c/EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 7 0 <5*
TITLE: Transmittal of the RCRA Ground-Water Enforcement
Strategy
APPROVAL DATE:
EFFECTIVE DATE:7/22 '35
ORIGINATING OFFICE: OWPE
Q FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OSWER OSWER OSWER
/£ DIRECTIVE DIRECTIVE Dl
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&EPA
United States Environmental Protection Agency
Washington. DC 20460
OSWER Directive Initiation Request
Interim Directive Number
9905.0
Originator Information
Name of Contact Person
Steve Heare
Mail
Telephone Number
475-8115
Lead Office
O OERR
D OSW
D OUST
LID OWPE
D AA-OSWER
ice Dir
Approved for Review
Date
Title
Transmittal of the RCRA Ground-Water Enforcement Strategy.
Summarv of Directive
Strategy to improve compliance at land disposal facilities subject to
ground water rponitoring requirements. National consistent baseline
of information on Land disposal facilities and assist Regions in
implementing Regionally specific efforts.
Land disposal facilities,.
geoi mrUwafeer monitoring
inspections, oafor&cniant- actions
baseline information standards
Type of Directive (Manual. Policy Directive. Announcement, etc)
Strategy
Status
D Draft
03 Final
New
LJ Revision
Does this Directive Supersede Previous Directive(s)' I I Yes (_ | No Does It Supplement Previous Direciive(s)? PI Yes [j
If "Yes" to Either Question, What Directive (number, titlej
Review Plan
D AA-OSWER D OUST
D OERR D OWPE
CD OSW D Regions
O OECM
D OGC
C OPPE
D
Other (Specify)
This Request Meets OSWER Directives System Format
Date
5-30
Signature of OSWER Directives Officer
Date
EPA Form 1315-17(10-85)
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JUL 2 2
MEMORANDUM
SUBJECT: iTtansmittal c>f the RCRA Ground-Water Enforcement
\S»rat/~
FROM:
' fting Assistant Administrator (WH-562A)
TO: Regional Hazardous Waste Division Directors
Regions I-X
Attached for your immediate implementation is the final
RCRA Ground-Water Enforcement Strategy to improve compliance
at land disposal facilities subject to ground-water monitoring
(GWM) requirements. This policy document, consistent with the
FY 86 RCRA Implementation Plan (RIP)/ continues to focus the
National RCRA Enforcement Program on those facilities which
present the greatest potential environmental risk, particularly
land disposal facilities.
This strategy was developed in concert with tha FY 86 RIP
and it provides a greater level of detail regarding the Agency's
management of information regarding land disposal facilities.
The Ground-Water Enforcement Strategy incorporates Regional comments
on both the RIP and the first draft of the strategy (mailed 6/13/85
and discussed at the last Division Director's meeting on June
18). Additional comments were received from the RCRA Project
Officers (RPO's) who met in Headquarters on June 25-26, 1986.
There are two parts to this strategy. The first part
establishes the priorities for inspections and enforcement
actions at GWM facilities. These priorities are completely
consistent with the priorities in the FY 86 RIP and are restated
here for emphasis. We merged the results of the development
of the FY 1986 RIP and the ground-water strategy to produce a
single approach responsive to program needs. The second part
of the strategy establishes the framework for a greater level
of Agency management of the information and data we have and
will gather concerning these high priority facilities. This
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frameworfc requires a greater Regional and, to some degree,
Headquarters role in program oversight. As we have discussed
in the past, increased activities to protect ground-water are
essential at this time. Most Regions have already started to
obtain more detailed programmatic and facility specific
information. The intent of this strategy is to establish a
nationally consistent baseline of information on these facilities
and to assist the Regions in implementing Regionally specific
efforts.
I am relying on your personal involvement to insure that
this strategy, in concert with the FY 86 RIP, is quickly
implemented. For this strategy to be successful, -implementation
must proceed in a cooperative manner between the Regions and
States. I do not anticipate that FY 1985 State Enforcement
Agreements will need to be changed pursuant to this strategy.
OWPE staff and their contractors are available to assist you,
as necessary, in some of the data gathering efforts. Your
staff can contact Jerry Kotas, Acting Chief of the RCRA Compliance
& Implementation Branch (FTS 475-8115) to discuss OWPE assistance.
I appreciate your continuing assistance in working together
to strive for full program implementation.
cc: RCRA Branch Chiefs, Regions I-X
RCRA Enforcement Section Chiefs, Regions I-X
RCRA RPO's, Regions I-X
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RCRA GRQUNDWATER ENFORCEMENT STRATEGY
Office of Waste Programs Enforcement
JULY 22, 1985
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I. Background
This document establishes a strategy for improving the
regulatory compliance at land disposal facilities subject to
ground-water monitoring (GWM). The facilities subject to GWM
requirements generally pose the greatest environmental risk.
For this reason, as stated in the FY 1986 RCRA Implementation
Plan (RIP) dated June 28, 1985, these facilities are the highest
priority for the RCRA Enforcement Program.
This strategy has two sections. The first section establishes
the national priorities for inspections and enforcement actions
at GWM facilities. These priorities are consistent with the
enforcement priorities contained in the FY 86 RIP. These priorities
are also consistent with the more general FY 85 Revised RIP,
although additional emphasis and data gathering are added.
The second section establishes clear roles for both the Regions
and Headquarters related only to the GWM facilities. This
section addresses three elements of information management:
(1) GWM inspection reports and enforcement orders; (2) Regional
and HQ facility files; and (3) an integrated data management
system for GWM facilities which incorporates HWDMS and other
existing systems and adds some limited new data elements.
Regarding RCRA land disposal facilities subject to GWM
requirements, it is the Agency's policy to:
0 take a formal enforcement action to abate any release
of a hazardous waste or constituents posing an immediate
threat to health or the environment (that is not addressed
by CERCLA)
0 by end of FY 1986, take a formal enforcement action
against all interim status land disposal facilities
that have not fully implemented ground-water monitoring
programs that satisfy both interim status requirements,
and final operating permit application requirements,
and have not voluntarily come into compliance;
0 support the issuance or denial by November 1988 of
all land disposal facility permits;
0 ensure that closed regulated land disposal units comply
with closure and post-closure requirements; and
0 ensure Federal facility compliance.
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The Facility Management Planning (FMP) process will
determine appropriate enforcement or permitting actions to be
taken.
III. PRIORITIES FOR INSPECTIONS AND ENFORCEMENT ACTIONS
The Agency and the States have emphasized ground-water
protection as a high priority. Our priorities have been
set forth most recently in the FY 1986 RIP. These priorities
underscore the commitment to protect groundwater. To assure
achievement of the priority activities in the RIP,. RCRA
inspection and enforcement activities should be oriented toward
the FY 86 RIP priorities which are summarized below. A complete
discussion and explanation of the following priorities is set
forth at pages 8-17 of the FY 86 RIP. It should be noted that
the FY 86 RIP contains priorities for inspections and enforcement
orders for facilities in addition to the GWM facilities. Those
are not changed by this policy.
Mandatory Inspection Priorities for Land Disposal Facilities
Subject to GWM Requirements
1. Facilities presenting an immediate threat to human health
and/or the environment.
2. Commercial land disposal facilities.
3. Facilities with ground-water monitoring systems of
unknown status.
4. Facilities with ground-water systems previously determined
to be inadequate.
5. Facilities without ground-water monitoring wells.
6. Facilities with ground-water monitoring systems previously
deemed adequate.
7. Land disposal facilities in the permit pipeline.
8. Closed land disposal units.
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Priorities for Taking Enforcement Actions at Land Disposal
Facilities Subject to GWM Requirements
1. Facilities presenting immediate or serious threat
to human health and/or the environment.
2. Facilities with inadequate well systems.
3. Facilities with no wells.
4. Enforcement orders to support the permitting of land disposal
facilities.
5. Other noncompliance with closure and post-closure require-
ments, including applicable GWM requirements.
IV. MANAGEMENT FOR RESULTS
The RCRA Enforcement program is focused on environmental
results. The priorities for inspections and enforcement
are designed to address the most environmentally significant
facilities first, i.e., land disposal, and then to further
prioritize actions within that group to move against the biggest
or potentially biggest problems first.
In addition to focusing inspection and enforcement activities
there is also a national need for significantly improved management
of the information gathered about land disposal facilities subject
to ground-water monitoring. The States and Regions have considerable
information on specific facilities, but the information is not
always readily available. A goal of this strategy is to obtain
necessary information and employ automated data processing
that will provide the Agency with a national picture of the
status of ground-water monitoring facilities. We expect that
the Regional files and consolidated data base described below
will be assembled and operational by October 1, 1985.
A. Facility Files
Improving Agency management of facility information will
require considerable cooperation between the States, Regions
and Headquarters. By the end of FY 1985 the Regions should
have a reasonably up-to-date individual file on most land
disposal facilities. Those files should include copies of state
and EPA inspection reports and orders, and other relevant
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submissi-ons. The Regional files, in conjunction with a brief
confirming phone call with the State, should be complete enough
to determine a facility's general compliance status, including
an evaluation of the facility's compliance with applicable
ground-water monitoring requirements. In developing and
maintaining files, the Regions should obtain information from
the States, and as appropriate, should also use authorities
such as RCRA §3007 to obtain information directly from owners
or operators. State inspection reports and enforcement orders
are to be submitted to EPA in final form for purposes of Regional
oversight and review for national consistency! not for EPA
concurrence. The general objectives of the EPA oversight are
to evaluate the quality and completeness of inspection
reports and to review the timeliness and appropriateness
of State formal enforcement actions. Results of oversight
evaluations will be shared with the States.
In addition, OWPE will establish a very limited file on
land disposal facilities that will contain primarily copies of
Regional and State enforcement complaints and orders, copies
of selected inspection reports, and copies of other documents
obtained through routine oversight activities. Copies of all
EPA Regional enforcement complaints and orders will continue
to be sent to OWPE. The Regions should obtain copies of formal
State enforcement pleadings (equivalent to EPA complaints and
orders) regarding violations of ground-water, closure, post
closure and financial responsibility requirements, and corrective
action at land disposal facilities and send copies to OWPE.
Copies of specific State and Regional inspection reports will
be periodically requested. OWPE will use the enforcement
documents in a general overview of (1) national progress in
enforcement actions, (2) procedures for and quality of
inspections (3) the national consistency of compliance with
the RCRA Enforcement Response Policy, and (4) trends in
the quality of enforcement actions, the results of which will
be shared with the Regions"! A Regional/State workgroup will be
established to help develop procedures and criteria for
selecting and reviewing enforcement inspections and orders
for cross fertilization and appropriate national consistency.
B. Consolidated Data Base
During the conference call with the Regional Division
Directors on May 9, the need for a consolidated information
base to improve oversight and evaluation of compliance monitoring
and enforcement activities at land disposal facilities was
discussed. Data currently collected on the compliance status
of GWM facilities through the State-EPA reporting process may
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not provide, in all cases, the level of detail essential to
address non-compliance of environmentally significant
facilities. Hie consolidated data base for land disposal
facilities will provide EPA with a slightly more detailed
information management tool for land disposal facilities and
will rely primarily upon HWDMS data. The purpose of the
consolidated data base is to facilitate EPA management and
oversight of the compliance of these priority facilities. It
is not intended to substitute for the detailed information in
files that is needed for enforcement actions.
Building a better information base requires the following
steps:
1. Determine information needs based on the enforcement
strategy and responsibility to more closely monitor
activities at land disposal facilities.
2. Determine what information is currently available and
assess its reliability; determine what new data needs to
be collected.
3. Determine how to collect, quality assure, process, and
analyze this information.
Implementation of the three steps is as follows:
1) Information Needs;
Attached is the list of information needed for
each of approximately 1,600 land disposal facilities
subject to ground-water monitoring. These data
will provide a profile of each facility with
information on evaluations focusing on ground-
water monitoring systems and closure/post closure
plans; ground-water monitoring violations including
details on the status of ground-water monitoring
systems; and outstanding enforcement actions
addressing ground-water monitoring violations.
Data elements pertinent to loss of interim status
provisions are necessary for managing in the post
November 8, 1985 world of RCRA enforcement. This
includes certification data and the status of the
permit or closure process as appropriate. Finally,
information on CERCLA site wastes at RCRA facilities
is becoming critical.
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2) Existing data and quality; new data needs;
The list includes the source of each data item.
Much of the data on the list is routinely collected
through the State reporting process and is in
HWDMS. The quality and completeness of these
data vary from Region to Region and State to
State. Much of the basic facility information
collected via Part A permit applications is already
in HWDMS. Part A data should be reviewed to
accurately identify facilities subject to
ground-water monitoring and loss of interim status
provisions. Some detailed information on the status
of ground-water monitoring systems was captured
through the Congressional survey in early 1985
and automated by Headquarters. CERCLA wastes at
RCRA sites data were captured and automated by
Headquarters last tail, however, updated information
is needed.
Some of the information on the list has never been
systematically captured and processed on a facility-
specific, national basis. These are the new data that
will be collected for the first time from the Regions.
3) Procedures to collect, quality assure, process and
analyze data;
The task at hand is to quality assure existing data and
capture new data- This will be achieved through a
single operation. The attached proposed schedule
includes the major data gathering milestones. The
effort must involve both Regions and States to provide
the new data and quality assure the current data in
existing data bases.
OWPE will consolidate existing data into a single
data base that will be accessible to the Regions
and easy to utilize. Under an OWPE contract, data
from HWDMS Regional data bases, the Congresssional
Survey, and the CERCLA/RCRA Survey will be linked
together by EPA's facility ID number and established
as a separate file on the IBM mainframe computer at
the National Computer Center at Research Triangle
Park. This computer can be accessed by all Regions
and Headquarters. Current data will be sent to Regions
to be quality assured for completeness, correctness,
and timeliness. Quality assurance is very important
since future oversight reports on Regional and State
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performance will assume a thorough assurance of
existing data. It will come to the Regions in
the form of a computer-generated listing for
each land disposal facility. This listing will
show all current data available and identify the
source of the data (HWDMS, Congressional Survey,
etc.). Discrepancies such as where Congressional
enforcement data disagrees with HWDMS/CMEL enforcement
data will be laid out for resolution.
Any corrections of HWDMS data will be made to HWDMS
regional data bases by the regions and/or the States, usi
established procedures.Headquarters will capture
corrections to HWDMS data by re-loading regional data
bases at a pre-arranged time.
Corrections to Congressional Survey and CERCLA/RCRA
Survey data will be submitted to headquarters
in specially assigned formats and will be entered
into the consolidated data base by OWPE.
All data on the consolidated data base is formatted in
a software package (SAS) which permits any combination
of data relationships to be established and analyzed.
This provides flexibility in processing data that is
not available using HWDMS alone. Reports and analyses
can be routed to Regional printers so Regional managers
can make use of the consolidated data. Some Regional
ADP staff may be familiar with SAS and can generate
reports off the consolidated data base for Regional
management staff. Alternatively, requests for reports
can be called into Headquarters, generated by OWPE
and routed to Regional staff. The goal is to provide
a flexible, accessible data base which will serve the
Regions.
Those Regions and States which have conscientiously
collected and processed HWDMS data and reported
Congressional Survey data accurately should have few
problems with existing information quality. Their
burden largely will be limited to providing the new
information and updates. Those Regions and States
which have not been as successful face a larger work
load. OWPE's regional coordinators and contractor
staff will work directly with Regional staff and
through the Regions with States to help with this
process.
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This.approach is being taken for several reasons. First,
a consolidated data base is needed as soon as possible. This
can be accomplished only by building on the foundation of
existing data bases. It is faster and easier to correct existing
data and collect a limited amount of new data than to start
from scratch.
Second, hardware used must be common to all Regions.
It has been suggested that a series of Regional IBM-PC's
be used to process this information. However, not all Regional
RCRA Enforcement staffs have PC's. It is also unlikely.that
staff in all Regions have been trained on IBM-PC's.
Third, the data collection and processing infrastructure
exists in all Regions. Establishing an entirely different set
of procedures is not practical under current time constraints.
It is acknowledged that State reporting and HWDMS processing
have not been ideal. The current operating environment provides
a unique opportunity to address and resolve HWDMS data quality
issues. However, there is some information that is not currently
being collected in HWDMS. Consequently, the separate data-
gathering process for this segment cf information is necessary.
1. Use of the consolidated data base:
The purpose of the data collection initiative is to
develop a better information base for management,
oversight, and program evaluation purposes. Both
Regional and headquarters staff will be encouraged to
access the data base on an interactive basis to support
implementation of the strategy. Examples are:
- Generate listings of facilities with no well systems,
These facilities are to receive additional attention
regarding the November 8, 1985 deadline and loss
of interim status.
- Generate listings of facilities with known releases
along with related enforcement action data. This
is to ensure that timely and appropriate enforcement
actions are taken, that corrective action can be
prioritized, and that data exists for national
budgetary purposes.
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Generate listings of facilities that were reported
as in compliance along with evaluation information.
Knowing the date and type of most recent evaluation,
inspectors can determine which facilities need CME's.
2. Updating of information:
In keeping with Regional and State reporting practices
since FY 84, the consolidated data base will be updated
monthly. For the universe of land disposal facilities
which are the focus of the strategy, this will constitute
the FY 86 RCRA Implementation Plan State reporting
requirements. The Compliance Monitoring "and Enforcement
Log will continue to be used to report actions at the
balance of facilities not covered by the strategy.
Again, this is described in detail in the'RIP.
3. Support in using the consolidated data base.
At the outset, in the event that a Region experiences
difficulty in using the system, OWPE will provide
support. As requested, OWPE will arrange for printouts
and send them to the Regions.
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July 12, 1985
U.S. EPA - Office of Waste Programs Enforcement
Consolidated Data Base Information
Phase A - To he collected now
I. Background Information
1. Facility Name
2. EPA Rac. ID #
3- City and/or County
II. Profile Information
HWEMS
C0101
C0101
com
Existing Data Sources
CERCLA/ Dlngell
RCRA Survey
yea
yes
Old
F3S
yes
New Data
GW
Strategy
SPAR
For RCRA Regulated Units, report:
4.
5.
6.
8.
n of Landfill units
iC of Land Treatment Units
H of Surface Impoundments
- Storage
- Treatment
- Disposal
§ of Class I HW Underground
Injection Wells
ft of Waste Piles
C1801
=D80T
=D8l
=S04
=T02
=D83
=D79
=S03
Process
- Codes
Actual #
of units
for each
process
•ft, U t*
[Note - This Information helps define the universe of land disposal facilities. In some regions
where C0305 = D (for Disposal) Is the Indicator for land disposal facilities.]
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Existing Data Sources
HWDMS HWDMS
V6 V6.5
CERCLA/ Dlngell
RCRA Survey
New Data
PSS GW
Strategy SPAR
Is the facility in:
9. Fart 265 Detection Monitoring
Where 2401=G
C2107=D
Where 2101KJ
10. Part 265 Assessment Monitoring C2407=A
11. Is Facility developing data/
plans pursuant to Part 270
Requirements
12. Is Facility developing data/
plans pursuant to Part 270
requirements and Part 265
Assessment Monitoring
13. Is entire facility operating
under a waiver from GWM req.
It. Has waiver been reviewed
15. Was waiver adequate
16. Has faclltly submitted
dellstlng petition
Where 2*401=0
Where 2401 =G
2102=5
C2135 exists
02136= Yes
2H76=A
2176=P
2U76=C
Where 2*401=G
2U07=W
Where 2401=C
2U71=05
Q-19
Q-la
Q-la
yes
yes
Derive from #13 and #!'»
(If reviewed and approved,
It was adequate)
Q-la
Q-6a
Q-6b
(This data Is maintained by Jim Popettl of OSW)
17. Is there a fundamental
disagreement between EPA/State
and facility re regulated units
or whether Is disposes of hw Y/N?
yes
18. Has facility notified/closure
C2402 or
2102
Where 2001=C
2102=13
2107=PC
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Existing Data Sources
HWDMS HWCMS CERCLA/ Dlngell
V6 V6.5 RCRA Survey
New Data
PSS
GW
Strat.
SPAR
OWPE will generate data supplied by regions
In response to the Dlngell survey:
As of 12/84, facility was Judged
to have:
No wells
No wells because It has a waiver
from GWM requirements
No wells because It was a waste pile
and didn't require wells to meet
Part 265 requirements
An Inadequate well system
Adequacy of system unknown or under
review
An adequate well system
Facility not subject to GUM requirements
Update Dlngell survey data; per most
current Information, facility was
Judged to have:
19. No wells
20. No wells becasue It has a waiver
from GWM requirements
21. No wells because It was a waste pile
and didn't require wells to meet
Part 265 requirements
22. An Inadequate well system
23. Adequacy of system unknown or under
review
24. An adequate well system
25. Facility not subject to GWM requirements
yes
yes
yes
yes
yes
yes
yes
Q-2a
Q-2b
Where 2401=G
2407=X
2107=W
yes
yes
yes
yes
yes
yes
yes
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Existing Data Sources New Data
HWDHS HWDMS CERCIA/ Dlngell FSS GW
V6 V6-5 RCRA Survey Strat. SPAR
For purposes of this data base, CWPE has divided CME's Into three basic components as shown below.
The considerations In parentheses are not meant to be all Inclusive. It Is Agency position that
requirements for site characterization, well location and design and sampling and analysis pursuant
to Parts 26H and 265 are essentially the same, I.e. they are In keeping with the parameters of
constituents to be monitored. See Chapter 3 of the Ground Water Compliance Order Guidance.
Current HWEMS and planned enhancements provide Information on CME (Eval type 04) overall.
26. Review Hydrogeologlcl study/
Information. (Collection and
analysis of hydrogeologlc
Information on which system
design Is based)
Reviewed Where 2311=01
2313 exists
Responsible Agency All above yes
2339=S. E,etc. 23l4=S,E,etc.
Adequate All above and yea
2331 - 0
yes
Date reviewed 2313
27. Well construction and
location (# and location
of wells, depth and length
of well screens, deiagn and
construction of wells, etc.
Reviewed Where 2311=0*1 yes
2313 exists
Responsible Agency All above and yes
2339=S, E.etc. 2311=S,E,etc.
Adequate All above and yea
2331 = 0
Date reviewed 2313
yes
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Existing Data Sources
HWDMS HWEMS
V6 V6.5
CERCLA/ Dlngell
RCRA Survey
New Data
FSS GW
Strat. SPAR
28. Sampling and Analysis
Program (adequacy of sampling
equipment, sampling protocols
and QA/QC protocols)
Reviewed
Responsible Agency
Adequate
Date reviewed
29. Has facility detected a
statistically significant
Increase?
Date
30. Has Part B been received?
Where 2311=01
2313 exists
All above
2339-S, E.etc.
All above and
2331 • 0
2313
Where 2101=G
2402=3
2138
Where 2001-P
2102=02
2106 exists
23H=S,E,etc.
yes
yes
yes
yes
Where 2101=0
2171=03
2179
yes
yes
Record Reviews of Interim Status Facilities:
31. Have Closure/Post Closure
Plans and Cost Estimates
been reviewed?
Date Reviewed
Responsible Agency
Were violations discovered?
Where 2311=03
and 2333=X or 0
2313
2339
2333=X
yes
yes
yes
yes
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Existing Data Sources
HWDMS HWDMS CERCIA/ Dingell
V6 V6.5 RCRA Survey
New Data
PSS GW
Strat.
SPAR
32. Have Financial Assurance
Instruments been reviewed?
Date Reviewed
Responsible Agency
Were violations discovered?
Where 2311=03
and 2331=X or 0
2313
2339
2331=X
yes
yea
yes
POP each enforcement action taken aa the result or any
evaluation or Information obtained from beginning of
FY 1981 to date, provide the following:
33. "type of Enforcement Action 2351=
NOV/WL 03
3008(a)complaint (or State equlv) 01
3008(a)flnal order ( » " " ) 05
3013 Initial 06
3013 final 07
7003 08
3008(h)
CERCLA §106
31. Date of Evaluation 2313
35. Type of Evaluation 2311=01-05
36. Class I Violation area or
reason for action P332-2338
37. Responsible Agency 2360=S,E,X
38. Scheduled compliance date 2356
39. Actual compliance date 2357
10. Is facility in compliance with
compliance schedule In final
order?
yea
0-7
16
17
yes
yea
yes
yea
yes
0-7
0-7
Q-7
2366=A
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Existing Data Sources New Data
HWCMS HWDMS CERCLA/ Dlngell PSS GW
V6 V6.5 RCRA Survey Strat. SPAR
Disposition of CERCLA Wastes at RCRA facilities
11. Has the facility received
Superfund wastes yes
42. Superfund sites from which waste
sent - Site ID# and name ves
11. Date of first shipment yes Q-8
45. Date of last shipment yes
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Existing Data Sources New Data
HWCMS HWDMS CERCLA/ Dlngell PSS GW
V6 V6.5 RCRA Survey Strat. SPAR
Phase B - Data to be collected at a later time
B-l Was Closure certified Where 2001=C yes
2102=15
B-2 Has post-closure permit yes
application been submitted 2001=W
2102=7
Date 2106
B-3 Has post-closure permit 2001=W
application been Issued 2102=?
Date 2106
The following relate to loss of Interim status provisions:
B-1 Certification with Subpart P or Where 2001=P yes
equivalent State requirements 2102=13
Where 2106 exists
Certified all units 2107= CC
Certified some units 2107= PC
Certification not submitted 2107= NC
B-5 Certification with Subpart H or Where 2001=P yes
equivalent State requirements 2102=1'!
Where 2106 exists
Certified all units 2107= CC
Certified some units 2107= PC
Certification not submitted . 2107= MS
Facility unable to obtain Insurance 2109= TBD
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Existing Data Sources New Data
HWEMS HWDMS CERCLA/ Dlngell F5S QW
V6 V6.5 RCRA Survey Strat. SPAR
Por each facility which did or did not certify compliance with ground water monitoring
or financial requirements, has It submitted a:
B-6 Part B Application
As above
B-7 Closure Plan
As above
B-8 Post Closure Permit
Application
As above
B-9 Has a PA/SI been performed Where 2001= yes (SPAR)
2101= TBD
2105 exists
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