&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
r
DIRECTIVE NUMBER: 9610.5-1
TITLE: TRANSITION TASKS LIST
APPROVAL DATE: January 30, 1989
EFFECTIVE DATE: January 30, 1989
ORIGINATING OFFICE: OUST
SPINAL
D DRAFT
STATUS:
REFERENCE {other documents): OSWER Directive
9610.5 - "FY 1989 - FY 1990 Transition Strategy for
the UST Program."
OSWER OSWER OSWER
'E DIRECTIVE DIRECTIVE Dl
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fl ^QJL United States Environmental Protection Agency
ofcm OSWER Directlvelnitiation Request
2. Originator Information
1. Directive Number
9610.5-1
Name of Contact Person
Josh Baylson
Mail Code
OS-420
Office
OUST
Telephone Code
475-9725
Transition Tasks List
. Summary of Directive (include brief statement of purpose) ———————————
The Transition Tasks^List supplements the Transition Strategy for the UST Program and
xs a guide for negotiating agreements with the States to implement the final UST
regulations during the transition period.
UST regulations, transition period, implementing agency
b. Does It Supplement Previous Directive(s)?
No
No
X
Yes
Yes
What directive (number, title) Draffc
DRAFT Transition Tasks List
What directive (number, tftle) 9610.5
PY1989 - FT1990 Transition
for- tho
I Level
A-SignedbyAA/DAA
B - Signed by Office Director
C - For Review & Comment
D-In Development
8. Document to be distributed to States by Headquarters?
Yes
-X.
No
Thla Request Meets OSWER Directives System Format Standards.
Beverly
:e Directives Coordinator
asiDirlctives Coordinator, OUST
Date
Ron Brand, Director, Office of Underground Storage Tanks
; /
/3V?-?
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
-------
&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
r
DIRECTIVE NUMBER: 9610.5-1
TITLE: TRANSITION TASKS LIST
APPROVAL DATE: January 30, 1989
EFFECTIVE DATE: January 30, 1989
ORIGINATING OFFICE: OUST
m FINAL
D DRAFT
STATUS:
REFERENCE (other documents): OSWER Directive
9610.5 - "FY 1989 - IY 1990 Transition Strategy for
the UST Program.*'
OSWER OSWER OSWER
TE DIRECTIVE DIRECTIVE Dl
-------
&EPA
Washington, DC 20460
OSWER Directive Initiation Request
1. Directive Number
9610.5-1
2. Originator Information
Name of Contact Pereon
Josh Baylson
OHie
MaH Code
OS-420
Office
OUST
Telephone Code
475-9725
Transition Tasks List
4. Summary of Directive (include brief statement of purpose) • ^—————_
The Transition Tasks List supplements the Transition Strategy for the UST Program and
is a guide for negotiating agreements with the States to inplement the final UST
regulations during the transition period.
5. Keywords
UST regulations, transition period, implementing agency
6a. Does This Directive Supersede Previous Directive(s)?
b. Does R Supplement Previous Directive(s)?
No
No
Yes What directive (number, title) jvaf*.
DRAFT Transition Tasks List
Yes What directive (number,title) 9610.5
PY1989 - FY1990 Transition
frvr t"hp IT^T Pr-no-rai
7. Draft Level
A-SignedbyAA/DAA
B - Signed by Office Director
C—For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters?
Y«s
_X
No
This Request Meets OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
Beverly Thomas, Directives Coordinator, OUST
10. Name and Title of Approving Official
//^ tS'****
Ron Brand, Director, Office of Underground Storage Tanks
Date
DM.
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JAN 30 689
MEMORANDUM
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER DIRECTIVE 3610.5-1
SUBJECT: Final Transition Tasks list
FROM: Ron Brand, Director
Office of Underground Storage Tanks
TO: Waste Management Division Directors,
Regions I-III, V-IX
Water Management Division Directors,
Regions IV and X
The enclosed Transition Tasks List identifies the
universe of tasks specified in the final underground storage tank
regulations (40 CFR Part 280) that are a responsibility of the
implementing agency. This list is designed to aid the Regions in
negotiating agreements with the states to conduct these tasks.
EPA's goal is to have the States conduct most of these tasks
during the transition period before State program approval. All
tasks that States agree to conduct as the implementing agency or
on behalf of EPA must be included in formal transition
agreements. This includes both tasks identified in the following
pages as specified and optional.
This document is an updated and final version of the
September 29, 1988, Draft Transition Tasks List (Draft OSWER
Directive 9610.5-1). Minor changes were made to Part 1 of the
document (technical standards and corrective action
requirements). Peirt 2 was" substantially revised and reordered to
reflect the provisions of the final financial responsibility rule
(dated October 26, 1988).
We hope this list facilitates the development of transition
agreements with the States. These agreements will play a seminal
role in implementation of the UST regulations during the
transition period. For additional information or clarification,
please contact Josh Baylson (FTS 475-9725), of my staff.
Attachment
cc: UST Regional Program Managers
UST Program Regional Attorneys
Kirsten Engel, OGC
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OSWER DIRECTIVE 9610.5-1
TRANSITION TASKS LIST
The Transition Tasks List supplements the "FY 1989 - FY 1990
Transition Strategy for the UST Program"
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OSWER DIRECTIVE 9610.5-1
Transition Tasks List - Part 1
•Technical Standards and Corrective Action Requirements
CFR Part 280: Subparts A - G
The definition of implementing agency in the UST technical
standards and corrective action requirements has been written to
allow the State to be the implementing agency during the
transition period for those tasks that they agree to perform.
Thus, the concept of implementing agency is divisible, with the
State considered the implementing agency for those tasks they
agree to conduct, and EPA remaining the implementing agency for
the balance of specified tasks.
Subparts A through G of the UST technical standards and
corrective action requirements specify only 9 tasks as
responsibilities of the implementing agency. EPA's goal is to
have States assume and conduct all 9 of these tasks during the
transition period. States with UST program grants and LUST Trust
Fund cooperative agreements already are performing many of these
tasks .
UST OF SPECIFIED TASKS (Subparts A - Gl
*• Receive notifications 16280.221 and certifications of
installation r«a280.20(e)1 of new UST systems.
All 'States will continue to receive notifications as
required in the final regulations [6280. 22(a) ] . This is a
regulatory requirement and need not be included in
transition agreements.
2- Answer calls reporting releases, including suspected
releases reZSO.SOI. spills and overfills ffl280.S31 . anri
confirmed releases re280.52 & 3280.611.
3- Receive reports of corrective actions taken or planned.
including initial abatement measures fe280.62fbn.
4« Receive initial site character! gat ion reports re280.€31.
5- Peceive free product removal reports and determine the
practicable extent for free product removal f 6280.6*1.
6- Under certain conditions . request and receive reports pf
investigations of the magnitude and extent of soil anfl
ground-water contamination re28Q.65V.
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OSWER DIRECTIVE 9610.5-1
7. Receive, review, and evaluate required and voluntarily
of implementing the plans f@280.66l. For each corrective
action plan requiredf provide notice to the public of the
release and the corrective action plan fe280.67l. Oversee
implementation of corrective action plans.
Tasks 2-7 refer to the corrective action requirements.
and will occur only after a release is suspected or
confirmed. Many states are currently conducting these, or
similar, activities as part of their LUST Trust Fund
cooperative agreements. States should be asked to continue
to conduct these activities related to releases of petroleum
from UST systems as part of their Trust Fund cooperative
agreement work plans. In addition. States should be asked
to conduct tasks 2-7 related to releases of hazardous
substances from UST systems as part of their program grant
work plans.
8. Receive notifications prior to permanent closure or change-
in-service r@280.7l1.
9. Receive records of excavation zone assessments at closure if
the records cannot be kept at the site or an alternate site
for 3 years r@280.741.
States now are receiving new tank notifications (Task
1) and likely will want to receive notices of intent to
close or change-in-service (Task 8). Task 9 will occur only
if the records cannot be kept at the site or an alternate
site. States should be asked to perform tasks 8 and 9 as
part of their program grant work plans.
In addition, both states and Regions will need to be
prepared to respond to Freedom of Information Act (FOIA) requests
and to follow regulatory requirements for public participation in
the program.
In summary, most of the 9 tasks are based on receiving
reports or notices: tasks 1 and 8 are related to management of
States' notification data, an activity most States currently are
conducting; tasks 2 through 7 relate to the corrective action
regulations and will occur only when an owner or operator reports
a suspected or confirmed release; and task 9 will occur only in a
limited number of cases.
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OSWER DIRECTIVE 9610.5-1
1; LIST OF SPECIFIED MOD OPTIONAL TASKS fSDBPARTS A - (?)
The following is a more complete listing of tasks for the
implementing agency. The tasks are identified as either:
S = SPECIFIEP: explicitly described in the UST regulations as a
responsibility of the implementing agency or implied to be a
responsibility of the implementing agency based on a
requirement placed on owners and operators; or
O = OPTIONS; carried out at the discretion of the implementing
agency. .
/
The specified tasks are a repetition of the previous list.
Guidance for implementation of the specified tasks is indicated
below each task as options for State or Regional implementation
during the transition period. The tasks identified as optional
indicate program areas for the Regions to work with States to
enhance capability.
SUBPART A - PROGRAM SCOPE AND INTERIM PRQHIBTTJQN
O Pursue violations of the Interim Prohibition for deferred
UST systems [(§280.11].
SUBPART B - UST SYSTEMS! DESIGN. CONSTRUCTION,
INSTALLATION & NOTIFICATION
O Determine if proposed alternatives for tank design,
construction, and corrosion protection are no less
protective [6280.20(a)(5)].
O Determine if proposed alternatives for piping design,
construction, and corrosion protection are no less
protective [6280.20(b)(4)].
O Determine if proposed alternatives for spill and overfill
prevention equipment are no less protective [6280.20
Certify or license installers [@280.20(e)(2)].
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OSWER DIRECTIVE 9610.5-1
. 6
O Inspect and approve installations [€280.20(e)(4)].
O Determine if proposed alternative installation methods are
no less protective [6280.20(e)(6)].
O Determine if proposed alternative methods for assessing
tanks for corrosion holes are no less protective
[e280.21(b)(2)(v)].
S Receive notifications [@280.22] and certifications of
installation [€280.20(e)] of new UST systems.
[All States will continue to receive notifications as
required in the final regulations [@230.22(a)]. This is a
regulatory requirement and need not be included in formal
transition agreements.]
O Follow-up on notification forms to enhance compliance, e.g.,
forms that are incomplete, contain information indicative of
a violation, or have not been submitted by the o/o
[€280.22],
O Update notification data base.
SUBPART C - GENERAL OPERATING REQUIREMENTS
O Establish alternative time frame for testing of cathodic
protection systems [@280.31(b)(1)].
O Determine that alternative post-repair test method is no
less protective [@280.33(d)].
SUBPART D - RELEASE DETECTION
O Approve use of proposed alternative release detection
methods for hazardous substance UST systems
[e280.42(b)(5)(iii)3,
O Approve use of proposed alternative release detection
methods (petroleum tanks) and set conditions for their use
[€280.43(h)(ii)].
AND CONFIRMATION
Some States currently are operating clean-up programs that
include reporting requirements that differ from the federal
requirements. It is not EPA's intent to place an unreasonable
burden on owners and operators in those States. Therefore, if
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OSWER DIRECTIVE 9610.5-1
7
State requirements are entirely auplicative of the federal
requirements, the submission of a separate federal report is not
necessary if the State has agreed to conduct the related task(s)
-as part of a transition agreement. --However, before State program
approval, any federally required reports that are not duplicated
by State reporting requirements must be submitted by owners and
operators to the implementing agency.
Regions should ask states to receive reports required under
Subparts E and F for petroleum releases as part of their LUST
Trust Fund cooperative agreement work plans and for hazardous
substance releases as part of their program grant work plans.
S Answer calls reporting releases, including suspected
releases [6280.50], spills and overfills [€280.53], and
confirmed releases [6280.52 & €280.61].
Option 1: State agrees to answer calls as part of Trust Fund
cooperative agreement and/or program grant work plans.
Region refers calls it receives to the State.
Option 2: Region receives and maintains a log of calls.
Region will continue to work with the State to conduct this
task. . •
O Require o/o to determine if the UST system is the source of
off-site impacts [€280.51].
O Establish alternative time frame for o/o to investigate and
confirm suspected releases [€280.52],
O Establish alternative time frame for o/o to report suspected
releases, spills and overfills, and confirmed releases
[€280.53(a)].
O Establish alternative amount for petroleum spills and
overfills that o/o must contain and immediately clean up
[€280.53(b)3.
SUBPART F - RELEASE RESPONSE AMD CORRECTIVE ACTION
O Follow up on reports of confirmed releases, -e.g., site
visits.
O Establish alternative period of time after a release is
confirmed within which o/o must perform initial response
actions [€280.61]
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OSWER DIRECTIVE 9610.5-1
8
Receive reports of corrective actions taken or planned,
including initial abatement measures 16280.62(b)].
Option 1: State agrees to receive reports as part of Trust
Fund cooperative agreement and/or program grant work plans.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. Owners and operators may
proceed with corrective actions without a response from the
implementing agency. RP-lead corrective actions occur with
limited direct supervision from the Region or the State.
Region will continue to work with the State to conduct this
task.
Follow up on reports of corrective actions taken or planned,
e.g., site visits.
Receive initial site characterization reports [€280.63].
Option 1: State agrees to receive reports as part of Trust
Fund cooperative agreement and/or program grant work plans.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. RP-lead corrective
actions occur with limited direct, supervision from the
Region or the State. Region will continue to work with the -
State to conduct this task.
Follow up on initial site characterization reports.
Receive free product removal reports and determine the
practicable extent for free product removal [@280.64].
Option l: state agrees to receive reports as part of Trust
Fund cooperative agreement and/or program grant work plans.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. RP-lead corrective
actions occur with limited direct supervision from the
Region or the State. Region will continue to work with the
State to conduct this task.
Follow up on free product removal reports.
Under certain conditions, request and receive reports of
investigations of the magnitude and extent of soil and
ground-water contamination [$280.65].
Option 1: State agrees to request and receive reports as
part of Trust Fund cooperative agreement and/or program
grant work plans.
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OSWER DIRECTIVE 9610.5-1
Option 2: Region requests 'and receives reports and keeps
-them until the State agrees to conduct this task. RP-iead
corrective actions occur with limited direct supervision
from the Region or the state. Region will continue to work
with-the State to conduct this task.
O Follow up on reports of investigation of soil and ground-
water contamination.
S ' Receive, review, and evaluate required and voluntarily
submitted corrective action plans (CAPs) and reports of the
results of implementing the plans [€280.66]. For each
corrective action plan required, provide notice to the
public of the release and the corrective action plan
[6280.67]. Oversee implementation of corrective action
plans.
Option 1: state agrees to receive, review, evaluate, and
provide notice of CAPs as part of Trust Fund cooperative
agreement and/or program grant work plans.
Option 2: Region receives, reviews, evaluates, and provides
public notice of CAPs until the state agrees to conduct this
task. RP-lead corrective actions occur with limited direct
supervision from the Region or the State. Region will
continue to work with the State to conduct this task.
SUBPART G - QUT-QF-SERVICE UST SYSTEMS AND CLOSURE
O Grant extensions of the 12-month temporary closure period
[@280.70(c)].
S Receive notifications prior to permanent closure or change-
in-service [@280.71].
Option l: state agrees to receive reports as part of program
grant work plan.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. Region will continue to
work with the state to conduct this task.
O Review excavation zone assessments.
O Direct o/o of UST systems closed before December 22, 1988,
to assess the excavation zone and properly close the UST
system £€280.73].
S Receive records of excavation zone assessments if the
records cannot be kept at the site or an alternate site for
3 years [6280.74].
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OSWER DIRECTIVE 9610.5-1
10
Option 1: State agrees to receive records as part of program
grant work plan.
Option 2: Region receives records and keeps them until the
State agrees to conduct this task. Region will continue to
work with the State to conduct this task.
Reports of releases discovered at closure trigger the tasks
associated with the corrective action regulations (Subpart F).
COMPLIANCE MONITORING AND ENFORCEMENT TASKS
O Conduct outreach and compliance assistance activities to
promote compliance.
t
O Conduct site inspections (e.g., random, targeted, new tank
installations, or closures). Review o/o records, including
records regarding repairs, corrosion protection, and release
detection.
O Conduct enforcement activities related to the LUST Trust
Fund.
O Use formal enforcement actions to pursue violations of
Subparts A through H.
O Pursue Interim Prohibition violations.
In addition, both states and Regions will need to be
prepared to respond to Freedom of Information Act CFOIA) requests
and to follow regulatory requirements for public participation in
the program.
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OSHER DIRECTIVE 9610.5-2
11
Transition Tasks List - Part 2
Financial Responsibility Requirements
40 CFR Part 280: Subpart H
The definition of implementing agency in the financial
responsibility
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OSWER DIRECTIVE 9610.5-1
"12
15. Receive notifications of cancellation or non-renewal of
coverage f(3280.105(b) 1.
16. Receive copies of -the financial responsibility mechanism
from owners and operators in the event, of a release
1^280.1061 or in the event of failure to obtain alternate
coverage within 30 days of notice of incapacity by provider
of financial assurance f3280.106 & ^280.1101.
17. Direct guarantorsr suretiesr and institutions (letters of
credit) to deposit money into standby trust funds
16280.108(a)1.
18. Effect the drawdown of standby trust funds f6280.108(bll.
19. Receive notices from owners or operators of the commencement
of bankruptcy proceedings and copies of financial assurance
instruments documenting current financial responsibility
f@280.1101 ..
Tasks 10, 14, 17, and 18 are necessary only for those owners
or operators who choose to use guarantees, surety bonds, or
letters of credit to meet all or part of their financial
responsibilities. These instruments require the creation of a
standby trust fund. Tasks 14, 17, and 18 will occur only after
the reporting of a confirmed release.
States should be asked to conduct tasks 10. 11. 15. 16. and
19 as part of their program grant work plans. Task 10 likely
will occur once per State. Task 11 will occur only a very
limited number of times. States that are receiving new tank
notifications and/or notifications of closures very likely will
want to conduct tasks 15, 16, and 19.
Tasks 12. 13. 14P 17. and 18 must be performed by EPA
(Regional Administrator) during the transition period. States,
however, are required by the final regulations to provide the
letter or certificate to owners/operators related to Task 12.
This list does not include tasks associated with suspension
of enforcement of the financial responsibility requirements. The
following appendix includes other tasks related to the financial
responsibility requirements in the final rule, including optional
tasks, and a discussion of suspension of enforcement.
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OSWER DIRECTIVE 9610.5-1
13
ftPPEHPIK 2t LIST OF SPECIFIED AND OPTIOMM. TASKS ISOBPART H>
The following is a more complete listing of tasks for the
implementing agency. The tasks are identified as either:
S • SPECIFIED: explicitly described in the UST regulations as a
responsibility of the implementing agency or implied to be a
responsibility of the implementing agency based on a
requirement placed on owners and operators; or
O = pPTTQWAL; carried out at the discretion of the implementing
agency.
The specified tasks are a repetition of the previous list.
Guidance for implementation of the specified tasks is indicated
below each task as options for State or Regional implementation
during the transition period. The tasks identified as optional
indicate program areas for the Regions to work with States to
enhance capability.
SUBPART H - FINANCIAL RESPONSIBILITY
Receive State Attorney General's certification that
guarantees and/or surety bonds are legally valid and
enforceable obligations in that State [@280.94(b)J.
Option l: state agrees to request and receive certification
as part of program grant work plan.
Option 2: Region will continue to work with the State to
conduct this task.
Request and receive reports of financial condition at any
time [§280.95(fJ] (self insurance only).
Receive notices that o/o no longer meets the financial test
of self insurance t@280.95(g)].
Option 1: state agrees to receive notices as part of program
grant work plan.
Option 2: Region receives notices and keeps them until the
State agrees to assume this task. Region will continue to
work with the State to conduct this task.
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OSWER DIRECTIVE 9610.5-1
•; 14
O Notify guarantor that he no longer meets the requirements of
the financial test of self insurance C@280.96(b)].
O To promote compliance, follow-up on notices that o/o and
guarantors no longer meet the requirements of the financial
test of self insurance.
S Receive description, evaluate, determine acceptability of
use, and notify States of determination for State trust
funds and other State (including State-required) assurance
mechanisms [6280.100 & $280.101]. Within 60 days of EPA
approval, provide to each o/o for which the State is
assuming financial responsibility a letter or certificate to
that effect [6280.101(d)].
[This task must be performed by the EPA Regional
Administrator. It may not be delegated to or conducted by
States during the transition period or after State program
approval. The final regulations require that States provide
the letter or certificate to o/o.]
S Instruct the trustees of trust funds to release excess funds
to o/o [6280.102]. (This refers to an o/o's trust fund, not
standby trust funds or State trust funds.)
[This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Instruct trustees to refund balances of standby trust funds
to providers (guarantors) after all costs and claims have
been settled [@280.103(c)].
[This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Receive notifications of cancellation or non^-renewal of
coverage [6280.105(b)].
Option 1: State agrees to receive notices as part of program
grant work plan.
• Option 2: Region receives notices and keeps them until the
state agrees to assume this task. Region continues to work
with the State to conduct this task.
O To promote compliance, follow-up on notifications of
cancellation or non-renewal of coverage.
S Receive copies of the financial responsibility mechanism
from owners and operators in the event of a release
[€280.106] or in the event of failure to obtain alternate
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OSWER DIRECTIVE 9610.5-1
•-.•-.
' 15
. '
coverage within 30 days of notice of incapacity by provider
of financial assurance [£280.106 & 6280.110].
Option l: State agrees to receive copies of the mechanisms
as part of program grant work plan.
Option 2: Hegion receives copies of the mechanisms and keeps
them until the State agrees to assume this task. Region
will continue to work with the State to conduct this task.
O Request and receive evidence of financial assurance or other
information from o/o at .any time £€280.106(c)],
S Direct guarantors, sureties, and institutions (letters of
credit) to deposit money into standby trust funds
[6280.108(a)].
[This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Effect the drawdown of standby trust funds [6280.108(b)].
[This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Receive notices from owners or operators of the commencement
of bankruptcy proceedings and copies of financial assurance
instruments documenting current financial responsibility
[6280.110].
Option 1: state agrees to receive bankruptcy notices as part
of program grant work plan, states receiving notifications
or closure notices likely will want to receive notices of
bankruptcy or incapacity.
Option 2: Region receives bankruptcy notices and keeps them
until the Statte agrees to assume this task. The Region will
continue to work with the State to conduct this task.
Suspension of Enforcement
The April 1987 proposed rule contained relatively detailed
procedures for suspension of enforcement of the financial
responsibility requirements. Based on comments and the
uncertainty over the number of suspension applications likely to
be received, EPA has deferred promulgation of procedures for
suspension of enforcement.
The final regulations phase in the financial responsibility
requirements over 21 months. EPA recognizes that the
availability of financial assurance mechanisms (particularly
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OSWER DIRECTIVE 9610.5-1
16
State funds) may change dramatically over time. In the meantime,
some States may receive State program approval. Thus, there is
significant uncertainty over whether, and to what extent,
suspension of enforcement will be necessary in the future. As
the necessity is demonstrated, JEPA will adopt procedures for
suspension of enforcement. Until such time, however, EPA does
not intend to exercise its discretionary suspension authority.
Therefore, tasks associated with suspension of enforcement of the
financial responsibility requirements have not been included in
this document. * .
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