vv EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9481.09(84)
TITLE: Corrective Action During Interim Status
APPROVAL DATE: 7-30-84
EFFECTIVE DATE: 7-30-84
ORIGINATING OFFICE: office of solid waste
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
[' ],_"' A~ Pending OMB approval
[ ] '< B- Pending AA-OSWER approval
[ ] . C- For review &/or conment-
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PARTS 264 AND 265 SUBPART F - GROUND-WATER PROTECTION
DOC: 9481.09(84)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Corrective Action, Interim Status
40 CFR 265 Subpart F
Corrective Action During Interim Status
James H. Scarbrough, EPA Region IV
John H. Skinner, Director, Office of Solid Waste
#9481.09(84)
7-30-84
of
An interim status facility may begin corrective action prior to issuance
a permit. EPA does not have authority to prevent such action.
Regional offices are encouraged to lend technical assistance to facility -
owners or operators preparing corrective action plans under interim status.
Permit writers should be encouraged to work with facilities to write a plan
they can live with. However, a plan prepared during interim status may not be
in compliance with the corrective action program under 40 CFR §264.100. The
Regional office technical staff should emphasize to owner/operators that the
plan is subject to review and possible change before it is incorporated into
the final permit. _
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9431.09 (34)
'Implementation of Corrective Action for Contaminated
Ground Water Prior to Issuance of a RCTA Permit
John H. Skinner, Director
Office of solid Waste "I —
- -- • - - -- -• ' tflL 30 S84
James H. Scarbrough _ .
EPA Region IV """",""
In your memo of July 12, 1984, you-asked whether an
interim status RCRA facility can voluntarily begin corrective
action on contaminated ground water prior to issuance of the
RCRA perait. ' , •••
r f
We agree that a facility owner or operator nay begin
corrective action prior to issuance of a perait. It is
environnentally sound to allow and encourage such activity.
In addition, the Agency does not have the authority to prevent
the owner or operator from beginning corrective action* -_,
We encourage regional offices to lend technical assistance
to those facility owners preparing a corrective action plan.
The regions should check to be sure the plan is actually
correcting the ground-water contamination problem, not
exacerbating it.
Facility owners expressing interest in performing correc-
tive action during interim status should fully understand
the coaplex nature of the program. The plan prepared during
interim status will not necessarily be in compliance with
the corrective action program under 40 CPR 5264.100; Therefore,
the regional office technical staff should emphasize to the
facility owner or operator that the plan is subject to review
and possible chamje before it is incorporated Into the final
permit.
WH-565:PSbar:as:rm2106:382-3345:WSM:7/21/84
OSWO73
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