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-
L-, J :T;D7_.^n development_Jor circulating

             ^headquarters', '
  OS WER      OS WER      OS WER
/    DIRECTIVE   DIRECTIVE    Di

-------
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. _	

-------
                                                             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

-------