oEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9522.02(83)

TITLE: Revised Definition of "Major Handlers" of Hazardous
     Waste
APPROVAL DATE: 7-11-33

EFFECTIVE DATE: 7-11-83

ORIGINATING OFFICE: Office of Solid Waste

O FINAL

D DRAFT

 STATUS:
                           [ ]
               REFERENCE (other document*):
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- In development or circulating
          headquarters
  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE    Dl

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 PART 270  SUBPART A - GENERAL INFORMATHN                     DOC:  9522.02(83)


 Key Words:     Major Handlers

 Regulations:   40 CFR Parts 270 and 271

 Subject:       Revised Definition of "Major Handlers" of Hazardous Waste

 Addressee:     Program Implementation Guidance Addresses

 Originator:    Lee M.  Thomas, Acting Assistant Administrator for Solid
               Waste and Emergency Response

 Source  Doc:    #9522.02(83)

 Date:          7-11-83

 Summary:

     The  States  and EPA Regional Offices should jointly develop updated lists
 of  designated  "major  handlers"  based on the revised definition.  The following
 hazardous waste  handling activities are to be designated as "major":

     I.   All facilities subject to ground-water monitoring and/or
          protection requirements;                                             ^

     II.   All incinerators;

    III.   Up to 10%  of remaining TSDFs;

     IV.   Up to 3% of  generators and  transporters.

     Percentages are  to  be based on  the number of known handlers in HWDMS as
of October 1,  1983.   EPA or  the State may add facilities, generators or trans-
porters to the list,  subject  to the  10% and 3% ceilings, and shall notify the
other party in writing.   However,  the delegation of any facility, generator or
transporter must be agreed to in writing by both parties.  The list will be
reviewed and renegotiated  at  least annually.

     Reporting requirements  in  §270.5 or in the annual RCRA Guidance which
refer to major handlers  apply to  the  above designated list.  Those major handlers
which comprise categories  I,  II, and  III are designated as major facilities for
EPA permit overview.

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                                                               9522.'02 (83)
MEMORANDUM

SUBJECT:  Definition  of  "vajor Handlers" of Hazardous Waste

          Lee M. Thomas    Z.sTgr.8c?7 He* ]fl. Thomas
          Acting Assistant Artrri'nis tra Cor" for
            Solid  waste  and  Errergency Response

TO:       Procrar  Irrplerenta tion Guidance Addressees
     what definition will  provide consistency in the designation
by t-JPA and authorized  States  of  "rrajor handlers" of hazardous
waste?

DISCUSSION

     Compliance with  the 40 CFS  Parts 270 and 271 requires certain
Hazardous waste handlers to be designated as •rrajor."  This desig-
nation is intended  to  identify,  for administrative purposes, environ-
rentally significant  hazardous waste handlers and to be used in
concentrating  ins^ction,  periri ttincj , and reporting resources on
those handlers.

     The original definition  of  a "rajor handler' of hazardous
waste, which was  the  subject  of  PIG-82-2 (Hay 14, 1982), was based
on infor^a tion available to the  Aqency at the tire, including our
experience with imminent hazard  and Supertunc sites.   It was a
first step in  providing a  uniform,  nationally consistent standard
to identify rrajor handlers to serve as a focus for limited RCP.A
resources.  As rrore data have tecoire available,  it has becoi^e
evident that changes  and clarifications to the existing definition
would rake it  irore  useful  in  the iirpleren ta tion  of RCRA.  That
revision is identified below.

( WH-5 6 3-B ) M. Mad i son :mt: 6/9/8 3:5-256
Disk: 18D   Index:  4

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                              - 2 -

     The States and EPA Regional Offices should jointly develop
updated lists of designated  'major handlers* based on  this
revised definition*  The lists will be used by authorized States
and  the Regions for program  implementation, budget decisions,
inspections, reporting/ and  peririt overview.  The increased
attention which must be directed to these facilities is resource
intensive.  Thus, the resulting lists of vajor handlers will be
considered in the budget planning process for allocations of
resources.  The effective implerrentation date for this definition
is October 1, 1984.  The Regions and the States will develop
lists of rajor handlers on the basis of this definition during
PY 1984 for use in PY 1985.
        \

DECISION   \

     The following hazardous waste handling activities are to
be designated as •major";

     I.  All facilities subject to ground-*** ter ironitoring
         and/or protection requirements

    II.  All incinerators

   III.  Up to 10% of remaining TSDF's

    IV.  Up to 3% of generators and transporters

Percentages are to be based on the nuirber of known handlers in
HWDMS as of October 1, 1983.  EPA or the State iray add facilities,
generators or transporters to the list, subject to the 10% and 3%
ceilings,  and shall notify the other party in writing.  However,
tne deletion of any facility, generator or transporter mist be
agreed to in writing by both parties.  The list will be reviewed
and renegotiated at least annually,.

     Reporting requirements  in 40 CPR 270.5 or in the annual
RCRA Guidance which refer to major handlers apply tc the above
designated list. Those major handlers which comprise categories
I,II, and III are designated as icajor facilities for EPA peririt
overview.

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