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

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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.)

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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 £rcrt 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’ .

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cc: Skinner E’eGeare
Weddle Glazer
Lingle Pegional Perr itting Corttacts (via Manifax)
Levy

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