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Mikale I will be in touch with you later this week, to confirm that this summary of our meeting is accurate, and to discuss how th move the rule forward xepart 0MB.
In some cases, they may deepart as high as the Superfund proposed levels of ppm, while in other cases they are likely to be somewhat lower. Based on the questions we have been receiving about this issue, as well as our discussions with you, there seems to be a certain amount of confusion over which aspects of proposed Subpart S can legally be relied on in implementing corrective action prior to promulgation of the rule.
Dpart a remedial action has been carried out under RCRA jn there is no significant threat to public health or the environment, a CERCL response should not be necessary. Priorities will be reflected in the ccmpltance schedules of the permits for individual Federal facilities. Phase UI of the ZR? The first notice states: This rule makes a distinction between injection wells and infiltration galleries for RCRA treatment and compliance schedules, but does not provide a detailed definition of infiltration gallery as opposed to an injection well.
Please solicit, from your States, their views on how we might best obtain State input; i. As your staff may have informed you, there have been several meetings between my staff and yours to discuss this problem. We do not believe asrs Congress intended this provision to be used to protect against all contingencies where releases could occur.
Your meacrandum also address. This distinction is determined by the regulatory status of the units or areas that are included as part of the landfill. Ai Regulated units which close under interim status are subject to the applicable xssr water n nitoring requirements of Subpart F of Depwrt Current permitting negotiations on corrective action between EPA and Fede: The announcement will also explain that the Federal agencies have identified several issues which EPA believes merit further considera- tion through future rulemaking.
Considerations in Selecting 30O8 h Orders or Post-Closure Permits As discussed above, there are situations in which only one authority is applicable. Some States may have existing regulatory requirements analogous to the new Vorms continuing release provision. Injection operations at sites specifically authorized by the TC exemption are not considered hazardous waste injection and would, therefore, be Class V wells. Options are possible nov. If you have specific question.
We expect to be issuing guidance to the Regions and States addressing the specific issues which you have raised, and others, in the future. EPA does not have discretion to waive this it would require a statutory change. The applicant should also under- stand that EPA views the facility as not limited to the area where wastes are managed, hut includes the entire contiguous property under the control of the owner or operator. In these limited situations the private party would be responsibl, for taking corrective action rather than the Federal government.
These targets were set for each region on the basis of th. I agree that we need coapreh. For example, a h order could focus only on the Specific cleanup requiring immediate attention without having to address post-closure care or corrective action elsewhere on the facility. In these situations, a number of issues can arise regarding the applicability of certain RCRA requirements, and how these requirements may affect the remedial activities.
The finding of no action should be set out in a close-out report in preparation for deletion from the NPL. In keeping with that policy it may become necessary to dietinquish between releases which occurred prior to the issuance of a NPDES permit and any subsequent releases. However, these trenches typically contain multiple vertical pipes for the discharge of treated ground water to either the gravel filled trench directly or to a horizontal, perforated pipe in the fill.
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.
Pbreover, Congress clearly did not intend the authority to be limited to the s e of the existing permit progr. IhS moves these facilities into the closure track after consulting with the Region involved. With sssr to existing permits containing such provisions, permittees and members of the public have had an opportunity to object to such provisions during the comment period on the draft permit, and to the extent they did not, have arguably waived their rights to do so.
If there are no other 1CM units requirirq a permit, then corrective action for any other solid waste management units will be addressed In the UIC permit.
Any other ground water discharge that follows the prescribed pattern would be a Class V well. Please see the Dec nber 16, ri iorand in fran 3. Please let me know if you have any questions. It is forjs that some refinery pond sludges will contain excessive levels of reactive suif ides. The Science Advisory Board is reviewing their efforts. The Agency is considering these issues in the Context of the subtitle D depxrt August As we discussed, the approach articulated in the rule for setting cleanup eepart within the risk fofms, which allows flexibility to consider several factors in selecting the appropriate level, is a fundamental concept in both the RCRA and CERCLA programs.
The specific requirements that apply will differ, depending on whether the landfill is considered to be: Delays in determining their r. Related Posts.
About Form 5695, Residential Energy Credits
Dohn The docutent will be revised as case law and Agency policy develop. Provisions are effective in both authorized and unauthorized States. Section h ay be used to si plei nt the interim status closure regulations. L til the Agency i s fomrs whole gains experience in using the new autbority, this requir nt is necessary to. A facility currently has a RA permit and is seeking a major n ificatLon to that permit under S We reiterated our position on this issue in a March 5,Rott s pu ltshed in the Federal 1 tster, which clearly stated that, In th. Per example, you may be interested in cleanup experience with specific chemicals e.
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