SEPA Unitvd Statat Environmental Proiacuon A^ancy Ofl'ce oi Solid Watre and Emargancy Ratponsa DIRECTIVE NUMBER: 9524.01(82) RCRA Permits for Facilities that have Underground Tanks APPROVAL DATE: 2-8-82 EFFECTIVE DATE: 2-8-82 ORIGINATING OFFICE: m FINAL D DRAFT STATUS: Office of Solid Waste REFERENCE (other document*): [ ] A- Pending OMB approval [ ] B- Pending AA-OSWER approval C- For review &/or comment [ ] D- In development or circulating headquarters DIRECTIVE DIRECTIVE D ------- PART 270 SUBPART C — PERMIT CONDITIONS DOC: 9524.01(82) Key Words: Tanks Regulations: 40 CFR Parts 270, 264 Subpart J. Subject: RCRA Permits for Facilities that have Underground Tanks Addressee: Director, Air and Hazardous Waste Hanagement Division, Regions I—X Originator: Gary N. Dietrich, Director, Office of Solid Waste Source Doc: 1/9524.01(82) Date: 2—8—82 Summary; Permits which are being issued for tank storage facilities under Part B regulations do not apply to underground facilities that cannot be entered for inspection. (It should be noted that this limitation may not be apparent from- a Part A application). Facility operators of underground storage tanks that cannot be entered for inspection may exercise one of the following options: 1. The operator can voluntarily choose to provide access for inspection, or discontinue the use of the tanks which cannot be inspected. 2. The operator can continue to utilize those tanks under the interim status standards until such time as Part 264 regulations are promulgated. If the second option is taken, a second permitting action will occur after future relevant regulations are put forth. (Revised hazardous waste tank standards were proposed on June 26, 1985, that would be applicable to all hazardous waste storage! treatment tanks, even If not enterable for inspection. However, until these revised rules are promul— - gated, the above policy holds.) ------- 9524.01 (82) FEB8 1982 TO t )irectc,r kir an azardous / te 7er rtt !‘iv ion e ioni I — V FRC M: : “dry “. flietrich f 4 aJSiq .ne by ‘)irector ‘ - C ’ C) ic, of oli ‘ T a -te JrCTS PC Permits for ac1Uties at av Thn Chris C r’s Deeer ber 21, 1 l er on CP2 . riortjtjen ni Proce ure ‘ ag a arent1 , rai .qel wrie concernjr.e7 the per ittir g of tank st,ra,e f cilitje Ii ca1jjn y in P rt P a n1icatjons or facilities t’ at ‘ave stor ce ‘ r treat’i nt in tanks please rer!ember that these re nlatjons fl k LY to un r round fa ilitjes that cannot en ere1 or ins ectjon! In noet cas you will not be able to tc l1 from a T’art ? .. anrlicatjon whether an un arryr ufl tank can he ntare for inspection (or even if the tank is above or below ground). reforp, you r-t&, wsnt to contact these facilities orior to sendino the c lJ. letterg or nut 3o ething in the letter to ad- reea this. If you re calling for a t’ rt P anpli atjon Łrcrt facility that has a combination of un r round storace tan cs that cannot he entered 9 or insoectjon as well as other storane iiities (tan3 s that can be inenected, above c’rouncj tanks, or ConteIiner 3) the or tiong or the aci1itv o eratr,r are as f 1low 1) The or’erator can’voluntarily choose to install manholes or insnectir n, or the tanks which cannot be ins’,ectqd. 2) The ooerator can continue to uti1j those tanks mder he interj , status stan arde until such ti,,q as !‘art 7 4 :e u1acjons are nror ulqated. If they elect the second o ,tton -- - . race a second permittjna action after fn ’—- - - t orls ealina with u rr round tanks -: 15 at Least 12 to 1 months awa ’. • ,, ! .1.ntajfl a record o f thoqe facilities wMc P ic1nue to use these tanks so that foll up action c n be taken once the r ecc ,e regulate’ . ------- cc: Skinner E’eGeare Weddle Glazer Lingle Pegional Perr itting Corttacts (via Manifax) Levy ------- |