Fact Sheet, July 2004
The purpose of this document is to provide guidance on transition issues related to program guidance for Underground Storage Tank owners and operators as well as environmental contractors and consultants.
This guidance applies to Leaking UST (LUST) sites doing site characterization, corrective action and closure in the LUST Program. It does not apply to waste oil releases. The Indiana Department of Environmental Management (IDEM) reserves the right to make site-specific decisions in order to ensure adequate protection of human health and the environment. The following non-rule policy documents (NPDs) apply:
- UST Branch Guidance Manual, October 1994 (UST 1994)
- Risk Integrated System of Closure (RISC), Technical Resource Guidance Document, February 15, 2001 (RISC 2001)
- RISC Technical Resource Guidance Document with January 1, 2004 Appendix 1 updates (RISC 2004)
- RISC User's Guide, Chapter 3 and related Appendices, February 15, 2001
- RISC Transition Policy, January 16, 2001
- RISC Technical Guide with January 31, 2006 Appendix 1 updates (RISC 2006)
The following are general guidelines related to transition:
- All releases reported on or after February 15, 2002 must use RISC.
- The changes from the RISC 2001 Appendix 1 Default Closure Levels to the RISC 2006 Appendix 1 Default Closure Levels do not apply to non-default RISC closures.
The following are specific guidelines related to transition. There are five (5) scenarios that can occur relative to transition between UST 1994 and RISC non-rule policy:
- UST 1994: Releases reported before February 15, 2002 may use UST 1994 if:
- releases reported before January 1, 2002, with an Initial Site Characterization (ISC) or equivalent submitted before February 15, 2002;
- releases reported between January 1, 2002 and February 14, 2002, with an ISC or equivalent submitted within 45 days of the release report or an extend time approved by IDEM; or,
- an ISC or equivalent was not submitted by the deadline and IDEM grants a written request.
- UST 1994 to RISC 2001: Releases reported before February 15, 2002 may transition to RISC 2001 when requested in writing before July 1, 2004.
- UST 1994 to RISC 2004: Releases reported on or after February 15, 2002 may transition to RISC 2004 when requested in writing on or after July 1, 2004.
- RISC 2001 to RISC 2004: Releases currently using RISC 2001 may transition to RISC 2004, if requested in writing to IDEM on or before July 1, 2006.
- Transition to RISC 2006: Releases currently using UST 1994, RISC 2001, or RISC 2004 may transition to RISC 2006, if requested in writing to IDEM when using the default closure tables. Releases may always transition to the most current guidance and default closure tables, but not the other way.
- RISC 2006 (no transition): Releases reported on or after January 31, 2006 follow RISC 2006
All transitions requests must be submitted to IDEM within the specified timeframes and approved by IDEM whenever applicable. The RISC Default Closure Tables are planned to be revised again July 2006. Attached is a table showing the Contaminants of Concern (COCs) UST 1994, RISC 2001 and RISC 2004. COCs and closure levels for waste oil releases are site specific. For more relevant LUST program information, please call (317) 232-8900 or e-mail at LeakingUST at idem.in.gov. For more information regarding transition issues, please visit the RISC Web page: http://www.in.gov/idem/land/risc/index.html. See TABLE 1 attached for default closure comparison.
- Table 1: LUST Site Contaminants of Concern and Cleanup Objectives [PDF]
- Bold: Change in default closure level from 2001 to 2004 for RISC
- NA = Not applicable
- SS = Site Specific
- * IDEM is developing a TPH non-rule policy document. In the interim, sites should analyze for TPH in addition to RISC COCs as part of the UST closures and site characterization activities.
- ** Waste oil only
- *** IDEM may require additional analyses for metals, PCBs, etc., depending on UST contents or site history
- Release reported before 2/15/2002 - Use 1994 UST Branch Guidance Manual
- Release reported on or after 2/15/2002 - Use RISC
- Release reported on or after 2/15/2002 and before 7/1/2004 - Use the 2/15/2001 default closure tables (RISC Technical Guide, Appendix 1)
- Release reported on or after 7/1/2004 - Use 1/1/2004 default closure tables
- Releases transitioned from 94 Guidance to RISC before 7/1/04 - Use 2/15/2001 default closure tables
- Releases transitioned from 94 Guidance to RISC on or after 7/1/2004 - Use the 1/1/2004 default closure tables
- Releases may always transition to the most current guidance and default closure tables, but not the other way