source encapsulation, and preparation of special chemical forms). General Agent for U.S. Dept. of Commerce . J. Nix, Chemistry Department, Fayetteville 4, 1, 1, 1, 1, 7, 37 1. 2, . ,,pr, 84Rb, ,,Re, 4aSc, assr., Q5,Q5mTc, ,mTe, 44Ti. You can call or write your assessor’s office or download a form from their Web State Department of Health – Armengaud Motley, Dena – Mott, Frank L. U.S.S.R. [Name of A.S.S.R.] Statistiche- .. vironmental Form –

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EPA Compendium Volume 10 This compilation may not include all documents discussing Agency views on particular subjects.

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In addition, these documents are not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any party in litigation with the United States. The views expressed in these documents do not necessarily reflect the current position of the Agency, and EPA reserves the right to act at variance with these views or to change them at any time without public notice.

The Aaency is thus in a position to begin the permitting process for these facilities. These targets were set for each region on the basis of th. Asaw iiq rauzghly a year 5 timfran the tin, a permit is Cal Led to when it is issued, adherenc, to th. Inciner- ators must he considered to be the first priority of the RCRA permitting pro am in th. In such cases the Part B shouLd be called for both the incinerator an4 the storage facilities.

Regional Hazardous Waste Division Directors On January 26,the new Part hazardous waste land disposal regulations will become effective, and EPA will begin the process of requesting Part B applications for selected land disposal facilities.

This memorandum is intended to provide guidance on selecting facilities for priority attention in this initial phase of the land disposal permit program. The decisions as to which land disposal facilities will be permitted first, and why, must be made carefully.

In addition, this permit program will be highly visible and subject to intense scrutiny by the public and the regulated conununity. This is consistent with our previous policies for permitting hazardous waste storage facilities and incinerators. Highest priority should be given to cases where sole source aquifers and other drinking water supplies are being endangered.

Information regarding groundwater contamination should be solicited from the states, and may also be available from interim status quarterly reports and other sources. This could include facilities which have histories of poor operating practices, prior enforcement actions, inadequate liner systems where applicableor inspection reports indicating improper facility designs or unsafe management practices.

Facilities which have yet to report groundwater monitoring data, or for which data is questionable should be examined closely for permit action. Again, primary emphasis should be on protection of valuable aquifers and other water supplies. Assessment of environmental risks could include the proximity of the facility to population centers, aquifers and surface waters, facility size, nature of the wastes being disposed of, and other environmental factors.

In addition to these primary environmental considerations, several other factors should be taken into account: As a result, some high priority incineration facilities have not yet been called since they are located with land disposal operations. Monof ills and Neutralization Surface Impoundments. As explained in the preamble to the new Part land disposal regulations, EPA currently plans to propose adjustments to its regulatory approach for monof ills and neutralization surface impoundments.

It is possible that permitting of a facility or facilities could have some effect on business competition. This is most likely in a case where a commercial land disposal facility is required to obtain a RCRA permit while a nearby competitor is allowed to remain under interim status. The importance of this permitting effort demands that EPA begin its implementation as soon as it is legal and practical to do so.


Provisions are effective in both authorized and unauthorized States. EPA is responsible for im l. Permits in process, including draft permits, must address the newly effective requirements before issuance. Therefore, issuance of a valid RCRA permit in authorized States must be accomplished through joint permit processing with EPA until States are authorized for the new provisions. To assist in identifying the eztent to which draft permits and permits under development, as veil as permit applications, must now be revised, th.

Ths attachment does not include provisions that affect the permit program at later datci, nor does it cover early enactment provisions beyond permitting. Because of the new statutory requirement, the timeframe provided in the National Permits Strategy for requesting remaining land disposal permit application. Current schedules for calling in land disposal facilities should be reevaluated and new schedules should be developed which will conclude all.

Our aim is to prepare the policies and guidance that the Regions and.

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Kith rsgard to the priority of post-clooure permits, ve recognise the difficulty in making final dsteruinations on all land disposal applications by November Therefore, in order to achieve the greatest environmental benefits from available re- sources, high priority should be placed on the processing of operating land disposal unit applications and Part closures.

ThanK you for your letter of July 25in which you idencitied potential issues associated with the permit application for destruction of nerve agents at the Pueblo Army Depot. Because Congress mandactdunder P.

We set January 1as the target date for tinal issuance of the RCRA permits because we anticipate it will take at least several years to construct these incinerators once the RCRA permits are issued.

The high permitting priority tor the nerve agent projects is rerlect. We recognise that Colorado has other high priority work invo1vu g land disposal facilities. If you believe the State does not have adequate resources to process this application, you should conaider allowing EPA to assume the lead for proceeain, it, though Colorado would be responsible tar issuing the permit.

EPA has stressed to assd Army that they are subject to State requirt. EPA 1 Q is heaviLy involved in thi.

This involvement was supported by the State. There are many aspects of this project, such as Part I application deficienctes and siting ditticuities, chat may aff. Frms Army is veil aware of th. Chip Stewart has been a workgroup participant and we appreciate his input. With regard to the siting issues, aassr Atmy has launched an expanded pubLic intormatton program in an attempt to make the public more receptive to the new facilities.

Similar public meetings were heLd tor the other proposed sites, which are located throughout the U.

The purpose of the meetLngs on the EIS La to intorm the public about the strategy and the risks posed by the nerve agent disposal program, and to solicit comments regarding the LIS. The deadline for public comment on the EIS ii September 2. It is my understanling that the Army plans to have an expanded public intormation program during Fl for aU t.

I appreciate your concern regarding the difficulties which may be encountered in processing the permit application for the Pueblo Army Depot and your raising them to me at this time.

I urge you to rats. Please ted tree to contact me it you have additional questions or concerns. F1O 1s Marcia E. Director Office of bolid vaats Har ioua baste Division Directors. In some cases, the facility no lonjer functions as a CRA site e. Delays in determining their r.

As a result, vs should resolve the regulatory status of these facilities a. Please resolve the regulatory status of thsse facilities by liove. Keep the C D designation for all bankrupt facilities or facilities now subject to Superfund. They automatically appear in the not on a permit or closure track category. IhS moves these facilities into the closure track after consulting with the Region involved.


We will continue this practice for all newly discovered illegal facilities. Regions Kate flouvs without attachment Pruc. To direct our resources toward these goals, we vii ]. In an effort to refine and apply this process more broadly, some Regions have established system. In FTefforts to establish priorities should be expanded to. As part of this effort to increase our focus on the moat environmentally-significant facilities, the Office of Solid Waste is examining revision of the SPMS system to better reflect the level of effort and environmental benefits associated with the various targetted activities.

This memorandum is intended to help focus your initial planning activities for FT Additional guidance will be provided in the F! Finally, as part of the EPI, Sup. As ws plan for th. Davis, Director Hazardous Waste Management Division 6H Region VI Your memo of November 30 indicated concern that the timing of the proposed location standards and incinerator rules may jeopardize your ability to meet the and permit deadiLnes.

I do not believe that delay of these in c rtant regulations until after the and statutory permitting deadlines would be an environmentally sound derision in light o: In order to minimize any disruption of the permit process, we will continue to share drafts of these.

Where you conclude that the draft rule contains a requirement applicable to a permit you are drafting and that such a requirement is needed to protect human health or the environment, you can use the omnibus provision to add that requirement to-the draft permit.

When we propose the new incinerator requirements in the spring, the preamble will explain that we have provided guidance documents to the permit writers to help them implement the proposed coni. The Permit Assistance Teams are avatlable to assist you. In conclusion, I believe that if we work together we can minimize any permit delays these new regulations may cause.

I would expect, however, that we can jointly keep delays to a minimum through regular communication on the direction of the rules and on their impact on particular permits. According to the March 25, Federal Register 55 FRthe facility must submit a Part A Permit application six months from the date of publication in the Federal Register 55 by September 25, When must the facility submit the Part B portion of the permit application?

The date on which the facility must submit its Part B permit application depends on the type of unit.

RCRA Permit Policy Compendium Update Package Volume 10

The definition of land disposal facility is not codified in 40 CFR, but a statutory interpretation depaart be found in the September 25, Federal Register. Wayne Roepe, 05W Research: E am writiriq to clarify some possible misconcep- tions over the two March 5 notices. The first notice states: This is riot true. Until EPA issues a final rule on priorities for corrective action at Federal facilities, the Regions.

Current permitting negotiations on corrective action between EPA and Fede: EPA shall continue to require corrective action at Federal facilities and EPA shall continue to require schedules of compliance in th. Where appropriate, administrative orders under h should also be issued to direct Federal agencies to conduct corrective action activities prior to issuance of the permit. Where the three parties are unable to agree on the Schedule for conducting corrective action activities, these disputes should be referred to Bruce Weddle, Director, Permits and.

Defense and the Interior to explain our intent to depqrt the permit process and to negotiate schedules of com liance for Corrective action.