treated wood
is allowed to occur over time.
Several Regions have reguested clarification regarding the
application of the concept of "solid waste management unit" to
other contaminated areas at facilities, such as one-time spills,
leakage from product storage, and releases from production areas
that are not routine, systematic and deliberate. Such releases
are not considered to be solid waste management units. As explained
in the Final Codification Rule, spills of wastes or constituents
are considered subject to §3004(u) corrective action only if the
spill occurred from a solid waste management unit. A spill which
did not occur from a discernible solid waste management unit is
not of itself a solid waste management unit. Likewise, leakage
from product storage and other types of releases associated
with production processes would not be considered solid waste
management units, unless those releases were routine, systematic
and deliberate.
Although of relatively lower priority in conducting RFAs,
certain releases at facilities which are not related to solid waste
management units can be addressed using §3008 (h) or other enforce-
ment authorities. In situations where an enforcement action has
been initiated at a facility to address releases that are not
related to solid waste management units, and where a permit is
subseguently issued to the facility, those actions can be continued
under the permit, under the authority of RCRA §3005(c)(3).
Likewise, at some facilities, investigators may have reason to
believe that an area that is not a solid waste management unit
is likely to be causing or have caused serious environmental
problems. In such cases, compliance schedules may be written in
permits (under §3005(c)(3) authority) or orders to provide for
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QSTTR Policy Directive
~3" 9502.00-5
preliminary RFA-type investigations by owner/operators to address
such areas. If releases.are subsequently identified which require
further investigation or action, the permit or order can be modified
to provide for necessary owner/operator actions.
If you have any questions or comments regarding the RFA
guidance, or other RFA-related issues, please contact Dave Fagan
at FTS 382-4740.
Addressees:
Hazardous Waste Division Directors, Regions I-X
RCRA Branch Chiefs, Regions I-X
RCRA Permit Section Chiefs, Regions I-X
RCRA Enforcement Section Chiefs, Regions I-X
State RCRA Permit and Enforcement Contacts
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