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Document Record Detail



Full Document:
Title:RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) BIENNIAL REPORT REQUIREMENTS FOR COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT (CERCLA) RESPONSE ACTIONS
RCRA Online Number:14842
Date:12/14/2011
To:Superfund National Policy Managers and Regional RCRA Directors
From:Woolford, Rudzinski, Stanton, and Cheatham
Organization of Recipient:NA
Description: For purposes of CERCLA response actions, EPA considers the RCRA biennial reporting requirement to be an administrative requirement, which only applies to off-site actions. Therefore, any RCRA hazardous waste generated on-site as part of a Superfund response action and managed on-site must comply with all substantive RCRA requirements but need not comply with administrative requirements, such as RCRA biennial reporting requirements. Any RCRA hazardous waste generated on-site and managed off-site is subject to all RCRA requirements, including, where applicable, biennial report requirements. RCRA regulations require biennial reporting from large quantity generators (LQGs). Hazardous waste generators at CERCLA sites may either report all RCRA hazardous waste managed off-site without evaluating whether they are an LQG or determine if, in any calendar month, the site is an LQG, and if so, report all RCRA hazardous waste that is generated on-site, but managed off-site for the entire calendar year.
Regulatory Citation(s) : 261.5(e), 262.40, 262.41, 264.75, 265.75 EXIT disclaimer
Statutory Citation(s):3002, 3004 Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):EPA Forms; Hazardous Waste Data; Large Quantity Generators (LQG)
Approximate Number of Hardcopy Pages:7
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:No

 

 
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