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10~13/8~ FRI 10:17 FAb 303 283 1238 R8 SUPERFLRQD REMEDIAL BR <br />__,,~ ~ <br />,, <br />.I'll n n.~~ <br />00000 III IIIIIIIIIIIIIIII <br /> <br />~~~. <br />~~ JNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />WASHINGTON, D.C. 206fi0 <br />~L <br />FE8 6 egg <br />MEMORANDUM <br />SUBJECT: Contracto <br />Manifests <br />FROM: Russel H. <br />Hazardous <br />T0: Superfund <br />Pur ose: <br /> <br />OFFICE OF <br />So IID W0.5T6 AND EMERGENCE RESPONSE <br />r Signing of Uniform azardous Waste. <br />for Materials Lea i a Superfund Site <br />Wyer, Directo <br />Site Control D si n <br />Branch Chiefs, Regions I-X <br />To resolve the issue of whether EPA's remedial action <br />contractors may Sign, on EPA's behalf, the uniform hazardous <br />waste manifests without changing their generator status. <br />Background,: <br />It has come to my attention that certain remedial action <br />contractors working undes contract for EPA at Superfund sites <br />have been unwilling to sign the uniform hazardous waste manifest <br />forms because they believe that, by signing, they would assume <br />liability as hazardous waste generators. Of concern is whether <br />EPA Regional Superfund staff would be required to be present <br />during remedial actions at Superfund sites which involve off-site <br />transport of hazardous wastes for the purpose of signing these <br />forms. Regional Project Managers would be required to spend many <br />hours at the site, diverting them from their appropriate program <br />management roles. <br />Objective: <br />This memo will resolve this issue by referring to and <br />applying the requirements of the applicable Federal regulation <br />associated with manifests for hazardous wastes. <br />