£EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
9410.00-1
TITLE* Early Enactment/ Provisions RCRA
Reauthori zatiorL
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE
[&FINAL
D DRAFT
•
STATUS.
02/01/85
02/01/35
SPB/OSW
]
A- Pending OMB approval
f ] B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other document*): headquarters
OS WER OS WER OS WER
VE DIRECTIVE DIRECTIVE Di
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Wasnington. uC 20460
OSWER Directive Initiation Request
9410.00-1
Name of Coniact Person
SPB/OSW
Man Code - Branch
SPB
Lead
D
OERR
G OUST
C OWPE
LJ AA-OSWER
Approved tof Review
Signature of O'dce 0.rector
Date
'•MS
Early Enactment Provisions RCRA Reauthorization
Summarv o( Directive
Summary of 1984 Amendments to RCRA.
Key Words: .
Hazardous and Solid Waste. Amendments, Reauthorization, Early
Enactment
Type of Directive (Manual. Policy Directive. Announcement, etc.i
Status
! D Draft
! 81 Ftnai
O New
LJ Revision
Ooe» this Directive Supersede Previous Direcnvets;' [ _ | Yes
( "Yes" to Either Question. What Directive (number, title/
No Does It Supplement Previous Directiveisi' [ j Yes fjf| No
Review Plan
LJ AA-OSWER
D OER'R
D OSW
Q OUST
LJ OWPE
LJ Regions
D OECM
D OGC
D OPPE
D
Other iSpecilyl
This Request Meets OSWER Directives Svttem Format
Sigr-ature of Lead Of'.ce Directives Officer
• Date
Signature of OSWER Directives Officer
' Date
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-:OY DIRECTIVE NO.
-00-1 !
jlEMGRANDUfl
SUEJF.CT: Draft Guidance on Implementation of Minimum Technology
Requirements and Corrective Action Requirements
of the Hazardous and Solid Waste Amendments of 1981
FROU: John H. Skinner
Director
Office of Solid Waste (WK-562)
TO; Addressees
Attached are two draft P.eauthorization Statutory Interpretations
that provide guidance on the implementation of several early enactment
provisions of the Hazardous and Solid Waste Amendments of 1981. Theee
documents have been prepared to solicit your input on the manner In
which the Environmental Protection Agency will implement these key
provisions of the Act. The draftn include interpretations of statutory
language and central elements of the implementation strategy.
Minimum technology requirements went into effect on the da.te of
enactment of the HSWA of 1981. Permits cannot be issued to land
disposal facilities unless they address these requirements. In
addition, certain interim status land disposal facilities will have
to implement these minimum technology requirements by ?'.ay M, 1985.
On December 21, 1981, the Office of Solid Waste distributed for
comment a draft technical guidance that described the specifications
for designs that EPA believes meet the performance requirements of
the minimum technology provisions. The draft RSI and the draft techni-
cal guidance together provide the guidance necessary to implement
these provisions. (Comments on the draft technical .cuidance are still
under review and are not reflected in the attached guidance.)
Corrective action provisions also went into effect on the date of
enactment o'f the HSWA of 1981. Permits issued after November 8, 1981,
must address "corrective action for all releases of hazardous waste or
constituents [at a RCRA regulated facility] regardless of the time at
which waste was placed in such unit," Additional technical guidance—
to be developed and Issued over the course of the next year—will
supplement the attached RSI. These guidances will describe how a
permit writer determines if a facility is subject to corrective action,
and what must be done about a release of concern.
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:,.-.t:< POLICY DIRECTIVE NO.
*-6 10 -GO" 1
-2-
Please send your comments on proposed minimum technology
requirements to:
Robert Tonetti, Office of Solid Waste, Waste Management and
Economics Division, ROOK 2106 fall - WK-565, 401 M Street, SW,
Washington, DC 20460.
Comments on the corrective action provisions should be sent
to:
David Pagan, Office of Solid Waste, Permits and State
Programs Division, Room S-2^3 Kail - WK-563, *t01 H Street, SW,
Washington, DC 20AGO.
All comments should be received at EPA no later than March 1.
We look forward to hearing from you.
Attachments
Addressees
Regional Hazardous Waste Division Directors
State Hazardous Waste Program Managers
Industrial Groups
Environmental Groups
WH-563:CRastatter:Rm.S263: 382-W6:1/3/845
Clem's Disc. #6 - Item No. 30
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