United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
oEPA
DIRECTIVE NUMBER: 96io.i
TITLE: When is a Tank Considered to be Installed
APPROVAL DATE: November 1985
EFFECTIVE DATE: November 1985
ORIGINATING OFFICE: OUST
m FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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&EPA
United States Environmental Protection Agency
Washington, DC 20460
OSWER Directive Initiation Request
Interim Directive Number
9610.1
Originator Information
Name of Contact Person
Steve Nacht
Mail Code
WH-562A
Telephone Number
382-7904
Lead Office
D OERR
D OSW
Lfil OUST
D OWPE
Approved for Review
Signature of Office Director
AA-OSWER
Date
Title
When is a Tank Considered to be Installed
Summary of Directive
Determination of the date an underground storage tank
is considered to be "installed" for purposes of the Interim
Prohibition.
Type of Directive (Manual, Policy Directive, Announcement, etc.)
Policy Interpretation
Status
D Draft
SI Final
CH New
I—I Revision
Does this Directive Supersede Previous Directive(s)? | | Yes
If "Yes" to Either Question. What Directive (number, title)
No Does It Supplement Previous Directive(s)? | | Yes fH No
Review Plan
LJ AA-OSWER [3 OUST
D OERR D OWPE
D OSW D Regions
OECM
OGC
OPPE
D
Other (Specify!
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
Mi
Date
Signature W OSWER Directives Officer
Date
EPA Form 1315-17 (10-85)
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9610.1
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
o ' '
- * WASHINGTON. O.C. 20460
OFFIC'E OP
SOLID WASTE AND EMERGENT* P!'
MEMORANDUM
FEB 10
SUBJECT: When is a Tank Considered to be Installed?
FROM: Stephen H.
Office of Underground Storage Tanks
TO: Ellen Siegler
Office of General Counsel
THRU: Ronald Brand, Director F~-
Office of Underground Storage Tanks
I have received a few inquiries regarding the point at which
a tank is considered to be "installed" for the purposes of the
Interim Prohibition. In other words, if the excavation starts
May 5, the tank(s) is placed in the ground May 5, 6, or 7, the
piping work is completed between May 6 and 9, and the excavation
is closed May 10, was the tank(s) installed on May 5, 7, or 10?
As a result of our phone conversation on February 7, we
decided that the tanks should be considered "installed" when the
first tank is placed into the excavation. This interpretation
should prevent anyone from avoiding the Interim Prohibition by
beginning the excavation before May 7 and installing the tanks
afterward. We should, perhaps, continue to discuss this issue as
it may affect the definition of when a tank is considered to be
"brought into use" for the purposes of the tank technical standards ,
I hope this accurately reflects our conversation. If not,
or if you wish to meet on this matter, please call me.
cc: P. Hansen
J. McCormick
OUST Staff
P. Cohn (WH-548D)
E. Cox (LE-134S)
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