&EPA
UnitM SIMM
£nvironm«nul Protection
Off'C* of
Solid Wjjie «na
DIRECTIVE NUMBER: 9502.00-3
TITLE: Implementation of UIC Corrective Action Requirement
APPROVAL DATE: os-04-86
EFFECTIVE DATE: 08-04-86
ORIGINATING OFFICE: osw
& FINAL
D DRAFT
STATUS:
REFERENCE (othar documents):
[ ] A- Pending OMB approval
[ j B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- In development or circulating
headquarters
'£ DIRECTIVE DIRECTIVE D
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FxvEPA
OSWER Directive Initiation
Name of Contact Person
Dave Pagan
Lead Office
D OERR
S OSW
D OUST
O OWPE
d AA-OSWER
Mai: Code
WH-563
Or^naror Informavor
Request
Q-./ -;-";;'
- Branch Telepnone Numoer
PSPD Permits 382-4740
Approved fat Review
Signature of
Office Director
Date
Implementation of UIC Corrective Action Requirements
Summary of Directive
Guidance on issuance of UIC permits to implement RCRA Corrective Action
requirements under 264.101 and 270.60. Clarifies UIC program guidance #45.
Key Words:
Corrective Action, Underground Injection
Type of Directive iMtnual. Policy Directive. Announcement, etc.i
Memo to Regions
' Status
i
I
D Draft
D Final
tJ New
!_l Revision
Does- this Directive Supersede Previous Directive^* | | Yes l^-l No Does It Supplement Previous Directive^ (jfj Yes • LJ No
if "Yes" to Either Question. What Directive (number, tititi Underground Injection Control Program Guidance #45
Interim Guidance concerning Corrective Action for Prior and Continuing Releases
Review Plan
D AA-OSWER
D OERR
O OSW
D OUST
D OWPE
LJ Regions
D OECM
D OGC
D OPPE
D
Other (Specify!
This Request Meets OSWER Directives System Format
Sigrature of Lead Office Directives Officer
: Date
Signature of OSWER Directives Officer
Date
I
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
AUG 4
MEMORANDUM
OSWER Policy Directive * 9502.00
SUBJECT: Implementation of UIC Corrective Action Requirements
A ,•' . f n '
FROM: Michael B. Cook, Direct
Office of Drinking Wate
A/
Marcia Williams, Director / jftAd.
Office of Solid Waste
TO: Charles H. Sutfin, Director
Water Division, Region V
Basil G. Constantelos, Director
Waste Management Division, Region V
Several issues have recently been raised by Region V
regardinq how RCRA corrective action requirements under §3004(u)
should be addressed when issuing permits to hazardous waste
injection wells under the_ Safe Drinking Water Act. This
memorandum is intended to clarify several points of guidance
contained in Underground Injection Control Guidance #45, issued
on April 9, 1986.
As outlined in the above guidance, a UIC permit may be
"issued to a hazardous waste injection well at a RCRA interim
status facility, without addressing the requirements of RCRA
§3004(u). In such case, the well retains RCRA interim status
until such time as the entire facility is addressed for the
purposes of corrective action. When the §3004(u) requirements
have been addressed for the entire facility, the well obtains
a RCRA permit by rule. The §3004(u) requirement cannot be
implemented selectively at the well only.
For a UIC permit which is issued at an interim status facility
for which the §3004(u) requirement is not addressed, a corrective
action program for the injection well (as outlined in Section VIII
of Guidance #45) should be followed. Such corrective action
programs will be implemented under SDWA authorities, and need
not invoke RCRA §3004(u).
To the extent that existing SPMS accounting measures
specify that UIC permits for hazardous waste injection wells
must also be RCRA permits by rule, we will work to adjust
those measures to reflect the guidance in this memorandum.
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-2- OSWER Pol -.:•.• Di r,-
We appreciate the conplexity of these issues, and tne dif-
ficulties inherent in effectively coordinating and implementing
these new requirements. If you have any questions or further .
problems, please contact Ellen Berick in the Office of Drinking
Water (382-5547), or Dave Pagan in the Office of Solid V.'aste
(382-4740).
cc: Hazardous Waste Division Directors, Regions I-X
RCRA Branch Chiefs, Regions I-X
Water Division Directors, Regions I-X
Drinking Water Branch Chiefs, Regions I-X
B. Weddle
P. Bait ay
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