United States EPA 510-F-93-011
Environmental Protection March 1993
Agency
Solid Waste And Emergency Response (OS-420WF)
vvEPA Streamlined
Implementation
A New Way To
LookAtUST
Corrective
Actions
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Some Background Information
Over the last two years about 1000 releases from
underground storage tanks (USTs) have been
reported every week, bringing the national total
to over 180,000 in December 1992. In most of
these cases, staff in state programs oversee
cleanups performed by tank owners and then-
contractors. However, the work of overseeing so
many cleanups is overwhelming state staff and
administrative systems.
"Streamlining" their cleanup procedures and
oversight systems is one way that states can meet
the demands of increased numbers of reported
releases. "Streamlining" means using total
quality management techniques, improved
technologies, and innovative regulatory
approaches to make cleanups faster, cheaper, and
more effective.
The Office Of Solid Waste And Emergency
Response (OSWER) has published OSWER
Directive 9650.13 entitled, "Streamlined Imple-
mentation of UST Corrective Action Require-
ments." The directive, which was released in late
1992, is an important part of EPA's strategy for
helping states cope with the challenges posed by
the growing numbers of release reports that they
are receiving.
This directive is a policy statement intended to
encourage states to streamline using the flexibility
that EPA wrote into the federal technical require-
ments for UST corrective actions (40 CFR 280
subpart F). The directive also can be useful to states
with regulations that differ significantly from the
federal regulations.
Why Streamline?
Streamlining can benefit implementing agencies,
tank owners and other interested parties, as well as
the environment, by making cleanups faster, less
expensive, and more effective. Streamlining can
help state and local UST programs:
« Begin cleanups sooner, making them more
effective in protecting the environment;
• Reduce delays in the cleanup process;
• Oversee more cleanups more effectively with
the same level of resources; and
• Reduce unnecessary paperwork, thereby cutting
the costs of plans and reports.
Why Did EPA Publish
This Directive?
The Agency believes that the national UST
program, which includes all "implementing
Agencies" and EPA itself, must renew its com-
mitment to innovation and improvement so that it
can meet the challenges posed by the growing
number of releases requiring corrective action.
The directive meets several new objectives for
EPA's streamlining work.
• It strongly affirms EPA's policy to support
streamlining, particularly in state programs
where most cleanups are managed.
• It clearly explains the flexibility in the federal
regulations and should eliminate some
perceived legal barriers to streamlining that
don't really exist.
• It provides programs with some fresh ideas
for streamlining that can help managers get
support for making changes within their
organizations.
• It should promote a more active dialogue
between regulators and other interested
parties on what improvements might be
possible in individual states.
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What It Does
This directive provides guidance and examples of
how agencies (primarily state UST programs)
have used and can use the flexibility in the
federal regulations to improve the efficiency and
effectiveness of their programs and make clean-
ups faster, cheaper, and more effective.
Even though the directive is based on the federal
regulations, many of the improvements described
can be implemented by states that have regula-
tions that differ significantly from those of EPA.
Streamlining has benefits for all programs,
including approved state programs. The
directive:
• Explains what streamlining means and why it
is an important part of EPA's policy.
• Identifies opportunities to carry out each
section of the federal UST corrective action
regulations in more flexible, efficient, and
cost-effective ways.
• Presents numerous examples of improve-
ments states can make and have made,
including:
- Combining or eliminating plans and
reports that require review and approval,
— Standardizing reporting formats,
Foregoing traditional, site-specific
corrective action plans for simple, low-
risk sites in favor of providing clear
guidance and monitoring results, and
Using field measurement techniques
instead of more costly laboratory
methods that tend to cause delays.
For More Information
For additional information or a copy of the
OSWER Directive 9650.13, contact EPA's
RCRA/Superfund Hotline, Monday through
Friday, 8:30 a.m. to 7:30 p.m. EST. The national
toll-free number is 800 424-9346; for the hearing
impaired, the number is TDD 800 553-7672.
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