vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
TITLE:
9483.01(85)
Periitting of Underground Tanks That Cannot Be Inspected
APPROVAL DATE:; i-ie-85
EFFECTIVE DATE:: '-16-85
ORIGINATING OFFICE
0 FINAL
D DRAFT
STATUS:
Office of Solid,Waste
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Vj,Pending'OMB'approval-.
[ ] B-, Pending AA-OSWER approval ^
[' ] C-",For ^review &/or comment '~ L
t 1 D-.JIn developmentjor circulatii
REFERENCE (other documents):
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PARTS 264-265 SUBPART J - TANKS DOC: 9483.01(85)
Key Words: Tanks
Regulations: 40 CFR 264.190(b)
Subject: Permitting of Underground Tanks That Cannot Be Inspected
Addressee: James H. Scarbrough, Chief, Residuals Management Branch,
Region IV • •.'• • :
Originator: John H. Skinner, Director, Office of Solid Waste
Source Doc: 9483.01(85)
Date: 1-16-85
Summary:
The current tank regulations (Subpart G) of the Part 264 regulations do not
apply to underground tanks that cannot be entered for inspection. Therefore,
these tanks are not currently eligible to obtain a RCRA permit. In addition, -
certain tanks, which tecnically can be entered, but are unsafe due to high
levels of radioactivity, are treated in the same manner as tanks that cannot be
entered.
Proposed tank regulations will apply to all underground tanks.
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9483.01 (85)
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MEMORANDUM" '"; ' '"' ""' '" '"' '" •••"•--••• '-- ••- •" ••"•- ••'••
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SUBJECT: Application of RCRA to "Unique- ^ « '
Underground Storage Tanks a-
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PROM: John H. Skinner, Director \.
Office of Solid Waste (WH-562) £1
TO: James H, Scarbrough, Chief
Residuals Management Branch
Waste Management Division
Region IV
Thank you for your letter dated December 19, 1984,
concerning RCRA permits for two different underground tank
systems. I agree with your conclusion that these units
cannot be permitted.
Underground tanks that cannot be entered for inspection
cannot be permitted (40 CFR 264.190(b)J. Although the tanks :
described in your memo can "technically" be entered, they are c
unsafe due to high levels of radioactivity, as cited. If the f
applicant can demonstrate by reference to a law, regulation or z
Agency procedure, that the radiation levels are unsafe for t
inspection, then these tanks may not be permitted. Revised
tank regulations, which will be proposed in March 1985, will
apply to all underground tanks; the phrase "cannot be entered
for inspection" will be eliminated.
As requested by Don Gibeaut, I am attaching a copy of my
February 23, 1984, memo entitled, Guidance on Permitting of
Hazardous Waste Treatment/Storage Tanks. This mepp, in part,
includes a checklist to assist permit writers in permitting
tanks.
If you have any further permit guest ions regarding tanks,
please contact Nancy Pomerleau at FTS 382-4500.
Attachment
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