&EPA
               United States
               Environmental Protection
               Agency
 Office of
 Solid Waste and
 Emergency Response
               DIRECTIVE NUMBER: 9483.oi(&)

               TITLE: Definition of Tank and Surface Impoundment



               APPROVAL DATE: 4-15-83

               EFFECTIVE DATE: 4-15-83

               ORIGINATING OFFICE: Office of Solid Waste

               E FINAL

               D DRAFT

                STATUS:
[  ]  A- Pending OMB approval
[  ]  B- Pending AA-OSWER approval
[  ]  C- For review &/or comment
                          [  ]  D- In development or circulating

               REFERENCE (other documents):      headquarters
  OSWER      OSWER      OSWER
VE   DIRECTIVE    DIRECTIVE   Dl

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PARTS 264 AND 265  SUBPART J - TANKS
                                                DOC:  9483.01(83)
Key Words:

Regulations

Subject:

Addressee:


Originator:


Source Doc:

Date:

Summary:
Surface Impoundments, Tanks

40 CFR Part 264, Subparts J and K

Definition of Tank and Surface Impoundment

Thomas W. Devine, Director, Air and Waste Management
Division, Region IV

Bruce R.  Weddle, Acting Director, State Programs and
Resource Recovery Division

#9483.01(83)

4-15-83
     Distinguishing a tank from a surface impoundment is based on an assessment
of the unit's structural support.  In making this assessment, the unit should.
be evaluated as if it were free standing and filled to its design capacity with
the material it is intended to hold.   If the walls or shell of the unit alone
provide sufficient structural support to maintain the integrity of the unit
under these conditions, the unit can  be considered a tank.  Accordingly, if the
unit is not capable of retaining its  structural integrity without supporting
earthen materials, it must be considered a surface impoundment.

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                                                               9483.01 (83)
MEMORANDUM

SUBJECT:  Determination of Tanks vs. Surface Impoundments

FROM:     Bruce R. Weddle
          Acting Director
          State Programs and Resource Recovery Division (WH-563)

TO:       Thomas W. Devine
          Director
          Air and Waste Management Division, Region IV


     In your memorandum of -March 23, 1983 you requested headquarters
guidance on the subject of how regional offices should determine
what constitutes a "tank", as opposed to a "surface impoundment,"
for RCRA permitting purposes.  T hope that the following will
serve to clarify this issue.

     Distinguishing a tank from a surface impoundment is, as you
suggest, primarily an assessment of what provides the unit's struc-
tural support.  In making this assessment, the unit should be
evaluated as if it were free standing, and filled to its design
capacity with the material it is intended to hold.  If the walls
or shell of the unit alone provide sufficient structural support
to maintain the structural integrity of the unit under these condi-
tions, the unit can be considered a tank.  Accordingly, if the
unit is not capable of retaining its structural integrity without
supporting earthen materials, it must be considered a surface
impoundment.

     The units for which the State of Florida is requesting guidance
should be assessed according to these criteria.  From the sketches
provided by Florida Power and Light, it would appear that the    x  "
Sanford, Port Myers, Manatee and St. Lucie units are probably
surface impoundments, and that the Cutler unit may possibly be a
tank.  However, the information you submitted is not sufficient
to enable us to make a definitive judgement in this regard.  In
order to support the contention that the units should be considered
tanks, you should request that Florida Power and Light submit
engineering data and drawings which establish that each unit meets
the above criteria.

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