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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