RCRA Permits, Compliance, and Enforcement OBJECTIVES At completion of this chapter, the student should: • Understand the basic outline of the RCRA permitting process. • Be familiar with the four steps of the RCRA corrective action process and the application of each of the steps. • Understand the goals of the RCRA Enforcement Program and the actions which may be taken to achieve these goals. • Be familiar with the administrative, civil, and criminal enforcement pro- visions of RCRA. INTRODUCTION In the previous chapters, we have attempted to first present materials on the generally accepted practice pertaining to the hazardous waste management subject at hand. We have followed the general (or “generic”) material with an overview of the regulatory requirements of the Resource Conservation and Recovery Act (RCRA) and other pertinent statutes, as they apply to the subject. This chapter deals with three related aspects of RCRA which have no generic counterpart. Similarly, we have attempted to present the highly complex subject of hazardous waste management, and the respective components of RCRA, in an orderly flow of compartmentalized subjects. We now find it necessary to present an important set of materials that do not “fit together” as nicely. Certainly, compliance is required of permit holders, and enforcement actions are taken against those not in compliance. However, compliance with RCRA (and other) statutes and regulations is required of all who handle hazardous wastes (not just permit holders or applicants), and enforcement actions may be taken against those who do not comply with the regu- lations. We will attempt to keep these aspects clear, but the reader should approach the subject with care. The requirement to apply for, and obtain, an operating permit to treat, store, and dispose of hazardous waste is the subject of § 3005 of RCRA. The implementing 9 L1533_frame_C09 Page 223 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC regulations for § 3005 are codified at 40 CFR 270. The related authority of EPA and/or state inspectors to enter upon the premises of any “… person who generates, stores, treats, transports, disposes of, or otherwise handles or has handled hazardous waste …” to inspect, obtain samples, and copy records is contained in RCRA § 3007. Section 3008 provides authorities for enforcement of RCRA provisions. Section 3013 provides the EPA with authorities to require owners or operators of Treatment, Storage, and Disposal Facilities (TSDFs) to conduct monitoring, testing, analysis, and reporting and to take enforcement action against any person who fails or refuses to comply with an order issued under this section. The operating requirements for TSDFs are found in Parts 264, 265, and 266. Facilities that have not received a permit and are operating under interim status must comply with the Part 265 stan- dards. The administrative procedures that apply to the permitting process, including procedures for issuing, modifying, revoking, reissuing, or terminating permits, are provided in 40 CFR 124 (EPA 2000; DeCamp 2000). P ERMITS TO T REAT , S TORE , OR D ISPOSE OF H AZARDOUS W ASTE Permits identify the administrative and technical standards that must be met by TSDFs. Permits are issued by the EPA or by a state agency that has been authorized by the EPA to administer the program. The permit specifies the operating require- ments for the facility based upon the general and technical standards of Part 264, as well as requirements for corrective actions. Facilities Permitted RCRA requires every owner or operator of a TSDF to obtain an operating permit. Congress and the EPA recognized that several years would be required to issue permits to all TSDFs and made provision for granting “interim status” to TSDFs that were in operation on November 19, 1980, and had “notified” the EPA prior to that date. Other TSDFs that are in operation “… on the effective date of statutory or regulatory amendments, under the Act, that render the facility subject to the require- ment to have a RCRA permit shall have interim status and shall be treated as having been issued a permit …” provided they have “notified” the EPA of hazardous waste activity and comply with applicable operating standards (40 CFR 270.70). Interim status facilities are allowed to operate in that status until a final permit is issued or denied. New facilities or existing facilities that failed to qualify for interim status are ineligible for interim status and must obtain a permit before commencing operations. Only in a very limited number of circumstances can a person treat, store, or dispose of hazardous waste without interim status or a permit. Such circumstances include • Generators (LQGs and SQGs) storing waste on-site for time periods shorter than prescribed by § 262.34 • Farmers disposing of their own pesticide wastes on site as provided by § 262.70 • Owners or operators of totally enclosed treatment facilities, wastewater treatment units, and elementary neutralization units as defined by § 260.10 L1533_frame_C09 Page 224 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC • Transporters storing manifested hazardous waste in containers meeting the requirements of § 262.30 at a transfer facility for a period of 10 days or less • Owners and operators performing containment activities during an imme- diate response to an emergency per § 264.1 • Persons adding absorbent material to hazardous waste in a container and persons adding hazardous waste to absorbent material in a container 1 (EPA 1998d, Chapter 8) Permits are also issued for research, development, and demonstration projects; post-closure of land disposal facilities; emergency situations involving imminent and substantial endangerment to human health or the environment; temporary permits for incinerators to conduct trial burns; and for land treatment facilities to demonstrate acceptable performance. 2 Ocean disposal vessels and barges regulated by the Marine Protection Research and Sanctuaries Act (MPRSA), UIC wells regulated by the Safe Drinking Water Act (SDWA), and Publicly owned Treatment Works (POTWs) reg- ulated by the Clean Water Act (CWA) are considered to have “permits-by-rule.” RCRA provides for these facilities’ non-RCRA permits to serve in place of a RCRA permit, provided that the facilities are in compliance with their issued permits and the basic RCRA administrative requirements (adapted from EPA 1998c; EPA 1998d, Chapter 8; and EPA 2000). The Permitting Process Owners and operators of TSDFs must submit a comprehensive permit application consisting of two parts (Figure 9.1). Part A of the application is a short form (EPA Form 8700-23) that calls for basic information about the facility, such as name, location, nature of business conducted, regulated activities, and topographic map of the site. The Part B, in narrative form, is much more extensive than Part A and requires the submission of substantially more detailed technical information. General requirements are provided by 40 CFR 270.14. Specific information requirements for containers, tanks, surface impoundments, incinerators, land treatment facilities, land- fills, and miscellaneous units are provided by §§ 270.15 through 270.23. The appli- cant must become familiar with the requirements of Parts 264 and 270 in order to determine the nature of the data required for the particular facility. Technically, Part A may be submitted initially, to be followed by Part B when “called in” by the EPA. This procedure grew from the necessity for then-existing facilities to apply prior to November 19, 1980 in order to be granted interim status. 3 1 Provided that the container meets the definition of § 260.10 and that these actions occur at the time the waste is first placed in the container and §§ 264.17(b), 264.171, and 264.172 are complied with. 2 Although there are many hundreds more storage facilities nationwide than either treatment or disposal facilities, it is easy to lapse into an association of permitting with the “T” and “D” of the TSDF acronym. Generator (large and small) personnel should keep in mind the ease with which status can shift to that of a storage facility and the permitting requirements that apply. 3 In recent years, the EPA has granted interim status to some applicant facilities burning hazardous wastes in boilers and industrial furnaces. L1533_frame_C09 Page 225 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC Some authorized states no longer want Part A submissions, requiring Part B as the initial submission. Others require that Parts A and B be submitted simultaneously. Owners and operators of new facilities must submit Parts A and B simultaneously, at least 180 days prior to the expected date of start of construction. Construction may not begin until the application is reviewed and a final permit is issued. Except in the case of very simple or primitive facilities, the assigned permit writer will require even further submissions after reviewing the Part B. The supplemental data are requested through a “notice of deficiency” (NOD) letter to the applicant. As noted in earlier chapters, the omnibus authorities of RCRA § 3005(c)(3) provide the permit writer with considerable discretion to require the applicant to develop data, to conduct risk assessments, or to prescribe conditions not specifically addressed by the RCRA regulations. Figure 9.2 is an example of Parts A and B permit application requirements. The applicant should carefully coordinate preparation of the required submis- sions with the EPA or state program manager and/or assigned permit writer. The process is time-consuming, detailed, and exacting. For large and/or complex facili- ties, the process may require several years to complete. Public participation has become integral to each step of the permitting process and increasingly involves contentious and/or protracted issues. After a complete RCRA permit application is filed, the 40 CFR 124 regulations establish the procedure for processing the application and issuing the permit. The process includes FIGURE 9.1 Example Parts A and B, RCRA permit application requirements (EPA 1998d, Chapter 8). L1533_frame_C09 Page 226 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC FIGURE 9.2 The permitting process (EPA 1998d, Chapter 8). L1533_frame_C09 Page 227 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC • Review of the permit application • Preparation of a draft permit • Public comment and/or hearing • Issue or denial of the permit • Maintenance and termination of the permit In addition to RCRA requirements, activity at the facility must not conflict with other federal laws, including • Wild and Scenic Rivers Act • National Historic Preservation Act of 1966 • Endangered Species Act • Coastal Zone Management Act • Fish and Wildlife Coordination Act Permits for land disposal facilities, incinerators, other treatment facilities, and storage facilities can be issued for a 10-year fixed term. While permits may be reviewed and modified at any time during their terms, permits for land disposal facilities must be reviewed within 5 years following issue. When reviewed, the permit may be modified to incorporate changes in standards or policies regarding land disposal facilities. The permitted facility may request permit modifications for a variety of reasons, ranging from relatively inconsequential “Class 1” changes to major “Class 3” changes such as creation of a new landfill unit. Section 270.42, Appendix I, assigns classifications according to the type of change for which approval is sought. The EPA or the authorized state agency may initiate modification, in which case only the conditions subject to modification are reopened, or it may revoke and reissue the permit. In the latter case, the entire permit is reopened and, when reissued, a new term is established (adapted from EPA 1998, Chapter 8, and EPA 2000). The “Permit As a Shield” Compliance with an RCRA permit during its term is considered compliance (for purposes of RCRA enforcement) with Subtitle C of RCRA [§ 270.4(a)]. This pro- vision means that an owner and/or operator complies with the requirements specified in the permit, rather than with the corresponding regulations as promulgated in Parts 264 and 266. This is referred to as the permit-as-a-shield provision. Nevertheless, a permittee must comply with requirements that are imposed by the statute itself, e.g., the land disposal restrictions of Part 268, the liner and leak detection require- ments for land disposal units, and the air emission standards of Subparts AA, BB, and CC of Part 265 (adapted from EPA 2000). Closure Plans and Post-Closure Permits Owners and/or operators of TSDFs submitting Part B permit applications must include closure plans in accord with §§ 264, 265.112. The plan must explain in L1533_frame_C09 Page 228 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC detail how the performance standard of §§ 264, 265.111 is to be achieved. The approved closure plan then becomes an enforceable component of the issued permit. Interim status facilities must have a written closure plan on the premises within 6 months after the facility becomes subject to § 265.112. If all hazardous waste and contaminants, including contaminated soils and equip- ment, can be removed from a site or unit at closure, the site or unit can be “clean- closed,” meaning that post-closure care is not required ( see: Chapter 11 or Glossary). Land disposal/treatment facilities with contaminated equipment, structures, and soils that cannot be clean-closed must obtain closure permits, thereby ensuring that appropriate monitoring and maintenance requirements will be met. Owners and/or operators must submit a post-closure plan for the site or unit to be closed as part of the post closure permit application. The plan must include • A description of planned groundwater activities • A description of planned maintenance activities • The name, address, and telephone numbers of the person or office to contact during the post-closure plan (40 CFR 264 and 265.117-118) Post-closure care consists primarily of groundwater monitoring and maintaining waste containment systems. The post-closure period is normally 30 years, but may be extended or shortened by the regulatory agency (adapted from EPA 1997; EPA 1998d, Chapter 8; and EPA 2000; see also: EPA 1998a: EPA 1998e). RCRA Permits As a “Virtual Elimination” Tool As noted in the previous chapter, the EPA has made clear the intent to use the RCRA permit program (among others) to eliminate the use of target compounds 4 wherever possible, thereby minimizing future releases. The agency has indicated that intent in the document “The Virtual Elimination Project” (EPA 1998b), unambiguously stating that reductions in releases can be achieved without the need for additional research or regulatory action. The EPA has also published a “handbook” entitled “Pollution Prevention Solutions During Permitting, Inspections and Enforcement,” which provides examples of P2 inclusions in permits and enforcement settlements in air, water, and hazardous waste actions by the EPA and state agencies (EPA 1998a). T HE C ORRECTIVE A CTION P ROCESS Note: As this text was being prepared, the EPA was responding to Congressional, public, and stakeholder pressures to increase the pace of RCRA cleanups with a set of administrative reforms known as the RCRA Cleanup Reforms. The reforms are designed to achieve faster, more efficient cleanups at RCRA Treatment, Storage, and Disposal sites that have potential environmental contamination. The goals of the reforms focus on 1712 RCRA facilities identified by the EPA and states because of the potential for unacceptable exposure to pollutants and/or for groundwater 4 The current emphasis being on elimination of persistent, bioaccumulative toxic (PBT) chemicals. L1533_frame_C09 Page 229 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC contamination. This group is referred to as the “RCRA Cleanup Baseline.” The goals are that by 2005, the states and the EPA will verify and document that 95% of these 1712 RCRA facilities will have “current human exposures under control” 5 and 70% will have “migration of contaminated groundwater under control.” 5 A number of guidance and related documents are being propagated and are accessible on the Office of Solid Waste Web site <www.epa.gov/epaoswer/osw/cleanup.htm> (EPA 1999b). Thus, much of the following material is subject to change. Additional notes relative to the reforms are provided in the following paragraphs. The 1984 Hazardous and Solid Waste Amendments (HSWA) expanded the authorities of the EPA and the authorized states to address releases of hazardous waste through corrective actions beyond those then contained in 40 CFR 264, Subpart F. Corrective action requirements are imposed upon permitted or nonpermitted facilities through a permit, an enforcement order, or lawsuit. RCRA facilities gen- erally are brought into the RCRA corrective action process when there is an identified release of hazardous waste or hazardous constituents or when the regulatory agency is considering the permit application submitted by the facility. The agency can incorporate corrective action requirements in an existing permit or a newly issued permit . At a minimum, permits including corrective action requirements will include schedules for compliance and provisions for financial assurance to cover the cost of implementation of the required cleanup. In addition to the Part 264, Subpart F, requirements for groundwater monitoring and correction of any releases from land disposal units, HSWA added statutory provisions for addressing corrective action in permits as follows: • Section 3004(u) provides authority to the EPA to require corrective action for releases of hazardous waste or hazardous constituents from solid waste management units (SWMUs) on or within the facility. • Section 3004(v) authorizes the agency to impose corrective action require- ments for releases that have migrated beyond the facility boundary. • The omnibus permitting authority of § 3005(c)(3) authorizes the EPA or the state agency to modify a permit as necessary to require corrective action for any potential threat to human health or the environment. The EPA has additional statutory authorities to order corrective actions that are not contingent upon a facility permit: • RCRA § 3008(h) authorizes the EPA to require corrective action or other necessary corrective measures in the form of an administrative enforce- ment order or to seek a court order, in case of a release of hazardous waste or constituents from an interim status facility. • Section 7003 provides the EPA broad enforcement authority, upon finding evidence of past or present handling of solid or hazardous waste, to require any action necessary to abate potential imminent and substantial hazards caused by releases from any source. 5 Two guidance documents termed “Environmental Indicators” (EIs). L1533_frame_C09 Page 230 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC The decision regarding these alternatives is made by the EPA on a case-by-case basis, taking into account the nature and magnitude of the release. Corrective actions presently proceed through one or more of six steps. The procedures are detailed and tailored to the situation at the facility in question. The steps, briefly, involve: • RCRA Facility Assessment (RFA) — a review of existing information on contaminant releases, including information on actual or potential releases (The RFA may include sampling if needed.) • A follow-up investigation referred to as a release investigation or Phase I RCRA Facility Investigation (Phase I RFI) — may be useful before full- scale characterization for a variety of reasons or purposes, such as con- firming dated information • RCRA Facility Investigation (RFI) — wherein the owner or operator of a facility may be required to conduct further investigations to verify and/or characterize a release or releases or to conduct a full-scale site characterization • Interim Measures — short-term actions to control ongoing risks while site characterization is underway or before a final remedy is selected • Corrective Measure Study (CMS) — in which the owner or operator is required to identify, evaluate, and recommend specific corrective measures that will remediate the site • Corrective Measures Implementation (CMI) — may include design, con- struction, maintenance, and monitoring of the selected corrective measures Interim corrective measures may be required, at any point in the process, where the EPA or the authorized state agency believes that expedited action should be taken to protect human health or the environment (EPA 1998d). Remediation Waste Management Units 6 Until recently, the EPA had implemented the corrective action program primarily through direct use of statutory authorities and by the issue of guidance and policies developed pursuant to those authorities. In 1993, the Agency codified rules pertaining to corrective action management units (CAMUs) and temporary units (TUs) at 40 CFR 264, Subpart S (58 FR 8683). The subpart was revised and § 264.554 (staging piles) was added in 1998 (63 FR 65939). 7 6 “Remediation waste” means all solid and hazardous wastes and all media (including groundwater, surface water, soils, and sediments) and debris that contain listed hazardous wastes or that themselves exhibit a hazardous characteristic and are managed for implementing cleanup (40 CFR 260.10). 7 The EPA initially proposed to replace CAMUs with “remediation piles” (61 FR 18779; April 29, 1996). The term was replaced with “staging piles” when § 264.554 was added (63 FR 65939). The Agency did not follow through with the replacement proposal and has announced that it will not take final action on the proposed Subpart S; however, the portions of Subpart S that have been finalized (CAMUs) will remain in effect (64 FR 54604; see also: Porter 1999). L1533_frame_C09 Page 231 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC A CAMU 8 is a physical, geographical area designated by the EPA or an autho- rized state agency for managing remediation wastes during corrective action. One or more CAMUs may be designated at a facility. The CAMU enables the facility to manage the remediation waste in a unit without having to comply with LDR treat- ment standards or the minimum technical requirements for land-based treatment, storage, or disposal units (40 CFR 264.552). TUs are containers or tanks that are designed to manage remediation wastes during corrective action at permitted or interim status facilities. The TU regulations for non-land-based units were promulgated at the same time as the CAMU regula- tions for land-based units. TUs may operate for 1 year, with opportunity for a 1-year extension (40 CFR 264.553). A staging pile is an accumulation of solid, non-flowing remediation waste that is not a containment building and is used only during remedial operations for temporary storage within the contiguous property under the control of the owner/operator, where the wastes originated. The staging pile must be operated according to the design criteria designated by the regulatory agency. The staging pile must not operate for more than 2 years, unless an operating term extension is granted by the regulatory agency (40 CFR 264.554; see also: EPA 1998c; EPA 1998d; EPA 1997a). C OMPLIANCE R EQUIREMENTS OF RCRA The goals of the RCRA enforcement program are to ensure that the regulatory and statutory provisions of RCRA are met and to compel corrective action, where necessary. Facility inspections by the EPA and/or state agency officials are the primary tool by which compliance is monitored; however, self-monitor- ing and reporting activity are important elements of the program. EPA Regional Administrators and officials of authorized state agencies have some discretion in reaction to findings of noncompliance by a facility that is subject to RCRA regulations. When noncompliance is detected, the range of enforcement options include the use of administrative orders, civil lawsuits, or criminal indict- ments, depending upon the nature and severity of the offense. Federal and state administrators must have reliable compliance data in order to make fair and equitable decisions regarding enforcement options and to assess the overall effectiveness of the RCRA program. Competent monitoring acts as a deter- rent, by determining the extent to which a facility is in or out of compliance; by 8 On February 11, 2000, the EPA, the Environmental Defense Fund (EDF), the Natural Resources Defense Council (NRDC), and the Environmental Technology Council (ETC) reached a settlement agreement on the pending litigation over the CAMU regulations for remediation waste. The settlement calls for the Agency to amend the 1993 rule to establish CAMU-specific treatment and design standards and minimum liner and cap standards for CAMUs (EPA 2000a). L1533_frame_C09 Page 232 Tuesday, May 1, 2001 12:41 PM © 2001 by CRC Press LLC [...]... facility (see also: EPA 198 6; EPA 199 7c; EPA 199 8, Chapter 10; NRC 199 7, ES7, Chapter 1; Corbitt 198 9, pp 9. 78ff; Sara 199 3, Chapter 10) Inspections The preferred method of obtaining compliance data is by the conduct of an inspection of the regulated facility RCRA § 3007 provides authorities for representatives of the EPA or authorized state agencies to enter any premises where hazardous waste is handled to... Protection Agency 199 8b The Virtual Elimination Project, Region 5 — Air and Radiation, Chicago, IL U.S Environmental Protection Agency 199 8c Management of Remediation Waste under RCRA, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530F -9 8-0 26 U.S Environmental Protection Agency 199 8d RCRA Orientation Manual, Office of Solid Waste, Washington, D.C., EPA 530-R -9 8-0 04 U.S Environmental... Agency 199 7a Introduction to RCRA Corrective Action, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530-R -9 7-0 65 U.S Environmental Protection Agency 199 7b Introduction to RCRA Enforcement and Compliance, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530R -9 7-0 66 U.S Environmental Protection Agency 199 7c Introduction to Groundwater Monitoring, Office of Solid Waste. .. U.S Environmental Protection Agency 199 8e Elizabeth Cotsworth, Acting Director, Office of Solid Waste Memorandum TO: Senior Policy Advisors Regions I–X, SUBJECT: Risk-Based Clean Closure, March 16, 199 8, Washington, D.C U.S Environmental Protection Agency 199 9 RCRA Enforcement and Compliance, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530-R -9 9- 0 60 U.S Environmental Protection Agency... L1533_frame_C 09 Page 240 Tuesday, May 1, 2001 12:41 PM U.S Environmental Protection Agency 198 6 RCRA Ground-Water Monitoring Technical Enforcement Guidance Document, OSWER Directive Number 99 50.1 Office of Waste Programs Enforcement, Washington, D.C U.S Environmental Protection Agency 199 7 Introduction to Closure/Post-Closure, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530-R -9 7-0 48 U.S... 880 F.2d 1033, 103 8-1 040 (9th Cir 198 9), the defendant was convicted of disposing of hazardous waste without a permit even though he neither knew the material was an RCRA hazardous waste nor that the party actually doing the disposal lacked a RCRA permit The court found knowing disposal of a hazardous waste when, even though the defendant did not know the paint was an RCRA hazardous waste, he did know... 530R -9 7-0 55 U.S Environmental Protection Agency 199 8 A Multimedia Strategy for Priority Persistent, Bioaccumulative, and Toxic (PBT) Pollutants, Office of Pollution Prevention and Toxics, Washington, D.C U.S Environmental Protection Agency 199 8a Pollution Prevention Solutions during Permitting, Inspections and Enforcement, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530-R -9 8-0 15... Ground Water and Soil Cleanup National Academy Press, Washington, D.C Porter, Amy 199 9 “EPA Suspends Consideration of RCRA Bill While Settling Corrective Action Suit,” in Environment Reporter February 19, 199 9, pp 2074–2075 Bureau of National Affairs, Washington, D.C Sara, Martin N 199 3 Standard Handbook for Solid and Hazardous Waste Facility Assessments Lewis Publishers, Ann Arbor, MI 11 The name of the... Wasson, Eugene R 2000 Hazardous Materials Management Desk Reference, Doye B Cox, Editor-in-Chief, Adriane P Borgias, Technical Editor, McGraw-Hill, New York, Chapter 2 With permission.) © 2001 by CRC Press LLC L1533_frame_C 09 Page 2 39 Tuesday, May 1, 2001 12:41 PM while promoting the public’s right-to-know.11 The Compliance Assistance program claims that the nine compliance centers on-line received an... of the differences REFERENCES Corbitt, Robert A 198 9 Standard Handbook of Environmental Engineering McGraw-Hill, NY DeCamp, Gregory C 2000 “RCRA Overview: A Generator Perspective,” Chapter 35, in Hazardous Materials Management Desk Reference, Doye B Cox, Editor-in-Chief, Adrianne P Borgias, Technical Editor, McGraw-Hill, NY National Research Council 199 7 Innovations in Ground Water and Soil Cleanup . the individual facility ( see also: EPA 198 6; EPA 199 7c; EPA 199 8, Chapter 10; NRC 199 7, ES- 7, Chapter 1; Corbitt 198 9, pp. 9. 78ff; Sara 199 3, Chapter 10). Inspections The preferred method. EPA 53 0- F -9 8-0 26. U.S. Environmental Protection Agency. 199 8d. RCRA Orientation Manual, Office of Solid Waste, Washington, D.C., EPA 530-R -9 8-0 04. U.S. Environmental Protection Agency. 199 8e. Elizabeth. D.C., EPA 530-R -9 7-0 48. U.S. Environmental Protection Agency. 199 7a. Introduction to RCRA Corrective Action, Office of Solid Waste and Emergency Response, Washington, D.C., EPA 530-R -9 7-0 65. U.S.