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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Most of the preamble and proposed rule are interpretative and are not inconsistent with any current regulatory requirements and thus can be used as guidance in the interim.

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The burden of proof in the demonstration of scouring is upon the Agency. Us at Sfl FRJuly 15, Because of the new statutory requirement, the timeframe provided in the National Permits Strategy for requesting remaining land disposal permit application. We are assuming that, by referring to closure, you are describing a facility that has at Least one unit that accepted hazardous waste.

It is likely that some refinery pond sludges will contain excessive levels of reactive suif ides. Further, a number of additional authorities are available to address the operation of injection galleries.

As a result, the proposed process, including the provisions governing interim measures and conditional remedies, can be used as guidance until promulgation of the final rule. Because Section h is quite broad, both with respect to the types of envi ental prcb1 m that may be addressed and the actions that EPA may e1, delegation of Section h authority is subject to limitations.


RCRA Permit Policy Compendium Update Package Volume 10

Section h orders may address releases or potential releases to all medta. The inistrator can require corrective action or such other response measures as he deen necessary to protect hunan health or the envi nt. Site-specific conditions may warrant the use of soil cleanup levels below the ppm level or somewhat above the ppm level. In an effort to refine and apply 46955 process more broadly, some Regions have established system.

If I can be of any further assistance, please let me know.

The Off ics of Solid Waste rec. The se d and vorms delegate the authority to issue orders and sign consent agre tents.

Upon issuance of a post-closure permit, the applicable requirements for ground water rronitoring, including compliance monitoring and corrective action, must be Complied with. In the long-run, therefore, we anticipate that post-closure permits should serve as the routine mechanism for the majority of corrective actions at closing land disposal facilties. The Aaency is thus in a position to begin the permitting process for these facilities.

Therefore, in implementing correc- tive action under Section uRegions and states shoul3 consider areas which have become contaminated through routine and syste natic releases of hazardous wastes or hazardous constit- uents to Ce solii waste mana emer t units.

Kith rsgard to the priority of post-clooure permits, ve recognise the difficulty in making final dsteruinations on all land disposal applications by November Thus, a facility such depaft the one mentioned in your letter cannot terminate its interim status by simply withdrawing its Part A application. Such an argument, although technically complex, can be made based on well established hydrodynamic principles.

However, a post-closure permit is not required if the unit closes by removal under standards equivalent to S standards.

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Routine and systematic releases constitute, in effect, management of wastes; the area sasr which this activity has taken place can thus reasonably be considered a solid waste management unit. Notice to States Section h does not require that States be given notice of an inpending action. The high permitting priority tor the nerve agent projects is rerlect.

In particular, advice has been sought on when to use a post-closure permit instead of S3O08 h order to compel corrective action at interim status facilities or facilities that have lost interim status.

V facility design Lnci. Additional guidance will be provided in the F! Under what circumstances would different or dual authorities be used at th.

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We agree that Federal agencies need more time to compile their deparh, and we intend to distribute the questionnaires for the inventory well in advance of the January 31 deadline. In the case of the white phosphorus burial some, since whit, phosphorus is a basardous vast, and the unit is located within the facility boandary, the tact of being underwater would have no attest on its designation as a scUd waste management mit. For instance, the SPE i provides detailed guidance on hcw to assess health impacts at known points of exposure.

Much of the impleii ntation of the continuing release provision is subject to interpretations which have not yet been made by the Agency.

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