United States
        Environmental Protection
        Agency
           Solid Waste And
           Emergency Response
           5403G
EPA510-B-98-004
August 1998
&EPA
Test Protocol For Evaluating
Integrity Assessment
Procedures For Underground
Storage Tanks
                             Printed on Recycled Paper

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                                  CONTENTS
Foreword  	   Page 1
Acknowledgments	   Page 4
Quality Assurance Project Plan, including Appendices	Section 1
Results of Evaluation Forms 	Section 2
Instructions for Filling Out Results Forms  	Section 3
"Guidance on Alternative Integrity Assessment Methods ..." Memorandum	. Section 4

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                                   FOREWORD
                                                 \          '            '    ''          '
How to Demonstrate That Integrity Assessment Procedures For Steel USTs Meet EPA's
Recommended Performance Standards

       The Environmental Protection Agency's (EPA's) regulations for underground storage
tanks (USTs) require that all substandard UST systems be upgraded, replaced, or closed by
December 22, 1998. These regulations require that steel tanks without corrosion protection
must be assessed for structural integrity. Then cathodic  protection, lining, or both must be
added to meet corrosion protection requirements. The federal UST regulations at 40 CFR §
280.21 (b)(2) state that an assessment method may be used to ensure the integrity of steel tanks
prior to upgrading with cathodic protection if one of two things is true. One is if the
assessment method is specifically listed in the regulations. The other is if the agency.
implementing the UST program determines that an alternative assessment method prevents
releases in a manner that is no less protective of human health and the environment than those
listed.

      •Deciding whether an alternative method of integrity assessment will prevent releases
in a manner that is no less protective than the methods listed in the regulations has not been
easy.  Vendors of such alternative methods have based their performance claims on a wide
variety of test methods and data bases. EPA issued guidance on July 25, 1997, titled
"Guidance on Alternative Integrity Assessment Methods for Steel USTs Prior to Upgrading
with Cathodic Protection," to assist states and local implementing agencies in determining
what alternative assessment methods to allow.  In this guidance, EPA recommends that after
March 22, 1998, implementing agencies allow  alternative (non-human entry) integrity
assessment methods as meeting the December 22, 1998  requirements, but only if they meet
one of two options..

       The first option is a national standard code of practice. Although the American
Society for Testing and Materials developed an emergency standard (ASTM ES 40) for
performing such methods, it has lapsed and a replacement standard has not been finalized.

       The second option is a successful third-party evaluation against specified criteria. The
purpose of this document is to provide a protocol for evaluating alternative integrity
assessment procedures, in a form that is readily available via EPA's distribution channels, and
that is consistent with the July 1997 guidance.

       EPA will not test, certify, or approve specific vendor procedures for assessing the
structural integrity of steel tanks. Instead, the Agency is describing how implementing
agencies may determine that an alternative integrity assessment method (not listed in the
regulations) meets the performance standard of preventing releases in a manner that is no less
protective of human health and the environment than those listed in the regulations.

       Conducting  evaluation testing to demonstrate this level of release prevention is the
responsibility of the vendor of such integrity assessment procedures, in conjunction with an
independent third-party testing organization. In ah evaluation and certification process, a
vendor contracts with a third party for evaluation. The third party conducts the evaluation and

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 writes a report on the findings for the vendor. The vendor can then provide a copy of the
 report to UST owners and regulators, showing that the procedure meets EPA's recommended
 performance criteria. This information should be provided to UST owners and operators, who
 must keep the evaluation results on file to show compliance with regulatory requirements.

        Within the third-party evaluation option, EPA recognizes two distinct ways to
 determine that an integrity assessment procedure meets the federal recommended performance
 criteria and should be considered to prevent releases in a manner that is no less protective than
 the methods listed in 40 GFR § 280.21 (b)(2)(i) though (iii):

        1.    A qualified independent third party evaluates a vendor procedure by using
              EPA's standard test protocol and certifying that the procedure meets specified
              performance criteria regarding detection of perforations and of either internal
              or external damage, or;

       2.    A qualified independent third party evaluates a vendor procedure by using a
              test protocol deemed equivalent to the EPA test protocol by a nationally-
              recognized association or independent third-party testing laboratory.

       This document discusses both "integrity assessment methods" and "vendor
 procedures." The usage here is that a "method" is a general technology (such as robotic
 devices or diagnostic modeling).  A method may be described in a national standard code of
 practice (such as those from ASTM) and encompass multiple vendor procedures.  A "vendor
 procedure" is an application of such a technology, typically marketed under a trademarked
 brand name.  A vendor procedure must be successfully evaluated and certified by a third party.
 However, such evaluation is not necessarily recommended for each individual contractor who
 is the local provider of a vendor procedure.

 Evaluation Process

       In an evaluation  and certification process, a vendor contracts with a third party for
 evaluation. This third party should be a qualified test laboratory, university, or not-for-profit
 research organization with no financial or organizational conflict of interest. Based on the
 nature of EPA's performance criteria, evaluations will likely be qualitative, but quantitative
 evaluations also are acceptable.  The evaluation should be performed first without and then
 with any information about the leak status of the tank divulged to the vendor. The method's
 performance characteristics, both with leak data and without, are determined, summarized on
 a results form, sometimes called a "short form," and certified by the evaluator. For the
 purpose of determining whether a vendor procedure meets the recommended performance
 standards, the results of the procedure after incorporating knowledge about the leak detection
 test results are to be used.

       Implementing agencies should allow the use of those vendor procedures successfully
 evaluated and certified by a qualified independent third party to meet specified performance
 criteria regarding detection of perforations and detection or either internal or external damage.
 However, those vendor procedures that were part of the 1996 field study conducted by EPA's
Edison, New Jersey lab can use applicable data generated in that study as part of a more

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comprehensive evaluation. In addition, even if a vendor follows a standard code of practice, it
may voluntarily put its procedure through this evaluation process in order to obtain
independent third-party documentation of performance.

EPA Standard Test Protocol

       This document incorporates the peer-reviewed "Quality Assurance Project Plan ..."
(QAPP) prepared for EPA's engineering study, "Field Evaluation of UST Inspection
Assessment Technologies," conducted in 1995 and 1996. With the associated reporting
forms, this document is considered a Standard Test Procedure, similar to EPA's Standard Test
Procedures for Evaluating Leak Detection Methods.  The Agency recommends that
evaluations conducted in accordance with this document be considered valid.  The original
QAPP called for an assessment method to be used on approximately 100 tanks, which are then
removed from the ground for testing and inspection.  EPA now allows as few as 42 total
tanks, with at least 21 being unsuitable per the baseline testing.
                                              ' •
Alternative Test Protocols Deemed Equivalent to  EPA's
               /              .                '.''-'
       Because of the nature of the vendor procedure, in order to take advantage of existing
data, or because of improved testing methods, an alternative evaluation protocol may be, more
effective in a particular case than the standard protocol developed by the EPA. Removal  and
examination of tanks as detailed in the QAPP may not be necessary for all tanks in the
evaluation.  An evaluation following a protocol different than EPA's may be performed by a
qualified third party as above. An approach that uses existing  data to establish the baseline
status can be used in lieu of some physical testing if all relevant data requirements are factored
in. The development of other protocols is not precluded, but rather is encouraged. The
alternative protocols should be based on the same evaluation criteria as the QAPP, and the
results should include an accreditation by the association or third-party testing organization
that the evaluation was at least as rigorous as the EPA standard test protocol.

Evaluation Criteria

       Within EPA's recommended option for evaluation, the criteria for proving tank  .
integrity are as follows:
       One of the following:
              a)     Detect external pits deeper than 0.5 times the required minimum wall
                     thickness, OR
              b)     Detect internal pits deeper than 0.5 times the required minimum wall
                     thickness AND any internal cracks or separations.
Note that a perforation of a tank is regarded as a pit that is deeper than the wall thickness,
whether it originated from the outside or the inside of the tank. Thus, perforations must be
detected under either (a) or ;(b). To meet the criterion, a method must demonstrate a
probability of detection of unsuitable (by one of the  above criteria) tanks or sites of at least
95%.  A site is considered unsuitable if any one of the tanks at the site is unsuitable. The
estimated probability of false alarm  is to be reported, but there is no required level for this
probability. This is a change from the July 1997 guidance.
                                          .3

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 Human-Entry Inspection

       This document is not intended to discourage the use of human-entry internal
 inspection as an assessment method or tank lining as an acceptable upgrade option. EPA's
 UST regulations allow for human-entry inspection and interior tank lining to be used as an
 upgrade option for tanks lacking corrosion protection (40 CFR § 280.2 l(b)(l)). This
 document addresses primarily methods not specifically listed in the federal regulations (see §
 280.21(b)(2)(iv)), although human-entry inspection procedures can also be evaluated
 according to this document.
                             ACKNOWLEDGMENTS

       This document is based on the "Quality Assurance Project Plan Field Evaluation of
UST Inspection Assessment Technologies," which was produced for U.S. EPA's Office of
Research and Development by IT Corporation. EPA's Work Assignment Manager was
Carolyn Esposito of the National Risk Management Research Laboratory, IT's Project
Manager was Janette Martin, and the primary author was Jarius D. Flora Jr., Ph.D. of Midwest
Research Institute.  The Foreword, Results of Evaluation forms, and instructions for the
Results forms were produced by Dr. Flora and David Wiley of EPA's Office of Underground
Storage Tanks (OUST). Paul Miller of OUST, Russ Brauksieck of the New York State
Department of Environmental Conservation, Pejman Eshraghi of the Arizona Department of
Environmental Quality, and Jeff Tobin of the Montana Department of Environmental Quality
all helped, via their participation in the ad hoc Integrity Assessment Evaluations Work Group,
to improve this document.

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                     SECTION 1

             Quality Assurance Project Plan
Field Evaluation of UST Inspection Assessment Technologies

                     October 1995

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       QUALITY ASSURANCE PROJECT PLAN
      FIELD EVALUATION OF UST INSPECTION
           ASSESSMENT TECHNOLOGIES

                       by

                   IT Corporation
                 11499 Chester Road
                Cincinnati, Ohio 45246

                       and

               Midwest Research Institute
                425 Volker Boulevard
              Kansas City, Missouri 64110
               Contract No. 68-C2-0108
              Work Assignment No. 4-17
                    JTN 764396   ;

                       for              A,

     U.S. ENVIRONMENTAL PROTECTION AGENCY
      OFFICE OF RESEARCH AND DEVELOPMENT
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
            2890 WOODBRIDGE AVENUE
           EDISON, NEW JERSEY 08837-3679

                  Carolyn Esposito
               Work Assignment Manager
         '            !       '           - '      t '
                    October 1995

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      RREL QUALITY ASSURANCE PROJECT PLAN (QAPP) IMPLEMENTATION AGREEMENT
         ,'••-•        '   •           •      f°F         '      -  '         '  •
              RREL Gontracts/Inter-Agency Agreements/Cooperative Agreements/In-house Projects
RREL QA ID Number:.

Contractor:      	
                                     RREL Project Category:  "_	    QAPP Revision Date:
QA Project Plan Title:
                            Field Evaluation-of  U.ST  Inspection/Assessment  Technologies
QAPP contributors (i.e., QA and management personnel, including subcontractors, for extramural projects
and the EPA princiipal investigator for in-house projects) must sign below.  Signatures should be acquired
before submitting the QAPP to EPA for review and written approval.
Name (print)
                       Role - Affiliation
                                                            Agreement Signature'
                                                                                         Date
C
                         IT
      1  Any substantive change to the measurement, data-gathering, or data-generation activity must be documented
        in a revision to the previously approved QAPP. Accordingly, this agreement must be revised, re-signed and
        submitted with the QAPP revision.  (Note:  The term "substantive change" is defined as any change in an
        activity that may alter the quality of data being generated or gathered.)

      2  Signing here signifies agreement with all measurements, data-garnering, and data-generation activity, as
        specified, in the QAPP. Above signatures indicate a commitment to implement the QAPP\ approved, in
        writing, by the EPA.                                           ,
RREL (IA)
March 1995

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                                                             Section No. QAPP List
                                                             Revision No.  1
                                                             Date: October 4.1995
                                                             Page: 1  of 1
Carolyn Esposito

Robert Amick

Janette Martin

Dennis O'Conner

Thomas Clark

J.D. Flora

C. Green

Thomas Barlo

Quinton Bowles

Bopinder Phull

Oliver Siebert
   QAPP DISTRIBUTION LIST


EPA/NRMRL Work Assignment Manager

IT Project Manager

IT Work Assignment Leader

IT Senior Reviewer

IT QA Manager

MRI Project Manager

. MRI QA Officer

Project Work Group Member

Project Work Group Member

 Project Work Group Member

 Project Work Group Member

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                                                                 Section No.  Contents
                                                                 Revision No.   1
                                                                 Date: October 4. 1995
                                                                 Page: 1  of 5
                                   CONTENTS
 Section
Contents       List of Tables
Contents       List of Figures
 1.0           Project Description
 2.0           Quality Assurance Objectives
 3,0           Site Selection and Sampling
               Procedures
 4.0           Analytical Procedures and
               Calibration
 5.0           Data Reduction* Validation, and
               Reporting
 6.0           Internal Quality Control Checks
 7.0        .   Performance and Systems Audits
 8.0           Calculation of Data Quality
               Indicators
 9.0           Corrective Action
 10.0          Quality Control Reports to
               Management                .
 11.0  •        References
Pages
1
1
21
8
10
2
7 ,
i
2
1
1
1
Revision
No. .
1
1
r
1
1
1
1
1
1
0
0
o
0
Date
Revised
10/04/95
10/04/95
10/04/95
. 10/04/95
10/04/95
10/04/95
s
10/04/95
10/04/95
08/16/95
8/16/95
8/16/95
8/16/95
10/04/95

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                                                                 Section No. Contents
                                                                 Revision No.	1_
                                                                 Date: October 4. 1995
                                                                 Page:_2_ofJL
                                   CONTENTS (Cont.)
 Section

Appendix A

Appendix B


Appendix C
Radiographic Testing Procedure

Baseline Testing Procedures and Data
Collection Forms

Vendors' Standard Operating
Procedures
Pages
18
13
Revision
No.
0
1
Date
Revised
8/16/95
10/04/95
0
0
8/16/95

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                                                         Section No. Contents
                                                         Revision No;   1
                                                         Date: October 4. 1995
                                                         Page: _3_ of JL  ,
Table

 1-1
 1-2
 2-1
 2-2
 3-1
 4-1

 4-2
 5-1
 5-2
 Figure
  1-1
 -1-2
  1-3

  1-4
  3-1
            LIST OF TABLES

              Title

Critical or Non-Critical Data, Measurements, Records
Performance Measures for Assessment Methods
                 •'                        •    •
Completeness Objectives for Vendor Tests
Quantitative QA Objectives for Baseline Test Procedures
Number of Measurements
Measurement, Type, and Equipment for Baseline Testing
of Tanks and Coupons
Scheduled Baseline Test Calibrations
Conclusion of Each Vendor Assessment Method
Sample Data
            LIST OF FIGURES

               Title          .
 Tentative Schedule for Work at an Individual Site
 Tentative Schedule for Sites in the First Region
 Tentative Schedule for Sites in the Remaining Four
 Regions
 Project Organization
 Coupon History Form
P_ag£

 1-9
 1-11
 2-4
 2-5
 3-3
 4-2

 4-2
 5-5
 5-5
 Page
 1-14
 1-15,
 1-16

 1-21
 3-10

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                                                                 Section No. Content
                                                                 Revision No.	]_
                                                                 Date: October 4.
                                LIST OF ACRONYMS

 ADQ        Audits of Data quality

 API         American Petroleum Institute

 ASME       American Society of Mechanical Engineers

 ASTM       American Society for Testing Materials

 CFR         Code of Federal Regulations

 CP           Cathodic Protection

 EPA         Environmental Protection Agency

 ES           Emergency Standard

 IT           International Technology Corporation

 MRI         Midwest Research Institute

 NACE        National Association of Corrosion Engineers

 NLPA        National Leak Prevention Association

 NRMRL      National Risk Management and Research Laboratory

 OHSA        Occupational Health and Safety Administration

 PCD         Probability of Correct Decision

 PD          Probability of Detection

 PFA         Probability of False Alarm

 QA          Quality Assurance

 QAO        Quality Assurance Officer

QAPP       Quality Assurance Project Plan

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QC          Quality Control

SSPC        Steel Structures Painting pouncil

TSA         Technical Systems Audit

UL          Underwriters Laboratory

UST         Underground Storage Tank

WAL        Work Assignment Leader (Contractor)

WAM       Work Assignment Manager (EPA)
                                                                Section No. Contents
                                                                Revision No.   1
                                                                Date: October 4.  1995
                                                                Page: _5_ of _5_

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                                     SECTION 1.0
                               PROJECT DESCRIPTION
                                                                   Section No.   1
                                                                   Revision No.  1
                                                                   Date: October 4.199B
                                                                   Pane:  1  of 21
1.1 Background
       By December 22, 1998, all Underground Storage Tank (UST) systems must be replaced,
upgraded, or closed according to the current Federal Regulations for USTs (4QiCFR 280 and 281).
Owners and operators choosing to upgrade their UST systems via cathodic protection or cathodic
protection combined with an internal lining must determine the integrity of their system prior to
upgrading.  This Quality Assurance Project Plan (QAPP) presents the experimental design and
criteria for evaluating the performance of four assessment methods for determining the suitability
of USTs for upgrading with cathodic protection.                      -
       In order to be suitable for upgrading by cathodic protection alone (that is, without also lining
the tank), in accordance with 40 CFR Part  280, "Technical Standards and Corrective Action
Requirements for Owners and Operators of Underground Storage Tanks," the tank must be assessed
to ensure that it is structurally sound and free of corrosion holes [Section 280.21(b)(2)(I)j. For tanks
that are 10 years old, two alternative criteria for upgrading a tank with cathodic protection are stated
in the EPA regulations (CFR 280.21 (2)).
       "(I) The tank is internally inspected and assessed to ensure that the tank is structurally sound
       and free of corrosion holes prior to installing the cathodic protection system;"
       "(iv) The tank  is assessed for corrosion holes by a method that is determined by  the
       implementing agency to prevent releases in a manner that is no less protective of human
       health and'the environment than subparagraphs (I) through (iii)."
       Subparagraphs (ii) and (iii) of CFR 280.21 (2)  refer to tanks less than 10 years old.  By
December 22, 1998, when the Federal Regulation requires that all UST systems,must either be
"new" tanks, or be upgraded  to new tank standards, or closed,  there will be no tanks less than
10 years old that do not meet new tank standards.

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                                                                     Section No.   1
                                                                     Revision No.:  1
                                   ;                                  Date: October 4.
                                                                     Page:_2_of.2L_
        Determining the integrity of UST systems usually requires some type of internal inspection
 or assessment.  Past practices involved actual tank entry and internal inspection, and required
 significant down time from normal operations. Recently the American Society for Testing Materials
 (ASTM) Committee E-50 on Environmental Assessment and Subcommittee E50.01 on Storage
 Tanks has issued an Emergency Standard Practice, ES 40-94, "Emergency Standard Practice for
 Alternative Procedures for the Assessment of Buried Steel Tanks Prior to the Addition of Cathodic
 Protection."  The Emergency Standard Practice provides recommended minimum performance
 practices for three alternative methods to internal  inspection for assessing the suitability of
 underground storage tanks for upgrading by adding cathodic protection. These three methods are
 tank life/corrosion rate models, remote video camera tests, and robotic ultrasonic tests.  These
                                                v          »
 methods do not require human entry into the tank to determine the suitability of a tank for upgrading
 with cathodic protection.
       The three new  methods include a site survey  to  collect  basic tank and environment
 information. This site survey includes items such as tank age, a check for stray d-c current, other
 buried metal structures, tank material and electrical isolation, and tank leak and repair history. In
 particular, the tank is also required to have passed a suitable leak detection test. These methods all
 conduct basic site-specific tests of the tank environment including:
       •      Stray current/corrosion/mterference
       •      Soil resistivity
       •      Structure to soil potential
       •      SoilpH
       •      Electrical continuity/isolation
       In addition, other tests may be required by the corrosion expert including such measurements
as hydrocarbon, chloride, sulfide, and sulfate ion concentrations in soil and resistance of the tank
coating. Some methods have obtained approval from some State regulatory authorities; however,
other State agencies are withholding approval, pending an evaluation of performance claims for these
systems.

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                                                                    Section No.._...'1
                                                                    Revision No.:   1
                                                                    Date: October 4.1995
                                                                    Page: 3  of 21
       The intent of the  Emergency Standard Practice is to present alternative methods for
determining if cathodic protection is a reasonable and viable upgrading method for a particular tank.
To do this, a corrosion engineer must consider both the condition of the tank and the, condition of
the soil that forms the environment for the tank.  This project is designed to evaluate the performance
                                                                          ' •-             f
of the three methods described hi the Emergency Standard Practice, as well as the existing method
of internal inspection, hi  determining only the condition of the tank.  The procedure for this
evaluation is to have vendors of each of the four methods apply that method to a set of underground
storage tanks and report their results. The use of the soil data to determine the soil's compatibility
with applying cathodic protection is beyond the scope of this project.      ,
       The tanks will then be removed and the actual condition of the tanks determined by a series
of baseline tests, some of which are destructive. It should be noted that the non-destructive tank
assessment methods are inherently limited to observing and making measurements from the ulterior
of the tank.  The baseline tests will have both the inside and outside surface of the tank shell
available for determining the condition of the tank.
       The performance of each method of tank assessment will be estimated by comparing its
conclusion as to whether  each tank was suitable  for upgrading with  cathodic protection to the
condition of the tank determined by the baseline testing. The results  of the comparison will be
summarized for all tanks in the study by calculating the proportion of correct decisions reached by
each tank assessment method. That is; the proportion of tanks for which each assessment method
agreed with the findings of the baseline test will be calculated and reported. The proportions of each
type of disagreement between the assessment methods and the baseline findings will also be
calculated and reported.  Regulators may use these performance estimates  in deciding which
methods to allow in then- jurisdiction. Tank owners may use this information to select a method of
assessment for then- tanks. .
1.2     Vendor Assessment Methods to Be Evaluated
        The four vendor methods below are used to evaluate the structural soundness of the tanks.

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                                                                      Section No.   1
                                                                      Revision No.	1
                                                                      Date: October 4
                                                                      Page:_4_of_2J_
  1.2.1 Non-invasive Tank Life/Corrosion Model Tests (i.e., modeling)
        This method examines the environment in the specific vicinity of the tank.  A statistical
  model is used to determine a relationship between the aggressiveness of the environment and the rate
  of corrosion. The site-survey and site-specific tests noted above are to be conducted in more detail
  for this  method than'for the others.  For example, the stray current measurements  use a
 microprocessor-controlled data acquisition unit taking data samples at 5-sec intervals. The soils data
 are based on samples collected at 2-ft intervals fix>m two or more holes bored at least as deep as the
 bottom of each of the tanks.
        The data input to the model include the results of the analysis of soil samples as well as
 various electrical measurements (e.g., structure to soil potential).  The statistical model is required
 to have been developed on at least 100 sites  with at least 200 tanks that were excavated and
 inspected by a corrosion expert. The model must also include factors such as presence of a water
 table, annual precipitation and average temperature.
       The output of the model includes an estimated leak-free life of the tank (which must have a
 standard deviation of no more than 1.5 years) and an estimated probability of corrosion perforation.
 Tanks with an age less than the estimated  leak-free life  and with a probability of corrosion
 perforation  less than 0.05 (5%) may be upgraded by the addition of cathodic protection using an
 appropriately designed cathodic protection system. This method is described in ASTM ES 40-94.
 1.2.2  Invasive Robotic Ultrasonic Tests  (i.e., ultrasonic)
       Following the site-survey and site-specific tank environment tests,  the robotic ultrasonic
 equipment is installed in the tank through an existing opening (typically 4 in. in diameter). The tank
 will be prepared according to the vendor's specifications (in their written procedure) by the vendor.
 The robotic ultrasonic equipment is used to  take discrete, located measurements of wall thickness
 on at least 15% of the entire tank interior surface.  These measurements are designed to be uniformly
 distributed over the, tank surface (excluding man-way entries).  The data  from a mathematical
 corrosion prediction model are used to forecast when each tank is expected to leak.  The tank is
considered suitable for upgrading with cathodic protection if there is no pitting greater than 50% of
the minimum recommended wall thickness  and the average metal wall thickness of each 9  ft2 is

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                                                                    Section No.    1
                                                                    Revision Mo.   1
                                                                    Date: October 4.199$
                            ,                                        Page:  5  of 21
 greater than 85% of the minimum recommended wall thickness.  This method is described in ASTM
 ES 40-94.  In the event that one of the selected tanks does not have an opening large enough for the
 robotic ultrasonic equipment, a larger opening will be cut in the tank, since such an opening will be
 cut for the internal, inspection anyway.
 1.23 Invasive Remote Video Camera Tests (i.e., video)
    -  This method also uses the basic site survey information and the site-specific measurements
 described above.  In addition to those, this method consists of inserting a remotely operated video
 camera and. suitable lighting source into the tank.  The tank will be prepared according to the
 vendor's specifications (in their written procedure) by the vendor.  This video system must be
 capable of recording a video survey of the ulterior surface of the tank.\ The, detailed requirements
 of the video system are included in ASTM ES 40-94.        (
       The video system is used to survey the interior of the tank to allow the operator to first
 determine  that the tank is sufficiently clean for effective video inspection.   Then the camera is
 controlled to systematically record a visual inspection of the internal tank surfaces, with a recorded
 voice override and text input to document the direction and location of the view arid comment on
              »                        '_-,'...                            .
 findings. The corrosion tester using the video will document any evidence of corrosion including:
       •      Perforations               .'..'...
       •      Rust tuberculation
       •      Streaks      .;                       -..'..'..••
       •      Discoloration     •     ./•  '                  .
       •      Pitting " .           .
       •      Scaling or delaminations
     .'••••     Weld corrosion
       •      Cracks
       •      Passive films
       Based  on this visual  examination using the  video camera, review of the site-specific
 environmental data, and tank age, the examming corrosion expert makes a determination of whether
any evidence exists for corrosion or deterioration that would indicate that the tiank is not suitable for

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                                                             ,        Section No.   1
                                                                     Revision No.	1_
                                                                     Date: October 4.1.QRR
                                                                     Page:_6_of_2]_
 upgrading with cathodic protection, whether the tank requires further inspection by other recognized
 procedures, or whether the tank is suitable for upgrading with cathodic protection.  In the event that
 one of the selected tanks does not have an opening large enough for the robotic ultrasonic equipment,
 a larger opening will be cut in the tank.
 1.2.4   Invasive Internal Inspection (Le., inspection)
        Determination of tank structural integrity has most commonly been accomplished by means
 of human inspectors physically entering  properly prepared tanks and using various inspection
 techniques. Current practice is to perform a visual inspection either alone or in combination with
 other measurements. The techniques that have been used in an internal inspection include: (a) visual
 inspection for holes, cracks, and deformation, (b) "hammer test," involving striking the inside of the
 tank with a ball peen hammer to identify  structurally weak areas and/or judging the relative thick or
 thin area by the resonant sound produced; © ultrasonic transducer measurement of the  wall
 thickness; (d) magnetic particle testing  for cracks; and (e) various combinations of the previous
 methods. The visual inspection, and to  a lesser extent visual inspection in conjunction with UT
 testing, is commonly performed by applicators of ulterior tank linings.
       The internal inspection requires physical entry into a tank. Typically the top of the tank must
 be exposed by excavation and an opening (minimum 18 in by 18 hi) cut in the top of the tank.  The
 tank must be ventilated to provide a breathable atmosphere and to eliminate any fire hazard. Persons
 entering the tank must wear protective clothing and be supplied with air from a tank or outside
 source. Sludge must be removed from the tank and the tank cleaned and abrasively blasted prior  to
 performing the visual inspection. The vendor must follow all applicable OHSA and other regulatory
 requirements.  Generally the internal inspections follow the guidelines  in American Petroleum
 Institute (API) 1631, "Interior Lining of Underground Storage Tanks, 3rd  Edition, April 1992,"
National Leak Prevention Association (NLPA) 631 "Entry, Cleaning, Interior Inspection, Repair and
Lining of Underground Storage Tanks," or NLPA 632 "Internal Inspection of Steel Tanks for
Upgrading with Cathodic Protection Without Lining."

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                                                                    Section No.   1
         ,                                                           Revision (Vo.   T
                                                                    Date: October 4.1995
                                                                    Page: J^ of 21
 1.3    BASELINE TESTS (i.e., Baseline)
       The vendor test methods are all done with the tank in the ground and consequently are
 limited to the interior of the tank. Corrosion and pitting may occur on the outside of the tank. The
 baseline tests are conducted from both sides of the tank after it has been removed from the ground
 to establish the actual condition of the tank. This internal and external method is similar to the visual
 inspection method, with several additions. The internal vertical diameter is measured while the tank
 is still underground, then the tank is excavated and moved for additional measurements and an
 access hole is cut in one^nd.  The original location of the diameter measurement is recorded, and
 the internal vertical and horizontal diameters of each end are measured, then the amount of shell
 deformation is calculated. A grid pattern using 3 ft by 3 ft grids is marked on the inside and outside
 of the tank, and both the ulterior and exterior (before and after abrasive blasting) are visually
 inspected. The purpose of the inspection is to detect surface discontinuities such as cracks, holes,
 and pits, and to describe the amount and type of any corrosion observed. The written procedure that
 is applicable for this examination is that provided in Section 3.3. Photographs are used to document
the condition. When rust plugs are detected, they are removed. The depths of the visually deepest
pits are measured.
       Ultrasonic measurements are conducted to determine wall thickness.  This testing is done
primarily from the inside of the tank, but may also be done from the outside.  An ultrasonic test is
made at the approximate center of each marked grid. Additional ultrasonic readings may be taken
in any grid section based on field crew observation and judgement.  Wall thicknesses will also be
measured by drilling a sentry hole and using a through-wall micrometer. The minimum required
initial  wall  thickness for each tank will be determined by the tank size  in  accordance with
Underwriters Laboratory (UL) 58 "Standard for Steel Underground Tanks for Flammable and
Combustible Liquids."
       The results of the baseline measurements are used with the criteria hi Section 2.2.3, "Criteria
                                                     • ': •  •           •         i •
for Upgrading," to classify the tank as suitable or unsuitable for upgrading with cathodic protection.

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                                                                    Section No.   1
                                                                    Revision No.	1_
                                                                    Date: October 4.1995
                                                                    Page:  8 of 21
 1.4    STATEMENT OF PROJECT OBJECTIVES
        The primary objective of the project is to determine the performance, i.e., proportion of
 correct decisions, of the four tank assessment methods. First, the four assessment methods will be
 conducted by vendors.  Second, a baseline test on the same tanks will be conducted by the
 contractor.  Third, the conclusion of each assessment method will be compared with the baseline
 findings. Fourth, the measure of performance of each tank assessment method and their 95%
 confidence intervals will be calculated.
        The critical and noncritical data, measurements, and records for the four vendor methods and
 the baseline tests are provided below in Table 1-1. The equipment used for the baseline testing is
 also listed.                                                     *
       Table 1-2 classifies the tanks by the vendor's results and the actual tank condition. The cells
 where the vendor's result agrees with the actual condition are correct decisions, while those where
 the results disagree represent errors.  The proportion of correct decisions is the number of tanks
 classified hi the upper left and lower right cells of Table 1-2 divided by the total number of tanks.
       Four secondary objectives of the project are to estimate the proportions of false alarms,
 correct detection, missed detections, and correct approvals. A false alarm occurs if a vendor's result
 fails a tank that is suitable for upgrading (by cathodic protection). A correct detection occurs if a
 vendor's result fails a tank that is not suitable for upgrading. A missed detection occurs if a vendor's
result indicates that a tank is suitable for upgrading, when, in fact, its actual condition does not
 qualify it for upgrading.  A correct approval  occurs if the  vendor's result approves a tank for
upgrading and the tank is actually suitable for upgrading. Additional secondary objectives are given
 in Subsection 2.1.
 1.5    EXPERIMENTAL DESIGN
       One hundred tanks will be used in the study.  This number constitutes a statistically valid
population of tanks for assessing the performance of the vendor assessment methods. The total
number of tanks to be included hi this study was set by determining the number required so that the
expected half-width of the 95% confidence interval for the probability of false alarm and probability
of correct detection would be 0.15. That is, the objective of estimating the performance parameter

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                                                                    Section No.   1
                                                                    Revision No.   1
                                                                    Date: October 4.1995
                                                                    Page:  9 of 21

to within at least ±0.15 with 95% confidence would be met. This led to the selection of a sample'

size of 100 tanks, of which approximately half would be found suitable for upgrading with cathodic
protection, as sufficient to meet this objective.

           Table 1-1.  Critical or Non-Critical Data, Measurements, Records
Required Data/Measurement/Record ,
Modeling: , .
,
Tank identification .
Conclusion (suitable or unsuitable for upgrading with CP)
Raw data from soil and electrical measurements , .
Expected Life of the Tank
Probability of corrosion hole
Ultrasonic:
Tank identification
Conclusion (suitable or unsuitable for upgrading with CP)
If tank not suitable, reason for conclusion
Data base of ultrasonic wall thickness measurements (and locations)
Maximum pit depth found
Average wall thickness for each 3 ft by 3 ft area
Results of their prediction model
Video:
Tank identification ;
Conclusion (suitable or unsuitable for upgrading with CP)
If tank not suitable, reason for conclusion
Presence of pits or rust tubercles on opposite surface of > 0.125 in diameter
A copy of the video tape record ..'..-'
Location of any perforations or corrosion identified by the video inspection as significant
TYPE

C
C
NC
NC
NC

C
C
NC
NC
NC
NC
NC

C
C
NC
- NC
NC
NC

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                                                         Section No.   1
                                                         Revision No.   1
                                                         Date: October 4.1995
                                                         Page:  10 of 21
Table 1-1. Critical or Non-Critical Data, Measurements, Records
Required Data/Measurement/Record
Inspection:
Tank identification
Conclusion (suitable or unsuitable for upgrading with CP)
If tank not suitable, reason for conclusion
Location of any perforations, deep pits, or thin walls identified
Any quantitative measurements developed, e.g., wall thickness measurements
Baseline:
Tank identification
Presence of perforations
Location of perforations using grid system developed by tape measure
Depth of pit for 5 deepest pits using depth micrometer
Location of 5 deepest pits'
Diameter of pits on interior using a ruler
Wall thickness measurements using throughwall micrometer
Wall thickness measurements using an ultrasonic instrument
Tank diameter (vertical and horizontal) using tape measure
Presence of observed cracks in welds
Location of cracks in welds
Internal and external detailed inspection results
Results of any external laboratory tests recommended by field crew (e.g., radiography or
sectioning of steel coupons)
Photographic documentation of each tank
TYPE

C
C
NC
NC
NC

C
C
NC
C
NC
NC
C
C
C
C
NC
NC
NC
NC

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                                                                     Section No.   1
                                                                     Revision No.  1
                                                                     Date: October 4.1995
                                                                     Page:  IT'of 21
           Table 1-1. Critical or Non-Critical Data, Measurements, Records
   Required Data/Measurement/Recqrd
                                                                             TYPE
   Owner:
   Result of leak tests
                                                                             NC
   Age of tank
C = Critical
NC = Non-critical
                                                                             NC
                Table 1-2. Performance Measures for Assessment Methods

                                                 Vendor's result
   Actual condition
  •••••«••••
   Tank suitable for
   upgrading
               Pass
               •••
Correct Approval (Approved a tank
suitable for upgrading)
              Fail
             •••
False Alarm (Failed a tank suitable for
upgrading)
   Tank not suitable
   for upgrading
Missed Detection (Incorrectly passed a tank
not suitable for upgrading)
Correct Detection (Failed a tank not
suitable for upgrading)
       To assure that the environmental conditions at the tank sites would be representative of
conditions in the United States, the contiguous 48 states were divided into 5 regions.  The 100 tanks
will be selected with an equal number of 20 from each of the 5 regions.

       The Northwest region was chosen to represent cool, wet climates and a range of soil types.
The Southwest region represents the hot, dry conditions with sandy soils typical of that area. The
Midwest region represents agricultural soil types with hot summers, cold winters, and moderate
precipitation. The Northeast region represents densely populated urban areas with rocky soils and
climates typical of New England, and the Southeast region represents hot, wet climates with the

typical red clay and other soil types found in that region.
       EPA will arrange with tank owners to identify tanks previously scheduled for removal that
can be used in this project.  The tanks selected will be steel tanks that have not been cathodically
protected or lined. The tank owners will be asked to supply data on the age of each tank, its size or

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                                                                  /   Section No.    1
                                                                      Revision No.	1_
                                                                      Date: October 4.1995
                                                                      Paqe:JL2  of  21
 volume, the leak detection history, and any other information available. In planning, it has been
 assumed that all tanks at a given site (within a geographic region) would be scheduled for removal.
 A tank site is the specific location of the study tanks, for example, a gas station.  In order to control
 the cost, all tanks to be removed at a given site will be included hi the study. It is estimated that
 there will be an average of 3 tanks per site, leading to approximately 7 sites per geographic region
 to supply the 20 tanks. In order to obtain a variety of soil types and environmental conditions, at
        i    S              , "                    - .              f
 least 6 sites within each region will be used to provide the 20 tanks.
       EPA will develop a list of available tanks and sites within each region. If there are more than
 20 tanks within a geographical region, this list will be reviewed to select the tanks and sites for use
 in the project. The representativeness of the set of tanks is not completely under the control of the
 project. In addition, the tanks to be used do not need to represent the population of tanks. Ideally,
 approximately half of the tanks to be used should be suitable for upgrading by cathodic protection
 and about half should not  be suitable. This would make the estimation of the two performance
 parameters about equally precise.  To achieve representation of these two classes of tanks as well
 as possible,  the tanks will be selected from the list of eligible tanks by selecting equal numbers of
 tanks from those that have recently passed a leak detection test and those that have not, if there are
 enough tanks hi each group to allow this. If very few tanks have not passed recent leak detection
 tests, then about half of the tanks selected will be the oldest available.  The suitability of tanks for
 upgrading with cathodic protection will  not be known or determined until the baseline tests are
 conducted. Selecting tanks from these groups is an attempt to obtain approximately equal numbers
 of tanks in the suitable and unsuitable groups.
       All tanks selected for use in the study will be tested by each of the four tank assessment
    *                                                                  1
 methods to be evaluated. The vendors of the methods will supply their reports including conclusions
 as to the suitability for upgrading as well as supporting data.  The supporting data should be
 sufficiently documented to identify the reason for disqualifying a tank, and, if a specific problem is •
 found, the location in the tank of that problem.  The vendors of each method will first present their
 1              "                     * ' '       ,   , •      "  , "    '               i
 conclusions  in the absence of knowledge about the results of a leak test on the tank.   Such
 conclusions may be stated conditionally on the results of the leak test.  After the conclusions of each
method without knowledge of the leak status of the tank have been stated, the leak test results will

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                                                                       Section No.
                                                                       Revision No.	
                                                                       DateLOctober4
                                                                       Page:.J2_of_2J_
   be supplied to the vendors.  The vendors will then prepare second conclusion reports incorporating
-   the results of the leak detection test.  Thus, each method will provide two sets of results for each
   tank, one without knowledge of the leak test result on the tank, and one incorporating the results of
   the leak detection test.
           *                           •                                       -
         After the tank has been assessed using each of the four methods, the tank will be removed
  from the ground and subjected to baseline tests, some of which will be destructive.  These tests will
  determine the condition of the tank based on four primary parameters:
         •     Presence or absence of holes
         •     Depth of pits, if found                                        ,       \-
         •     Wall thickness
         •     Cracks in welds
         These four primary parameters will be used to determine if a tank is suitable for upgrading
 with cathodic protection. Because there is no single standard criterion for judging a UST suitable
 for upgrading with cathodic protection, the determination of suitability will be made using several
 different criteria, as listed in Section 2.3.  For a given criterion, the probability of false alarms for
 each method will be estimated as the proportion of tanks judged to pass by  the criterion applied to,
 the baseline data which the method reported as unsuitable  for upgrading.  The probability of
 detection for each method will be estimated as the proportion of tanks failed by that method that are
 also judged to fail by the criterion applied to the baseline data. Two  sets  of conclusions will be
 reported by the methodr-with  and without knowledge of the leak test results.  Separate estimates will
 be made for each set of conclusions compared to each of the 4 criteria for the tank.
 1.6   SCHEDULE
       Three tentative schedules are presented as Figures M through 1-3. Figure 1-1 is the
 tentative schedule for work at an individual site; Figure 1-2 is the tentative  schedule for all the sites
 at the first region; and Figure  1-3 is the tentative schedule for all the sites  at each of the remaining
 regions.  The comments  below provide the assumptions made in developing these schedules. A
minimum of 6 sites per region are required. For the schedule and budget, 7 sites per region were
used.                                                .                      -

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Pump 1
Robotic Ultrasonic
Remote Video
Noninvasive
Excavate, Open Tanks,
Desludge
Sandblast
Internal Inspection
Pull Tanks
Sandblast, Open End
Baseline Tests
Makeup Day
Site Schedule
1



2










3

I


4

I


Wor
5

I


kDay
6





7

8

I


9

I




10



                                                                                             a. ao ea
                                                                                             QJ CD  tO
                                                                           55-37 SEV gtauz »cd 1 072605
Figure 1-1.  Tentative Schedule for Work at an Individual Site
CO

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s
1
3
2
Regional Test Schedule
First Region

Identify Sites
Training & Mobilization
Scheduling
Site 1
Site 2
Site3
Site4
SiteS
SiteB
Site?
Final Lab Work
1

2

3








l

V
4

5

Week
6


1

(





7




8




9

,_
l l






10

1 I



11
-• ' .
I



                                                                                               -O O 3O C/3
                                                                                               Q) Q)  CD  CD
                                                                                               ca I-*-  <  r>
                                                                                               N
Figure 1-2.  Tentative Schedule for Sites in the First Region
                                                                                                  cr
                                                                                                  CD
CO
CO
01

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Regional Test Schedule
Remaining Regions

Identify Sites
Mobilization
Scheduling
Sitel
Site 2
Site 3
Site 4
SiteS
Site 6
Site?
Final Lab Work
1

2

3










4

Week
5










6




7

,_
I 1






8

1 1






9

1


                                                                                           -a a 3D co
                                                                                           m o> re  n>
                                                                                          CO r* <  O
                                                                                                 '
                                                             *MT >EV ^iw K anew
Figure 1-3. Tentative Schedule for Sites in the Remaining Four Regions
2. —'

=>

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                                                               Section No. __
                                                               Revision No. ,
                                  ,  -                          Page:_lZ_of_21_
   1.6.1  Site Schedule

   fl Id"  It T' 7 SfeS * * KSimWm ^ "^ >0 working days ,o complete al,
   neldworkby^vendorsand^eresearch.ean,. !t is assumed that each si* contains 3 tanks  !, ^
   — ^--^-^d**^;^^^^^    °
   construct contractors, ^   One slack day per site, shown as a makeup day  has been
                                                                     *
                                                      .
       of the tanks wil, be done by the tank owner^r prior to conducting vendor
  ^hrnmary purgmg may a!so have occurred, bu, addinona, purging wffl be needed for a few hours
  after the s*rt.  Tie Mowing additional assumptions also control the schedule
  1.6.1.1 Modeling
       I, is assumed to thework of ^ vendors on site can be accompUshed in , day. However,
 the data coUect-on reouired by the vendor does not require access to the tank, per se nor does it
 .n^erewit.theworkof^othervendors. Tr^ore, „ can be done any time during thefet week
 (before the tanks are excavated).
 1.6.1.2 Ultrasonic
 vendor cotad both be a, the site the same day, testing on a-temate tanks. Nevertheless, a total of
 2 days for the two methods has been allocated.
 1,6.1.3 Video
      Ine vendor wil, r^e about a day a, Me site.  However, mis vendor and the robotic
                   boateaaesitete^^^on
1.6.1.4 Inspection
                      methods has been aUocated.
                                                         on,oto
              lnspectio,
                                     ^
       otters are sttllunder test. Specific assumptions are as follows-

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                                                                       Section No. _. 1
                                                                       Revision No. _ 1
                                                                       Date:J)ctober4.
                                                                          e:_l£_of.2L_

 1.6.1.5 Baseline

    . . A total of 4 day, has been allotted to the baseline testing, including the necessary r^

work.  This preliminary work includes pulling the tanks, perhaps relocating the taks, abrasive

blastag ft. exterior of ft. tanks, and cutting open one end of each tank.  Specific assumptions
as follows:
                                                                                       are
               Pulling of the tanks (and relocating them if necessary) should require 1 day and is
               unlikely to be significantly overlapped with other activities.


                               bCen 8ll?Catod t0 Sbrasive blasting «* ext£rior of each tank and



                              been allocated to conducting the baseline tests on each of the three


 1.6.2 Regional Test Schedule for the First Region

       It is assumed that the field work at the 7 ^ sites in the &st region will require 1 1 weeks of

 effort following approval of the QAPP.  The primary assumptions deal with matters beyond the

 contractor's direct control. These are that EPAcan identify the sites within 3 weeks, that the tank

 owners/operators can comply with the contractor's schedule, and that the vendors and construction

subcontractors can comply with the contractor's schedule. The other assumptions are as follows.

       1.     Final  safety  and related  training and mobilization will require  approximated
             2 weeks, and can occur simultaneously with EPA's efforts to                  *

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       2.
       3.
       4.
                                                      Section No.    1
                                                      Revision Mo.   7
                                                      Date: October 4.1995
                                                      Pane: 19  of  21
Scheduling the sites, vendors;, and construction subcontractors can start as soon as
some of the sites are identified, and can continue after field work has started at some
sites.   '•,.'-'',         '             •      •         .        *  '
Each site requires 10 working days of field work. However, work can be staged, so
that work can be ongoing at more than one site at a time. A 1 -week overlap has been
assumed for the first four sites, and a half-week overlap for the last three, as the
various participants become more adept at their roles.
                     1            "                ~~       •     '     f      -
                                              -     " •          '• '     %
About a week and a half has been allocated to complete the lab work after all field
work is completed.
1.6.3 Regional Test Schedule for the Remaining Regions
       The assumptions made for the first region remain essentially valid for the remaining regions.
However, because of the experience gained by the research team and the vendors in the first region,
              ,                     . ,      ^   -           .   y     . .
the work in each of the remaining regions can be conducted somewhat more expeditiously.  It is
estimated that work at the first site can begin after 2 weeks, even though all 7 sites may not yet have
been selected. Work at the various sites can be overlapped somewhat more than hi the first region.
It is expected that field work in the remaining regions may proceed more rapidly than in the first
region.  As a result of all these assumptions, it is estimated all work at each remaining site can be
completed in 9 weeks, compared with 11 weeks for the first region.
1.7    Project Organization and Responsibilities
       The project organization and lines of authority and responsibility are presented in Figure 1-4.
Ms, Carolyn Esposito (Telephone:  (908) 906-6895) of the EPA NRMRL is the EPA Work
Assignment Manager (WAM) and will oversee all activities conducted hi this project. Ms. Esposito
will review the draft QAPP, and review the final report to determine if the project objectives and QA
requirements have been satisfactorily addressed. Mr. Guy Simes is the EPA Quality Assurance
Officer (QAO).  Guy Simes will review the QAPP or assign a designee to review the QAPP to
                             '
ensure that all QA requirements have been satisfactorily addressed.
       Mr. Robert Amick (Telephone: (513) 782-4759) is  the IT Project Manager for this contract.
Mr. Amick will provide overall review of the quality, budget, and timeliness of work conducted in
this project.  Ms. Janette Martin (Telephone: (513) 782-4956) is the IT Work Assignment Leader

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                                                                    Section No.   1
                                                                    Revision No.	1_
                                                                    Date: October 4.199S
                                                                    Page:  20 of  21
 (WAL) responsible for ensuring the completion of the project and for providing project status
 information to the EPA WAM.  She has ultimate responsibility for ensuring project quality and
 timeliness. Mr. Tom Clark (513-782-4700) is the IT QAO for the Cincinnati office. He will monitor
 the project activities to ensure the proper conduct of analyses, data reduction, and data reporting.
 Mr. Dennis O'Conner, and members of a Work Group formed specifically for this Work Assignment,
 will provide expert technical expertise and oversight during this study.
       Ms.  Martin will be assisted hi conducting the technical work by IT technical  staff and
 personnel from IPs subcontractor, Midwest Research Institute (MRI). The MRI Project Manager,
 Dr. J.D. Flora (816-753-7600), is responsible for technical oversight of the work conducted by MRI
 and will report to the IT WAL. Ms. Carol Green (816-753-7600) is the MRI QAO. She will conduct
 or direct audits as required hi the QAPP.
       Communications during this project will be maintained through weekly telephone calls
 between the  IT WAL and the MRI Project Manager, and the IT WAL and the EPA WAM. The IT
 Quality Assurance Officer and the Health and Safety Officer will be included in the calls and provide
technical assistance as required during the project. If a serious problem arises, IT and MRI will
immediately discuss the problem over the telephone, possible corrective actions will be discussed,
and the selected actions will be carried out.

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                                                                 Section No, _J_
                                                                 Revision No.  1
                                                                 Date: October 4.1995
                                                                 Page:  21  of 21
 Work Group Members
  Thomas -Barb, Ph.D.
 Quinton Bowies, Ph.D.
  Bopinder Phull, Ph.D.
   Oliver Siebert, P.E.
   IT Technical Staff
      MRI Health
    & Safety Officer
  James McHugh, CIH
On-Site Subcontractors
   • abrasive blasting
 ,  • leak detection
                                EPA Work Assignment
                                      Manager

                                   Carolyn Esposito
                                  IT Project Director

                                  Robert Amick, P.E.
IT Work Assignment
       Leader
   Janette Martin
MRI Project Manager

 Jairus Rora, Ph.D.
 MRI Technical Staff
                                  EPA QA Officer
                                IT Senior Reviewer

                                 Dennis O'Conner
      FT Health
   & Safety Officer
Larry Verdier, CIH, CSP
                                    IT Quality
                                Assurance Officer
                                  Thomas Clark
     MRI Quality
  Assurance Officer
     Carol Green
  Commercial Labs
                        Figure 1-4.  Project Organization.
                                                                                 MWI6417-2-3-SW5-O

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                                                                    Section No. _
                                                                    Revision No.
                                                                    Date: October 4.1
                                                                    Page:  1  of  8
                                      SECTION 2,0

                         QUALITY ASSURANCE OBJECTIVES
2.1    Overall QA Objectives

       The primaiy purpose of this study is to evaluate the performance of four different methods
for determining the suitability of steel underground storage tanks for upgrading with cathodic

protection.  The findings of each tank assessment method will be compared with the results of
baseline:tests that determine the actual status of the tank.

       The primary project objective is to estimate the proportion of correct decisions made by each
vendor assessment method with a 95% confidence interval having a half-width of 0.15 or less.    ;.

       For example, an estimated proportion of correct decisions of 0.85 with a 95% confidence

interval of (0.78, 0.92) would meet this objective.
       To do this, the following secondary objectives must be met:

       «     A statistically valid number  of  tanks  must be tested.  (See Subsection 15,
             Experimental Design.) For design purposes, 100 tanks are to be tested arid between
             45 and 55 of these tanks should be found to be suitable for upgrading by cathodic
             protection.                                                           .

       •     Vendors must follow established protocols and procedures.  (See Subsection 2.2,
             Evaluation and Documentation of Vendor Protocols and Procedures.)

       •'.    The data collected from each vendor method and the baseline tests for each tank and
             coupon must be. thoroughly documented  and sufficiently complete so that the
             conclusion reached may be reconstructed. (See Subsection 2.2.2, Documentation of
             Observed Procedures.)

       •     The precision of the baseline tests of the 5 deepest pit depths and the precision of the
             through-wall thickness measurements must be within specified criteria as proof of
             the reliability of the baseline tests.  (See table 2-2, Quantitative QA Objectives for
             Baseline Test Procedures.)

       •     Vendor results must be compared to the criteria for judging an underground storage
    1         tank to be acceptable for upgrading with cathodic protection. (See Subsection 2.2.3,
        '  " Criteria for Upgrading.)                                       ,

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                                                                      Section No.
                                                                      Revision No.
   2.2
                                                                    Page:_2_of_E_

        •     Each tank must be classified according to its status for upgrading with cathodir
               protection as detexmined by the baseline tests and as.repSed by^e vendor's
               assessment method.  (See  Table  1-2, Perfonnance MeLres for Ass™


        Documentation of Vendor Protocols and Procedures

        Evaluation and documentation of vendors protocols and procedures are important to:
        •     V^fy^ttheprotocolsandprocedires^

        •     Establish to vendor field crews both understand and follow the written protocols
              and procedures so that the data are properly evaluated, interpreted and arcSved

2.2.1  Comparison of Vendor Protocols to Applicable Standards

       Prior to participation of a vendor in this program, the vendor will submit a written protocol
that describes the purpose and principles of the method. This document will generally also contain
the following information:
        1.
        2.
        3.
        4.
        5.
        6.
        7.
             Scope and applicability of the method
             List of reference publications
             Delineation of applicable permits and local approvals
             Personnel training requirements
             General safety requirements
             Step-by-step procedures
             Methodology for inspection and compliance to specifications
        The contractor will review the vendor's protocol and compare it to any consensus standards

 such as thoseoftheAmericanPetroleumlnstituteCAPI), American Society for Testing and Materials
 (ASTM), American Society of Mechanical Engineers (ASME), Underwriters Laboratory (UL), and
 EPA Federal Register,  and will make an engineering judgment that the protocol meets'any
 appropriate and minimal standard, and/or note any discerned deficiency.

 2.2.2  Documentation  of Observed Procedures

       Prior to the observation of the vendors' operations the contractor will devise a check list of
the step-by-step procedures as delineated in the vendor's protocol.  The ^afeiSf keep a log of the

observed procedures for comparison with the protocol. In addition to this check list, the contractor
will note any other information deemed pertinent. As an example, note will be made of the type and

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                                                                 Section |\lo.
                                                                 Revision Mo.
   model of equipmenWnstanentation utilized, abrasive material and specifiers used during
   abrasrve blasting, maintenance and/or calibration of equipment, adequacy of data obtained, and
 .,.  record keeping.

         For each vendor's operation the contractor will providea succinct summary providing
   conclusions and recommendations.
  23   Criteria for Upgrading

        There is currency no single standard criterion for judging an underground storage tank ,„ be
  acceptableforupgradingbyfteadditionofcamodicprotection.  Consequent*, the determination
  of the acceptability of a tank for upgrading based on the baseline tests will be made using four
  drfferen, criteria. These are listed below. Bom forms of me vendor's conclusions wi,l be compared
 to each of these four criteria and the results summarized


 ~"
             suitable. (This requirement is specified in the Federal Regulations.)
 Criterion!:   To  b<
 "-*

             0.240 in. Note: Requirement(a) implies that there can be noperforations



      Quantitative QA Objectives
      For the vendor tests, only completeness objectives can be estabUshed. For the baseline tests
bothprecisionand completeness objectives ^^.~4^to£^^^^ .
Criterion 4:
2.4

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                                                                      Section No.    2
                                              ,   :                     Revision No.   1
                                                                      Date: October 4.1995
                                                                      Page: 4  of  8
                                            »  »                         ,
from a tank. A location grid is used to document the position of the measurements and various

features. Completeness objectives for the four vendor tests are provided in Table 2-1. Objectives

for the baseline tests are provided in Table 2-2.

       Table 1-2 classifies the tanks by the vendor's results and the actual tank condition. The cells

where the vendor's result agrees with the actual condition are correct decisions, while those where

the results disagree represent errors.
       •     A correct decision occurs if a vendor's result agrees with the baseline finding about
              the tank's suitability for upgrading with cathodic protection.

       •     A false alarm occurs if a vendor's result fails a tank that is suitable for upgrading (by
              cathodic protection).

       •     A correct detection occurs if a vendor's result fails a tank that is not suitable for
              upgrading.

       •     A missed detection occurs if a vendor's result indicates that a tank is suitable for
              upgrading, when, in fact, its actual condition does not qualify it for upgrading.

       •     A correct approval occurs if the vendor's result approves a tank for upgrading and
              the tank is actually suitable for upgrading.

                   Table 2-1. Completeness Objectives for Vendor Tests
Type of test
Modeling
Video
Ultrasonic
Inspection
Subject
Data, measurements, records,
conclusions, reason for failing
Data, measurements, records,
conclusions, reason for failing
Data, measurements, records,
conclusions, reasons for failing
Data, measurements, records,
conclusions, reasons for failing
Completeness (%)
100
100
100
100

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                                                                      Settion No.   2
                                                                      Revision Wo. _J_
                                                                      Date: October 4.1995
                                                                         B:  5 of 8
            Table 2-2. Quantitative QA Objectiyes for Baseline Test Procedures
Critical
measurement
Pit Depth
Wall thickness
Wall Thickness
through 5/8" sentry
holes (for nominal
quarter in steel tank)
Pit Diameters
(maximum and
minimum if not
circular)
Location by grid
system
Tank diameter
Equipment
Depth Gauge
Micrometer Model
449AZ-3R, L.S.
Starrett Company
Ultrasonic Thickness
Gauge Model
DM4DL,
Krautkramer Branson
Company using a 0.38
in transducer and
EXOSEN 30 couplant
Throughwall
Micrometer,
Inspectors
Micrometer Model
175RLZ.L.S. Starrett
Company)
Ruler (common
source)
Tape measure
(common source)
Tape measure or tank
gauge stick (common
source)
Sensitivity and
Reporting units
(in)
0.001
0,001
0.001
0.0625
0.5
0:0635
ty"
Precision (in)
0.01
NA ;
0.01
NA
NA
NA
Completeness
(%)
100
100
100
100
100
100
*
NA = Not Applicable

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                                                                   Section No.   2
                                                                   Revision No.  1
                                                                   Date: October 4.1995
                                                                   Page: 6  of  8
                                           i
       For this study, the accuracy of a tank assessment method is defined as the probability that
the method correctly determines that a tank is suitable for upgrading with cathodic protection. The
reliability of a tank assessment method is defined as the probability that the method correctly.
                                   .!','                       ;                           •
identifies a tank that is unsuitable for upgrading with cathodic protection.  Thus, among tanks
suitable for upgrading, the proportion of tanks correctly passed and incorrectly failed by each
assessment method must be estimated.  Naturally the sum of these two proportions is 100%.
Similarly, among tanks not suitable for upgrading, the proportion of missed detections and correct
detections must be estimated for each assessment method.  Again, these two proportions add to
                                                                          i •**
100%.                                                                    .
       A measure of performance of an assessment method, combining both aspects of performance,
is the overall correct rate of an assessment method. The overall correct rate is the proportion of
tests hi the upper left cell and the lower right cell of Table 1-2 among all tests. The complement of
this is the proportion of incorrect decisions among all tests.
       The goal is to estimate the vendor's overall correct rate to within ±0.15 with 95% confidence.
In addition, the performance measures in Table 1-2 will be estimated to within ±0.15 with 95%
confidence. This is referred to as the 95% confidence interval for the proportion having a half-width
of 0.15 or less. For example, for a false alarm rate  of 50%, it will be possible to  estimate the False
Alarm Rate of 0.5 ±0.15 (or 50% ± 15%) with 95% confidence.  The confidence interval will be
smaller for values of the proportion close to zero or one.
       In order to estimate these proportions, the study  must contain both tanks suitable for
upgrading and unsuitable for upgrading. If the numbers of suitable and unsuitable tanks in the stu,dy
are equal, the estimation of the two error rates would be based on the same sample sizes and so be
of about equal precision.  However, since the actual condition of the tanks in the study will not be
known until the baseline tests have been run, these sample sizes cannot be chosen hi advance.
       The number of tanks to be used in the study was chosen to provide the required amount of
data to estimate these proportions with the stated confidence and length of the confidence interval.
Assuming that approximately half of the tanks are found to be suitable for upgrading by the baseline
tests,  the denominator for estimating the probability of false alarm (PFA) and the probability of

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                                                                    Section No.
                                                                    Re vision No.
                                                                    Date: October
                                                                    Page:_Z_of JL
 detection (PD) will each be approximately SO.  The maximum width of the confidence interval
 would occurif the estimated proportion is 0.5. Using the normal approximation to the binomial, the
 half-width of the confidence interval in this case is
                                     W=1.96y'(0.5)2/n
where the number 1.96 came from the normal distribution for a two-sided 95% confidence interval.
If W is specified as 0.15, this equation can be solved for n to yield 43. Thus, the total sample size
of 100 tanks, which is expected to provide about 50 tanks suitable for upgrading and 50 that are not
suitable for upgrading, should be sufficient to meet this objective.
       It should be noted that if the methods actually produce a relatively small false alarm rate and
a high rate of detection, then the width of the confidence intervals will actually be shorter than the
worst case used for estimating the sample size.
2.5    Qualitative QA Objectives
       Comparability of data will be assured by use of the same brand of equipment by all of the
baseline field crew members. In addition, all baseline field crew personnel will be proficient in the
measuring and recording methods using the equipment.
2.6    What If QA Objectives Are Not Met
       The primary QA objective would not be met if the proportion of tanks found suitable for
upgrading differs substantially from 50%, this will affect the estimates of some of the performance
parameters.  In the most extreme case, if no suitable tanks were found, the study would be unable
to estimate the correct approval rate (the proportion of suitable tanks correctly identified by each
assessment method).  This extreme case is unlikely. If, say, the suitable group is much smaller than
the unsuitable group, then the confidence interval for the correct approval rate would be larger than
expected. The confidence interval for the correct detection (of unsuitable tanks) would be shorter
than expected.  The confidence interval for the overall correct rate would not be affected, although
it would be based on  a slightly different combination of correct approvals and correct detections.

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                                                                     Section No. __2_
                                                                     Revision No.	1_
                                                                     Date: October 4.1995
                                                                     Page:  8 of 8
       Other QA objectives would not be met, for instance, if triplicate measurements of pit depth
did not meet the precision objectives.  This would reduce the statistical confidence level of the study
and possibly cast doubt on the conclusions reached concerning the tank. An overall outcome would
be a weaker study with the possibility of the study gaming less acceptance from industry and
                                       i.    '                          •
regulators.

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                                                                    Section No.   3
                                                                    Revision Wo.  1
                                                                    Date: October 4.1.995
                                                                    Page: 1  of  10
                                      SECTION3.0
                  SITE SELECTION AND SAMPLING PROCEDURES
3.1    Site Selection
       Tanks will be selected by the contractor from an EPA list of a tank population provided by
the industrial and corporate community.  Ideally, approximately half of the tanks selected will be
suitable for upgrading and half will not.  The owner/operator of the tank will be asked to provide
information regarding the condition of the tank. Definitive data regarding whether a tank is suitable
for upgrading will not be known hi advance. Therefore, information provided by the owner/operator
(such as leak detection results, age, etc.) will be used to determine the approximate condition of the
tank.
       Steel tanks that have not been eathodically protected or lined will be selected to provide a
population encompassing a wide range of tank conditions including:
       •      Leaking tanks (tanks that have failed a leak-detection test)
       •      Nonleaking tanks (tanks that have passed a leak-detection test)
       •   ,   Tanks of unknown condition
       •      Tanks in a variety of geographic locations
3.2    Sampling Locations
       With regard to sampling strategy, results of vendor reports will be used to help identify areas
for conducting baseline tests.  The tank will have a grid system applied, with each grid being
approximately 9 ft2.  See Appendix, B for a figure showing the sampling grid numbering pattern
scheme to be used for all tanks. All grids will receive ultrasonic measurements. Lacking indications
of problem areas, randomly selected areas will be chosen for additional testing:  The random
                                                                           S     '      .
selection will be stratified to include areas known to be problematic (i.e., beneath the fill pipe, top
of tank, bottom of tank, etc.). Baseline testing will consist of axis measurements, pit depth, wall
                              s-            , •  -   -       .          ,
thickness and pit diameter measurements.
       A minimum of one and a maximum of five pit depth measurements will be made in each grid
of the tank on the exterior (if pits of apparent depth of least 0.05 in. are visually detected). On the

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                                                                   Section No.   3
                                                                   Revision No.  1
                                                                   Date:  October 4.1995
                                                                   Page:  2  of  10
interior of the tank a minimum of one and a maximum of five pit depth measurements will be made
on each grid of the tank for which pits of apparent depth at least 0.05 in. are visually detected.
Triplicate measurements will be made of the five deepest pit measurements for each tank.  The
average and standard deviation of the pit depth for each of these five pits will be calculated.
       Pit diameters of at least 0.125 in will be measured at the place on the inside of the tank
farthest from the remote video camera location.  If the pit diameters on the surface furthest from the
point of access for the video camera are near 0.125 in, the field team will have the pit diameter
measured by two persons to confirm that the diameter either exceeds or is less than 0.125 in. If pit
diameters are substantially larger than 0.125 in, a single measurement will suffice. Pit depth (inside
or outside) and pit diameter (inside) are not necessarily measured on the same pit.
       Ultrasonic tests of wall thickness will be made at the approximate center of each grid. For
any grid in which a thickness reading less than 90% of the minimum required wall thickness as
specified in UL 58 is obtained, the grid will be subdivided into nine smaller grids and readings will
be taken from each subsection.
       In addition, approximately 1-ft2 coupons will be cut using a cutting torch from tanks which
have passed all on-site tests. Areas for sampling coupons will be selected by searching for areas of
greatest corrosion potential or observed corrosion and two  coupons will be cut for each tank.
Coupons will be labeled according to the scheme described in Subsection 3.5, Sample Custody.
3.3    Baseline Testing
       The baseline tests listed below will be performed. Appendix B provides field procedures and
forms for the baseline tests. The number of measurements of each type will be a function of the tank
size. Table 3-1 provides the approximate number of measurements of each type for a nominal 8000
gallon tank that is 8 ft in diameter and 21 ft long. The contractor's field crews  may increase the
number of measurements based on observations and judgement if it appears that this would give a
more complete determination of the tank condition. Such a tank would have a grid with 66 locations
consisting of 8 sections around the circumference and 7 sections along the length of the cylinder plus
5 sections on each end consisting of a center circle and 4 sections around the outside of the central
circle.

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                                                                      Section No.   3
                                                                      Revision No.   7
                                                                      Date: October 4.1995
                                                                      Page: _3^ of  10
                           Table 3-1. Number of Measurements
<»
(b)
Measurement Type
Ultrasonic Wall Thickness
Pit Depth Gauge^
Pit Diameter0
Tank Diameter
Through-wall micrometer wall
thickness
Number^
66
162 - 690
10
2
'.'< 2
Based on a nominal 8000 gallon tank, 8 ft. diameter and 21 ft. long
Minimum number based on one pit depth measurement per grid square (66) plus triplicate measurement of 5 deepest
pits (15) for both interior and exterior. Maximum number based on five pit depth measurements per grid square
(330) plus triplicate measurements of 5 deepest pits (15) for both interior and exterior. Actual number may vary
depending on number of pits observed.
Up to ten pit diameters will be measured; actual number may vary depending on number and size of pits observed.

1...     Prior to excavation and removal of the tank, axis measurements will be made with
       a tape measure or tank gauge stick to document the vertical diameter of the tank.
       This checks for the tank's "out of roundness" due to deformation and gives a gross
       indication of tank condition.

       The vertical diameter will be measured at the fill pipe from outside the tank while it
       is still in the ground and this measurement recorded.   After the tank has been
       removed and an access hole cut in one end, the internal vertical diameter at the same
       location will be measured. If this measurement agrees with the original measurement
       to within 0.5 in, no substantial deformation occurred during removal. In this case,
      , the horizontal diameter at that location will be measured. If the difference between
       the original vertical diameter measured before removal and the horizontal diameter
       is more than 2% of the average of these two diameters, the tank, will be judged to be
       structurally deformed.
       If the original vertical diameter measured before removal differs more than 0.5 in
       from that measured after the tank is out of the ground, internal vertical and horizontal
       diameters will be measured at each end (where the end caps provide additional
       strength and would not deform). The average of these four diameter measurements
       is used as the original diameter of the tank. If the original vertical diameter measured

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                                                      Section No.   3
                                                      Revision No.  1
                                                      Date: October 4.1995
                                                      Page: 4 of  10
                          i  ,  r
before removal differs from this average diameter by more than 2%, the tank will be
judged to be structurally .deformed.

The tank will be excavated and removed by the tank owner or their subcontractor.
The contractor's field crew will hose down the tank or carefully brush away loose
soil.  The tank will have a 3 ft by 3 ft grid pattern applied to the exterior using a
combination of chalk lines and wax markers. The grid will be applied in the fol-
lowing manner:

•     The length of the tank in  feet will define the number of  horizontal grid
       sections, which run longitudinally along the cylinder of the tank.

•     The circumference of the tank will be divided into as many equal segments
       as the tank diameter hi feet.

•     Starting at the opened end of the cylinder, marks will be made every 3 ft for
       a circumferential grid line.  This provides the grid of the cylindrical surface.
       Each end will have a center circle of 9 ft2 area defined (a radius 20.375 hi).

•     The remaining area will be divided into equal segments of about 9 ft2 each.
       For example, an 8-ft diameter tank has about 45 ft2 of surface on each end.

•     Appendix B contains a figure showing the sampling grid numbering pattern
       scheme to be used for all tanks.

A visual inspection of the exterior of the tank will be conducted after the grid has
been applied. The purpose of the inspection is to detect surface discontinuities such
as cracks, holes, pits, general corrosion, and other porosities in the tank. A data form
will be provided for documentation of the visual  inspection. This inspection and
other visual  inspections of the ulterior and exterior will follow the procedure
provided hi Appendix B. The type of examination is a direct visual examination.
The written procedure for this is provided in Appendix B and calls for viewing the
entire surface with the human eye at a light level of at least 161 lumen/m2 from a
distance of no more than  24 hi.  A magnifying glass will be used  to observe
questionable areas.

Still photography using a 35 mm camera with color film will be used to document
the tank condition Areas of discoloration, apparent corrosion, exterior evidence of
petroleum product,  or obvious holes will be identified and referenced.  Special
attention will be paid to the bottom of the tank and to the lower weld seams as well
as to bungs, fittings, and connections.  If any rust plugs are identified, simple means
of extracting them will be made, such as with a screwdriver or hammer.

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                                                              Section No.   3
                                                              Revision Wo.  7
                                                              Date: October 4.1.QQR
                                                              Page:_5_of_m_

4.     The exterior of the tank will be abrasive blasted to bare metal (NACE 2 or SSPC-
       SP10) and the grid will be reapplied. A second visual inspection of the tank exterior
       will be conducted. This will be accompanied by still photography to document the
       tank condition.

       In making the baseline visual observations, the field personnel will characterize any
       apparent corrosion according to the following descriptions:

       •      Note presence, location, and approximate size of any perforations

       •   ,   Pro vide an estimate of the nature and approximate percentage of area within
              each grid location of a given type of corrosion

       •      Note the  presence, nature, and  approximate density  of shallow pits,
              subjectively judged to be <0.05 in deep

       .•      Note the presence, nature, and approximate density of deep pits subjectively
              judged to be 0.05 to 0.10 in deep

       •      Note the presence, nature, and approximate density of very deep pits
              subjectively judged to be > 0.10 in deep
  1                            .               •                              s
       •      Note the corrosion pattern, i.e., pits widely dispersed, isolated, overlapping,
              or in line

       •      Note an association of pitting with tank geometry or structural features, e.g.,
              top of tank, bottom of tank, under a gauge sticking port, at an apparent sludge
              line or ullage line, or associated with a weld, bend, or other stress risers

       •      Note surface conditions such as general roughness, evidence of coating, rust
              plugs, tubercles, and scale

       •      Provide a  characterization  of corrosion product including color, loose or
              tightly adhering, soft or hard, wet or dry, and any distinctive smell such as
              that of hydrogen sulfide

       • "•     Provide a characterization of pits as concave and hemispherical, elongated,
              vertical sides,  undercutting, subsurface, narrow and deep, or horizontal
              tunneling.

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                                                             Section No..
                                                             Revision No..
                                                             Date: October 4.1995
                                                             Page:  6 of  10

       Particular attention will be paid to those areas identified in the initial inspection and
       to problem areas not earlier evident but made visible by the abrasive blasting. These
       problem areas will be documented.

5.     The end of the tank that was closest to the placement of the internal video camera
       location will have an entry hole cut in it and the interior will have a grid applied as
       previously described. The interior of the tank will have been abrasive blasted to bare
       metal during the vendor assessment tests. A visual inspection of the interior of the
       tank will be conducted. This will be accompanied by still photography to document
       the tank condition. Areas of discoloration, apparent corrosion, or obvious holes will
       be identified and referenced for specific area testing.

6.     Ultrasonic measurements will be conducted to determine wall thickness. This testing
       will be done primarily from the inside of the tank, but may also be done from the
       outside. If areas of the inside are  pitted or rough to the extent that the ultrasonic
       instrument does  not indicate  a  satisfactory coupling with  the  surface, the
       measurement will be taken from the outside.

       Each 3 ft by  3  ft area will be defined by the  grid reference system for that tank
       described in Section 3.5.  An ultrasonic test of the wall thickness will be made at the
       approximate  center of each  marked grid.  The minimum required original wall
       thickness for each tank will be determined by the tank size in accordance with UL
       58. The thickness varies with tankage volume. Typically, the minimum required
       wall thickness is expected to be 0.240 in for a tank with a nominal wall thickness of
       0.25 in.

       Any grid section in which an ultrasonic thickness reading less than 90% of the
       minimum required wall thickness was obtained  will be subdivided into nine smaller
       grids. Then, a reading will be taken from each subsection. The average of these nine
       readings will be taken as the average wall thickness of that section. The field crews
       may elect to take additional ultrasonic readings in any  grid section based on their
       observations  and judgement  All readings taken in a grid section will be averaged
       for the average wall thickness of that section.

7.     Areas of the tank wall identified as likely to be thin will be marked. A portion of
       these areas, to include the suspected thinnest wall sections, will be subjected to direct
       physical measurement. This will be accomplished by drilling sentry holes through
       the tank wall of 0.625 in diameter  (for nominal wall thickness of 0.25 hi) to accept
       a thickness gauge or micrometer. Burrs will be removed from the drilling by filing
       or grinding.  A micrometer will then be inserted through the hole and the thickness
       measured directly. Duplicate wall thickness measurements will be made through the
       sentry holes.  If the ultrasonic measurement indicates that the wall thickness is less

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                                                      Section No..
                                                      Revision No..
                                                      Date: October 4.1995
                                                      Page:  7  of  TO

than  90% of the required minimum wall thickness, up to 5  direct thickness
measurements will be made using sentry holes to confirm the ultrasonic readings.

For each 3 ft by 3 ft grid area of the interior and exterior of the tank that has one or
more pits  that are visually judged to be 0.05 hi deep or more, at least one pit depth
measurement will be taken with a depth micrometer and recorded.  After these
measurements have been completed, the five deepest pits will be measured two more
times, giving triplicate measurements. For these 5 deepest pits, a measurement of the
remaining wall thickness will be attempted using the ultrasonic instrument from the
side opposite the pit. The ultrasonic instrument will be set hi a mode to store the
minimum  thickness measured, and then used to scan acrossjthe area of the pit from
the opposite side of the tank wall.

In cases where the pit depth of the deepest pits cannot be accurately measured with
a depth micrometer (for example, the pit is on the curved section of the end wall
where it is welded to the cylindrical portion of the tank, or the pit in question is
surrounded by other pits or areas of severe corrosion such that the depth gauge has
no good bearing surface), the pit depth must be measured by other methods. At least
two of the following methods will be attempted:

a.     Taking an ultrasonic measurement of the remaining wall thickness.

b.     Drilling a sentry hole next to the pit and using a throughwall micrometer.

c.     Cutting a coupon  containing the  pit from  the tank and sending it to a
       laboratory for sectioning and photomicrograpning (see following discussion).

In cases where the deepest pits are in an area of overlapping pits, so that the original
surface does not remain, the remaining wall thickness will be subtracted from the
required minimum wall thickness to give a depth.  If the apparent original wall
thickness of the tank can be determined from a relatively uncorroded section of the
tank and if it exceeds the minimum wall thickness, the remaining wall thickness of
the pits will be subtracted from this value to give a determination of pit depth.

In cases where no perforations were found in the tank shell, coupon samples for
laboratory analysis will be taken. At least two coupons, measuring approximately
12 x 12 in, will be identified by the field crew and cut from the tank by the tank
removal subcontractor using a cutting torch. In all cases, the feature of interest  will
be at least 2 in.  from the edge of the coupon to avoid any effect from cutting the
coupon.. One coupon will be taken from the tank wall area that had the least wall
thickness as measured by the ultrasonic instrument. The second coupon will be taken
from the area that had the most severe corrosion hi the opinion of the field crew

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                                                                    Section No..
                                                                    Revision No..
                                                                    Date: October 4.1995
                                                                    Page: 8 of 10

              based on the visual inspection. For example, this might be an area of overlapping
              pits on the exterior or an area along the bottom that had many small pits with
              apparent or possible undercutting.  Examples calling for. additional coupons may be
              taken at the discretion of the field crew.  Examples calling for additional coupons
              would include but not be limited to corrosion along a weld, an apparent crack in a
              weld, two distinct areas with different types of corrosion such as overlapping pits on
              the outside and intergranular corrosion on the inside, or a deep pit whose depth could
              not be measured satisfactorily by other methods.

              The coupons will be permanently marked in the field for identification. Coupons
              containing suspected weld cracks  will be taken to H.R. Inspection Service,  a
              commercial laboratory in the Kansas City area, for radiography testing. See
              Appendix A for the Radiographic Testing Procedure.

              All coupons will be photographed at MRI, with marking applied to show the location
              of interest.  They will be subjected to wall thickness measurements by ultrasonic
              and/or micrometer as well as pit depth measurements. If these measurements are not
              definitive and if additional data are needed to classify the tank according to the
              criteria in Section 2.3, smaller sections that contain the area(s) of interest will be cut
              from the coupons at MRI. These smaller sections, along with copies of the MRI
              photographs, will then be sent to Sherry Labs Oklahoma in Tulsa, Oklahoma for
              sectioning and mounting. Photomicrographs will be taken by that lab and returned
              along with the mounted specimens to MRI for definitive measurements of the wall
              thickness, pit depth, and weld cracking.   .

3.4    Sampling Equipment

       Sampling equipment to be used for the baseline tests includes:  drill with 5/8" bit (for sentry

holes), tape measure, chalk  line, and wax marker (for gridding).  All other equipment are for

measurements. Abrasive blasting equipment and an acetylene torch for cutting coupons will be

supplied by the tank contractor on site.
3.5    Sample Custody
       The five regions will be assigned numbers as follows:
       Rl     Midwest
       R2     Northwest
       R3     Southwest
       R4     Southeast
       R5     Northeast

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                                                                   Section No.   3
                                                          ,         Revision Wo.   1
                                                                   Date: October 4.1995
                                                                   Pane:  9  of  TO
       Within each region, sites will be assigned numbers sequentially once the list of tanks and
sites has bqen identified., At each site, tanks will be assigned sequential numbers and identified by
location and size on a sketch of the site. Once a tank has had its grid marked on it, each grid section
will be identified by a letter and number as described hi Appendix B, and within each grid section,
each square foot will have a number from 1 to 9 assigned to it. Thus, each tank can be identified by
the region, site, and tank number; e.g., Rl, S2, Tl would denote tank 1 at site 2. in region  1
           t              "        -                 t        ',               i  '        '  •
(midwest). A location on that tank would be identified by a sequence of a letter and two numbers;
e.g., D-5-4 would denote square foot number 4 in the grid section that begins 15 ft from the opened
end of the tank apposition D around the circumference. This location scheme will be used to mark
the coupons to be cut from the tank.           .
       Sample coupons will be initially marked with chalk and engraved or punched on their surface
prior to leaving the site hi order to provide permanent identification. Coupon History Forms will
be provided to document sample collection and sample history for each coupon taken at each site.
 Figure 3-1  provides an example of a Coupon History Form. Coupons and forms will then be
packaged and shipped according to DOT regulations.
       The field crew chief will be responsible for samples during field sampling.  Responsibilities
will include labeling samples and preparation of the sample documentation form.  Samples will be
permanently marked by engraving or punching in the field and shipped to MRI.  A sample history
form (Figure 3-1) will be prepared for each set of samples (one site's samples) and will travel with
the sample set as it is moved about for testing and analysis.
       Each time a sample set begins to undergo testing, the sample history form will be reviewed
and samples checked for correctness and completeness. If problems with a sample set are discovered
(such as missing or incorrect samples) the nature of the problem will be noted on the sample history
form and reported immediately to the MRI Project Manager and MRIQAO.

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                                                                      Section No.   3
                                                                      Revision No.  1
                                                                      Date: October 4.1995
                                                                      Page:. 10  of 10
                          Figure 3-1. Coupon History Form
COUPON
NUMBER
REGION
          SITE
                 TANK
                         COLLECTED
                            BY
  DATE
COLLECTED
                                                    RECEIVED BY
                                                                   DATE RECEIVED

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                                                                   Section No.   4
                                                                   Revision No.  T
                                                                   Date: October 4.199B
                                                                   Page: _L of J_    '
                                     SECTION4.0
                 ANALYTICAL PROCEDURES AND CALIBRATION
4.1    EPA-Approved or Other Validated Standard Methods
       The vendor methods are attached in Appendix C. The three new vendor methods (i.e.,
modeling, video, ultrasonic) are adapted from ASTM ES40-94.  The internal inspection method is
adapted from API 1631, NLPA 631, or NLPA 632.
       The baseline method has been summarized in Subsection 3.3.  The baseline method consists
of visual  inspections of the interior and exterior, depth, width, and thickness measurements,
evaluation of the type of corrosion, and the pit depth tests described in Subsection 3.3. The critical
measurement, type of measurement, and type of equipment used for the baseline tests are shown
below in Table 4-1.                                                ~
4.1    Calibration                                        K
       The depth, micrometer will be calibrated at the beginning and end of measurements for each
tank and the zero readings reported. The average will be used to correct all readings for accuracy.
       The through-wall micrometer will be calibrated at the beginning and end of measurements
for each tank and the zero readings reported.  These will be used to correct the readings.
       The ultrasonic gauge calibration will be checked upon instrument power-up and prior to
beginning each series of readings on each tank and its value recorded.  If the calibration value is off
by more than 5%, a two-point calibration will be done to calibrate the instrument. The calibration
checks will be recorded by the field crew and reviewed at the data reduction stage. The calibration
of the ultrasonic gauge will also be checked on a portion of the tank that appears to have little or no
corrosion. A measurement of wall thickness on such an area will be made with the through-wall
micrometer using an edge or a sentry hole and also with the ultrasonic gauge. The two readings will
be compared and must agree to within ±.01 in. This will ensure that the steel of the tank is not
apprebiably different from that of the calibration block.

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                                                                    Section No.   4
                                                                    Revision No.  1
                                                                    Date: October 4.1995
                                                                    Page:_2_of_2_
                     Table 4-1. Measurement, Type, and Equipment
                        for Baseline Testing of Tanks and Coupons
Critical Measurement and Type
Pit depth (distance)
Wall thickness (distance)
Wall Thickness through 0.625 in sentry holes (distance)
Pit diameter (distance)
Location by grid system (distance)
Tank diameter (distance)
Equipment
Depth Gauge Micrometer
Ultrasonic Thickness Gauge
Throughwall Micrometer
Ruler
Tape measure
Tape measure or tank gauge stick
The baseline methods and forms are provided in Appendix B.

       The calibration frequency and requirements are summarized in Table 4-2. The micrometers
                               •              -                        ,
will be checked before and after making measurements on each tank and the zero readings recorded.

The ultrasonic calibration will be checked on the 0.25-in standard before beginning a series of

readings. If it is more than 5% different from the standard, a two point calibration of the instrument

will be done and the calibration re-checked. The calibration reading will be reported.

                    Table 4-2. Scheduled Baseline Test Calibrations
Equipment
Depth
Micrometer
Through-wall
micrometer
Ultrasonic
Frequency
At the beginning
and end of
measurements
for each tank
At the beginning
and end of
measurements
for each tank
Prior to
measuring each
tank
Acceptance criteria
<0.01 in
< 0.01 in
< 5% relative to NIST
traceable standard
0.25 in
< + 0.01 in compared to
through-wall micrometer
Corrective action
If zero < 0.01, record and correct all
readings; if greater than 0.01 adjust
zero.
If zero < 0.01, record and correct all
readings; if greater than 0.01 adjust
zero.
Record calibration value. If greater
man 5%, recalibrate with 2 point
calibration and re-check.
Recalibrate to match micrometer and
re-check on NIST calibration block.

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                                                                    Section No.   5
                                                                    Revision No.  1
                                                                    Date: October 4.1995
                                                      •'•••-.     Paoe:  1  of 7
                                                           ;                    _
                                     SECTION 5.0
                DATA REDUCTION, VALIDATION AND REPORTING
 5.1 Data Reduction .
       The vendors are responsible for data reduction of their tests.
       The MRI Project Manager is responsible for data reduction of the baseline tests. There are
 four primary measurements to be made on each tank during the baseline test: tank diameter, pit
 depth, pit diameter, and wall thickness.
       For baseline tests each tank will be inspected for penetration and if any holes are found, the
 presence, location, and approximate diameter of holes will be noted. The qualitative assessment of
 corrosion on each 3 ft by 3 ft area of tank wall surface that is made as part of the visual inspection
 will be reduced by providing a textual statement summarizing the condition of the tank in terms of1**
 the amount and type of corrosion identified during the visual inspection.
       The pit depth data will be reduced by reporting the maximum pit depth found for each tank.
 If a tank has a corrosion hole, this will be deemed a pit completely through the tank wall thickness
 and will be noted as a hole, with a numerical value that is the larger of the nominal wall thickness
 (usually 0.25 in) or the largest wall thickness measurement observed on that tank. If a tank has a
 hole, the deepest nonpenetrating pit depth will also be reported.
 The five deepest non-perforating pits will be measured ultrasonically from the side opposite the pit
 to measure the remaining wall thickness. The minimum wall thickness found in the area of the pit
 will be used as the remaining wall thickness at the pit. This value will be subtracted from the larger
 of the measured remaining wall thickness in the area of the pit and the required minimum wall
 thickness (typically 0.240 in) to give another measure of pit depth. This will be compared to the pit,
 depth measured by the depth micrometer and the larger value used to report the maximum pit depth.
 This maximum will be reported as a percent of the required minimum wall thickness as well as in
 the directly measured units.
       The diameters of several pits, if any, on the interior surface of each tank at the maximum
distance from the internal video camera will be measured. Typically this surface will be the circular
end of the tank,  which will generally be 8 ft in diameter.  These data will be summarized by

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                                                                    Section No. _JL_
                                                                    Revision No.   1
                                                                    Date: October 4.1995
                                                                    Paoe: 2 of  7
 reporting whether any pits on that surface were found that were 0.125 in. in diameter or larger and
 whether the internal video inspection identified them or not.  While this is not a criterion for
 determining whether the tank is suitable for upgrading, it is a requirement stated in ASTM ES 40-94
 for the video inspection method.
       The precision estimates of the triplicate determinations of pit depths for the 5 deepest pits
 and the duplicate measurements of the wall thicknesses using the through wall micrometer will be
 calculated and reported as standard deviations. The formula for precision calculations is provided
 in Section 8.
       The ultrasonic thickness measurements from each 3 ft by 3 ft area of tank  surface will be
 averaged using the arithmetic mean to provide an average wall thickness for the shell of the tank.
              i,               „                          V   ,     ,       '       ,
 Any 3 ft by 3 ft section that is found to have a thickness measurement less than 90%  of the required
               i,<             •     ,  	      „   •      ,        '
 minimum wall thickness will have the average of the 9 measurements of wall thickness for that 3
 ft by 3 ft area reported separately. The location of that section will be identified by its grid reference
 and reported.
       For each criterion for accepting a tank for upgrading, the performance measures described
 in Section 2.0 will be calculated for each tank assessment method. A confidence interval for each
 estimated proportion will be calculated and reported. If the sample size available to estimate the
proportion is sufficiently large, the normal approximation to the binomial will be used to calculate
the confidence interval. If the sample size is too small or the proportion is small, exact confidence
intervals based on the binomial distribution will be used. Formulas for these calculations are
provided below.
       The 95% confidence intervals for the performance measures will be calculated using the
binomial distribution.  Each performance measure will be estimated as the observed proportion of
tanks that were classified by the vendor hi a particular category. For example, suppose that the
baseline method determined that 50 tanks were suitable for upgrading.  Each vendor's probability
of false alarm would be estimated as the proportion of those 50 tanks that the vendor concluded were
not suitable for upgrading. Let
       Y,-     =     0      if a vendor determined that the I-th tank was suitable  for upgrading.

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 Let
                                                                   Section No.   5
                                                                   Revision No.   T
                                                                   Date: October 4.1995
                                                                   Pane:  3  of  7
                     1      if a vendor determined that the  I-th tank was not suitable for
                           upgrading.               .
       Ns     -      the number of tanks determined bythe baseline to be suitable for upgrading.
 Then the probability of false alarm, PFA, is estimated as
       The 95% confidence interval for PFA will be calculated using the binomial distribution. If
 both
and
                                       Nv=Ns-Nu
are both at least 5 or more, the normal approximation to the binomial will be used to calculate the
confidence interval.
       That is, the confidence interval for PFA will be given by
                              PFA ± 1 .96JPFA(1-PFA)/NS

       If the requirements for using the normal approximation to the binomial are not met, then
exact binomial confidence limits will be calculated. Denote the cumulative binomial distribution
by   ".       "    -.    '   '                    .  •'   '    ./  '   '-  •       '   :   '   •   .  .'
where the summation is on x from 0 to y, the observed number of events. In the equation nCx stands
for the combinatorial number of ways to choose x items from n items.  That is
Then the lower confidence limit is found by solving the equation

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                                                                     Section No.   5
                                                                     Revision No.  1
                                                                     Date: October 4. 1995
                                                                     Page: 4  of  7
for p,.  Generally the solution must be found iteratively The upper confidence limit is found by
solving the equation                                                .
       BiOwy) = a/2
for pb, where again the solution must generally be found interactively. The result is a two-sided
confidence interval with confidence coefficient 100%(l-a).  In this example the number of events,
y, is the
where the Y,- were defined above. These formulas can be used to calculate the confidence intervals
for each of the estimated proportions hi the performance parameters.
5.2    Data Validation
       The MRI Project Manager will be responsible for ensuring that validation checks are done
on the data reported.  All raw data, including calibration and precision data, and calculated data will
be examined for completeness and compliance to all requirements and objectives. The calculated
data will be examined for accuracy.  Any assumptions will be examined for reasonableness. Any
data affected by problems will be flagged hi the records and in the report as follows:
       C (did not meet calibration requirements)
       P (did not meet precision requirements)
       T (did not meet completeness requirements)
       X (did not meet compliance requirements; i.e., did not follow test protocol/procedures or
       documentation requirements)
53    Data Reporting
       The results of the vendor tests will be supplied to MRI hi reports. Calibration, quality control
checks, calculations, assumptions, and evaluation will be documented and retained in the project
files.  The field crew leader will be responsible for preparing  a data report containing the data
recorded on each tank. The Project Manager will be responsible for preparing the final report. The
data reported will include those shown previously in Table 1 - 1 . All baseline data for pit depth, pit
diameter, and wall thickness will be reported hi niches.

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                                                                    Section No.   5
                                                                    Revision No.   1
                                                                    Date: October 4.1995
                                                                    Page:_§_of_Z_
       The conclusions of each assessment method will be presented in the report as shown below
 (where n  is planned to be 100):
                Table 5-1. Conclusions of Each Vendor Assessment Method
1
BASELINE
SUITABLE
UNSUITABLE

VENDORRESULT
SUITABLE
nn
°21
n.i
UNSUITABLE
nn
«22
n.2
INCONCLUSIVE
nn
na
n.3
< '
ni.
n2
n
       Such a table will be prepared for each of the four criteria listed in Section 2.3 and for both
versions of the vendor's conclusions (i.e. with and without knowledge of the results of the leak test)
       To illustrate how the performance parameters are determined, assume a vendor produces the
data shown in Table 5-2, as compared to one of the evaluation criteria (e.g., presence or absence of
penetrations found in the tanks).
                                Table 5-2. Sample Data

BASELINE
SUITABLE
UNSUITABLE

- VENDORRESULT
SUITABLE
45
8
,53
UNSUITABLE
5
31
36
INCONCLUSIVE
5
6
11

,55
45
100
      With these data, the following can be calculated:
      Correct Decision Rate
             = 76/100 = 0.76 ±0.084
      Proportion of Correct Approval (Accuracy)
             = n,,/nlf
             = 45/55 or 0.81 8 ±0.104

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                                                                    Section No. _JL_
                                                                    Revision No.  1
                                                                    Date: October 4. 1995
                                                                    Page:  6  of 7
        Proportion of Correct Detection (Reliability)
              ^n^/n^
              = 31/45 or 0.689 ±0.138
        Proportion of False Alarms
              =.n12/n,.
              -5/55 or 0.091 ±0.076
        Proportion of Missed Detections
              = n2,/n2>
              = 8/45 or 0.178 ±0.1 14
        Proportion of Inconclusive Results
              = 11/1 00 = 0.11 ±0.063
       Proportion of Inconclusives for Suitable Tanks
              = n,3/nu
              = 5/55 = 0,091 ±0.078
       Proportion of Inconclusives for Unsuitable Tanks
              = 6/45 = 0.133 ±0.101
       The final report will also include a QA section that documents QA/QC activities and results.
                1         .  "    \  , •                '•'•.'
This section will compare the QA findings to the QA objectives and will include a statement regard-
ing whether these objectives were met.  If the objectives were not met for any measurements for
some tank, the impact of this will be assessed  and reported.  Since 'the purpose of these
measurements is to determine whether a tank is qualified for upgrading with cathodic protection,
assessment of any impact will be on whether that decision can be made adequately on the basis of
the data collected. For example, measurements of pit depth that do not meet the standard deviation
requirement would not affect the results if the tank has a corrosion hole, or if another pit also exceeds
the threshold for maximum pit depth.

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                                                                    Section No.   5
                                                                    Revision No. __]__
                                                                    Date: October 4.199B
                                                                    Paoe: 1  of  7
                             *    !      "'*'."     -              '
       Raw and final  hard copy data will be stored as permanent records in MRI Archives.

Computer data will also be stored in MRI Archives, but the life is dependent on the media. Coupons

will be stored by the MRI Project Manager for a maximum period of 12 months after the final report

has been submitted, then disposed of according to IT directions.

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                                                                  Section No.   6
                                                                  Revision Wo.  1
                                                                  Date: October 4.1995
                                                                  Page:.
                                    SECTION 6.0

                     INTERNAL QUALITY CONTROL CHECKS
6.1 Types of QC Checks

       The field staff will be proficient in the use of the baseline equipment and procedures.
       Replicate field measurements will be made as follows:

       •     Triplicate depth measurements will be made for the five deepest pits (excluding
             holes) on each tank and all three measurements and their average and.standard
             deviation will be calculated and reported. In making the pit depth measurements, the
             field crew will adjust the position of the depth gauge to obtain the maximum reading.
             These data will be reviewed for consistency and the precision will be determined and
             reported.

       •     Duplicate wall  thickness measurements will be made using the through wall
             micrometer.

       •     If the difference between the largest and smallest of the measurements exceeds 0.02
             in, the measurements must be repeated.

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                                                                   Section No.   7
                                                                   Revision No.  0
                                                                   Date: August IB.
                                                                   Page:_j_of_2_
                                     SECTION7.0
                       PERFORMANCE AND SYSTEMS AUDITS

       The IT and MRI QAOs will conduct one or more Technical Systems Audits (TSAs) and the
 MRI QAO will conduct one or more Audits of Data Quality (ADQs). Performance audits are not
 appropriate to the scope of work and thus will not be conducted. Results of the audits by the MRI
 QAO will be reported to the MRI Project Manager and[department management, the MRI Project
 Manager will report the results to the IT Work Assignment Leader. Results of audits by the IT QAO
 will be reported to the IT Work Assignment Leader. Audit results and any corrective actions taken
 will be summarized hi the final report.
 7.1 Technical Systems Audits
       The IT and MRI QAOs will conduct technical systems audits during the initial phase of the
 work assignment, and periodically thereafter. All components of the data gathering and management
               •'                :                                   '      &
 system will be audited to determine if these systems have been properly designed to meet the quality
 objectives. The technical systems audit will include a review of the adequacy of the experimental
 design, the control procedures, and the analytical procedures. This review also includes compliance
 to the QAPP, personnel qualifications, project management structure, adequacy and safety of the
 facility and equipment, and the data management and reporting system. The systems audit will end
 with a review of the report, actions taken by MRI Project Manager on inspections and follow-up
 inspections, and an audit of the records at the completion of the study.  IT and MRI  will also
 participate in any external audits scheduled by the EPA Work Assignment Manager during this
 study.                                                            .
 7.2    Audits of Data Quality
       The audits of data quality, an important component of a total system audit, are the critical
evaluation of the measurement, processing, and assessment steps to determine if systematic errors
have been introduced into the system or if specific questions regarding the quality of the data need
to be resolved. During the data audit, the MRI QAO will audit either randomly selected data that

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                                                                     Section No.	Z_
                                                                     Revision No.	Q_
                                                                     Date: August 16.1995
                                                                     Page:  2  of  2
will be followed through the testing and reporting process, or audit all data hi question, if specific
questions of quality need to be resolved.  In addition, the quality control and calibration data will be
audited.  The audit verifies that the data-handling system is correct and assesses the quality of the
data generated to ensure that the data quality objectives are met.
       The completeness of all the data will be checked by the MRI Project Manager after receipt
of data from each tank and field site.
73    Site Audits
       The IT WAL, IT Senior Reviewer, and MRI Project Manager will conduct one site audit per
region to assess the field evaluation procedures, compliance to the QAPP, and field data reporting
procedures.

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                                                                  Section No.   8'
                                                                  Revision No.   0
                                                                  Date: August 16.1995
                                    SECTION 8.0

                 CALCULATION OF DATA QUALITY INDICATORS

              -  -         .'*••-          '                  '

       This section describes the calculation of the data quality indicators that will be used on this

project. Sensitivity is defined as the smallest possible equipment measurement.

8.1    Precision

       For the triplicate or duplicate measurements, the unit of precision will be the standard
         - =   '           - '•- .     .                     ,            '   -  •   -v .  .  "
deviation of the replicate measurements, where the standard deviation is defined as follows:
                                C ~
where:
               s
               y,-
               n
               y
standard deviation
measured value of the ith replicate
number of replicates
mean of the replicate measurements.
8.2 Completeness

    Completeness is defined as follows for all measurements
                                 %C = 100%  x (—)
                                                 T
where:       %C   =  percent completeness

                V =  number of measurements judged valid
               T   ?=  total number of measurements.

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                                                            Section No..
                                                            Revision No,.
                                                            Date: August 16.1995
                                                            Page: 1  of  1
                                     SECTION 9.0
                               CORRECTIVE ACTION
       Corrective actions are required;for any major quality-related or compliance problem. Such
 problems may be detected during routine inspections or by audits. The MRI Project Manager is
 responsible for notifying the IT WAL, making sure actions are taken to prevent recurrence of such
 problems, and that the actions taken are documented in a report to the MRI QAO and department
management. The MRI QAO must evaluate the effectiveness of corrective, actions taken and must
 document the results in a report to the MRI Project Manager and department management. The MRI
 Project Manager is responsible for providing these/results to the IT WAL, Typical problems and
 actions to be taken are listed below.
    • If problems are due to lack of training, the MRI QAO and/or the MRI Project Manager will
       implement the necessary training.
    • If the problems are due to lack of sufficient resources, the MRI Project Manager will inform
       department management, who will then provide the required resources.
    • If the problems are due to inadequate planning, the plan will be modified,  approved  as
       required, and then distributed to those on the distribution list.

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                                                                  Section No.   10
                                                                  Revision No.  0
                                                                  Date: August 1G. 1995
                                                                  Page:.
                                   SECTION 10.0
                QUALITY CONTROL REPORTS TO MANAGEMENT
    The IT and MRI QAOs will be responsible for conducting systems audits early in the project;
The MRI QAO will be responsible for conducting data audits soon after the data become available
The IT and MRI QAOs will prepare written QA audit reports used to keep project and department
management informed.  Such written reports will include items appropriate to this project, such as:
    • Items/areas audited and the results of the audits
    • QAPP changes or deviations, QA/QC problems, and recommendations for corrective action
    • Summary of any training and any improvements noted
    • Data quality assessment and limitations, and the possible impact on data quality
    • Followup and assessment of the effectiveness of any corrective actions taken
    If major quality-related problems are detected during an audit, the IT and MRI QAOs will
immediately so inform the IT WAL and MRI Project Manager, then follow up,with a written report

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                                                                  Section No..
                                                                  Revision No..
                                                                  Date: October 4.199R
                                                                  Page:J_of_2_    ,
                                    SECTION 11.0

                                    REFERENCES

 1.    40 CFR Part 280 and 281, "Technical Standards and corrective Action Requirements for
      Owners and Operators of Underground Storage Tanks," 1988. These regulations stipulate
      that in order to be suitable for upgrading by cathodic protection, a tank must be assessed to
      ensure that it is structurally sound and free of corrosion holes.

2.    ASTM  Emergency Practice  Standard ES 40-94, "Emergency Standard Practice  for
      Alternative Procedures for the Assessment of Buried Steel Tanks Prior to the Addition of
      Cathodic Protection," 1995. This standard provides the  following requirements for tanks to
      be suitable for  cathodic protection:  no  pitting greater than 50%  of the  minimum
      recommended wall thickness; average metal wall thickness of each 1 m2 is greater than 85%
      of the original wall thickness.

3.    Section V, Article 9 of the ASME Boiler and Pressure Vessel Code (ASME SE-797). The
      code provides a visual examination procedure consisting of viewing the entire surface with
      the human eye at a light level of at least 161 lumen/m2 from a distance of no more than
      61 cm.

4.    ASTM Standard G1-90 (Re-approved 1994) "Standard Practice for Preparing, Cleaning, and
      Evaluating Corrosion Test Specimens."  This standard will be used as the reference for
      marking and preparing coupons for testing.       •

5.    ASTM Standard G 46-94, "Standard Guide for Examination and Evaluation of Pitting
      Corrosion," 1994. This standard will be used as the reference for testing coupons for the
      evidence of pitting corrosion. The guide is used for the corrosion examination tests.

6.    ASTM Standard E 114, "Practice for Ultrasonic Pulse-Echo Straight-Beam Examination by
      the Contract Method," 1990.

7.    ASTM Standard E 797, "Practice for Measuring Thickness by Manual Ultrasonic Pulse-Echo
      Contact Method," 1990.
      •>       '                           ...               ,  .                     '
8.    API Standard 1631, "Interior Lining of Underground Storage Tanks," 3rd Edition, April
      1992.

9.    National Leak Prevention Association NLPA 631, "Entry, Cleaning, Interior Inspection and
      Repair, and Lining of Underground Storage Tanks," Fourth Ed., 1991.

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                                                                  Section No.   11
                                                                  Revision No.  1
                                                                  Date: October 4.1995
                                                                  Pane:  2 of  2

10,   Underwriters Laboratories Standard UL 58, "Steel Underground Tanks for Flammable and
      Combustible Liquids," 1984.

11.   H.R. Inspection Service, Inc., Shawnee, KS, "Radiographic Testing Procedure NDE-RT."

12.   National Leak Prevention Association NLPA Standard 632, " Internal Inspection of Steel
      Tanks For Upgrading with Cathodic Protection Without Lining," First Ed., 1990.

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                                       Section No. App. A
                                       Revision Wo.  0
                                       Date: August 16.1995
                                       Page:  1  of 18
         APPENDIXA
Radiographic Testing Procedure

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                        NDE-RT  REV. 4
                        MARCH 10, 1993
H. R. INSPECTION SERVICE, INC.
        P. O. BOX 3280
     6878 MARTINDALE ROAD
    SHAWNEE, KANSAS, 66203
 RADIOGRAPHIC TESTING PROCEDURE

           NDE-RT  '
             THIS PROCEDURE HAS BEEN TESTED
             AND APPROVED FOR USE BY
                 WILLIAMSON
             ASNT TC1A LEVEL III

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                  NDE-RT RADIOGRAPHIC BESTING PROCEDURE

                  * -        .       "    ' l'


                           TABLE OF CONTENTS
R-110
R-120
R-130
R-220
R-230

R-250
R-260
R-270
R-280
R-290
R-294
Scope	.2
Safety Requirements	 2
Applicable Documents.......................... .2
General Documents	 3
Industrial Radiographic Films-, Screens, &
                      Radiographs  ............3
Radiographic Sharpness	 7
Image Quality Indicators	 8
Radiographic Technique	11
Procedure REquirements	 13
Evaluation of Radiographs	,13
Qualification of Radiographic Personnel......14

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              RADIOGRAPHIC TESTING PROCEDURE

                          NDE-RT
R-110   SCOPE

        RilO.l
The procedure covers thfe requirements for radio-
graphic examination of ASME codes including the
ASME Boiler and Pressure Vessel Code (Sections I,
V, and VIII) and ANSI/ASME B31.1 and B31.3.
R-120   SAFETY REQUIREMENTS

        R120.1  Each installation or area where x-ray or radio-
                active material is used shall have a radiation
                survey made during the initial operation and any
                other time when the conditions change, to assure
                adequate personnel protection.  In all instances,
                .each person using the radiation source shall wear
                a radiation film badge and a pocket dosimeter.
                Personnel radiation exposure shall not exceed the
                limits called for in Title 10, Code of Federal
                Register.

R-130   APPLICABLE

        Contract Specifications and Codes.

        R130.1  ASME Boiler and Pressure Vessel Codes - 1992 ed.

                1.  Section I     Power Boiler

                    Section VIII  Pressure Vessels

                    Section V     Nondestructive Examination
2

3
                    a.  Article 1
                    b:  Article 2
                    c.  SE94 & SE142
        R130.2  ANSI/ASME B31.1  Power Piping - 1992 ed.
                         **         '''','
        R130.3  ANSI/ASME B31.3 Chemical Plant and Petroleum
                                Refinery Piping - 1992 ed.

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 R-220

 R-221
GENERAL REQUIREMENTS.

Surface Preparation.

R- 2 21.1  Materials
                 Surfaces shall  satisfy the requirements of the
                 applicable materials  specifications, with add-
                 itional conditioning,  if necessary, by any
                 suitable process to a degree that surface
                 irregularities  cannot mask or be confused with
                 discontinuities.
        R-221.1  Welds
R-230

R-231
         When, required, the weld ripples or weld surface
         irregularities on both the inside (where
         accessible) and outside, may be removed by any
         suitable process to such a degree that the
         resulting radiographic image due to any
         irregularities cannot mask or be confused with
         the image of any discontinuity.

R-221.3  Surface Finish

         The finished surface of all butt-welded joints
         may be flush with the base materials or may have
         reasonably uniform crowns, with reinforcement
         not to exceed that specified in the referencing
         Code Section (Par PW-35 of Section I & Table
         127.4.2 of ANSI B31.1).

INDUSTRIAL RADIOGRAPHIC FILMS, SCREENS AND RADIOGRAPHS.

Film Selection.

Radiographs shall be made using film equal to or finer
grained than Type 2 of Recommended Practice SE-94,
R-232   Screens.
        Except when restricted by the referencing Code Section,
        intensifying screens may be used with the film types
        specified in R-231,

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R-233   Film Processing.

        R-233.1

          a.  Liquid x-ray developer, fixers, short stop and
              Photo-Flo .shall be prepared in accordance with
              manufacturer's recommendations.

          b.  Solutions shall be thoroughly stirred before
              processing.

          c.  Development time shall be standardized based
              on temperature and exposure technique must be
              adjusted for the developing time.

          d.  Film shall be agitated during developing at one
              minute intervals.

          e.  After development, the film shall  be transferred
              to the short stop for one minute.   The film
              should be agitated for the first 15 or 20 seconds
              in the short stop.

          f.  After the short top the film shall be transferred
              to the fixer and agitated for 10 seconds.  They are
              to remain in the fixer for ten minutes minimum or
              twice the film-clearing time.  Films shall not
              remain more than 15 minutes in fresh fixer.

          g.  The film must be washed for a minimum of 30 minu-
              tes to remove all residual fixer prior to drying.

          h.  The film shall be transferred to the Photo-Flo
              solution for 90 seconds before drying.

          i.  All films shall be free from processing or other
              defects which would interfere with proper inter-
              pretation of the radiograph.

        R-233.2  Quality of Radiographs.
                                    • 7 .
                 All radiographs shall be free from mechanical,
               .  chemical or other blemishes to  the extent that
                 they cannot mask or be confused with the image
                 of any discontinuity in the object being radio-
                 graphed.  Such blemishes include,  but are not
                 limited to:

                    a.  Fogging.
                    b.  Processing defects  such  as  streaks,
                        water marks, or chemical stains.
                    c.  Scratches, finger marks,  crimps,  dirt,
                        static marks,  smudges or tears.
                    d.  Loss of detail due  to poor  screen to
                        film contact.
                    e.  False indications due to defective
                        screens or internal faults.

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       , Radiographic Density.

   R-234.1  Density Limitations  of Radiographs.

            The  film density through the radiographic image of
            the  body of the appropriate penetrameter and the
            area of interest shall be 1.8 minimum for single film
            viewing for radiographs made with an x-ray source
            and  2.0 minimum for  radiographs made with a gamma-ray
            source.   For composite viewing of double film expos-
            ures the minimum density shall be 2.6.  Each radio-
            graph of a composite set shall have a minimum density
            of 1.3.   The maximum density shall be 4.0 for either
            single or composite  viewing.  A tolerance of 0.05 in
            density is allowed for variations between densito-
            meter readings.

   R-234.2  Monitoring Density Limitations of Radiographs.

            Densitometers shall  be used for assuring compliance
            with film density requirements and a national stand-
            ard  calibrated step  wedge film shall be used for
            checking densitometer calibration.  Step wedge comp-
            arison film may be used,  for direct comparison with
            production radiographs to show compliance with  »
            density requirements,  as  a permissable alternate
            to the use of a densitometer as required above.

R-^235   Scattered Radiation.
       .       '                    •               ! .
   R-235.1  Back Scatter Check.

            As a check on back-scattered radiation, a lead symbol
            "B",  with minimum dimensions of 1/2 inch in, height
            and  1/16  inch in thickness, shall be attached to the
            back of  each film holder.

   R-235.2  Excessive Scatter.

            If a light image of  the  "B" appears on the darker
            background of the radiograph, protection from back-
            scatter  if insufficient and the radiograph shall be
            considered unacceptable.  A dark image of the "B"
            on a lighter background is not cause for rejection.

R-236   System of Identification of Radiographs.

        A system of Radiograph identification shall be used to
        produce permanent identification on the radiograph trace-
        able to the contract, component, weld seam,  or part
        numbers,  as appropriate. , In addition, the manufacturer's
        symbol or name and the date of the radiograph shall be
        plainly and permanently  included on the radiograph.  This
        identification system does not necessarily require that
        the information appear as radiographic images.   In any
        case,  this information shall not obscure the area of
        interest.

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R-237   Location Markers.

        Location markers, which are to appear as radiographic
        images on the film, shall, be placed on the part, not on
        the cassette, and their locations shall be marked on the
        surface of the part being radiographed or on a map in a
        manner permitting the area of interest on a radiograph
        to be accurately located on the part for the required
        retention period of the radiograph and providing evid-
        ence on the radiograph that the required coverage of the
        region being examined has been obtained.  Location
        markers shall be placed as follows (see Fig. T-275):

   R-237.1  Single-Wall Viewing.

        R-237. 1.1   Source side markers.

                    Source side location markers shall be used
                    when radiographing the following:

                        Flat components or longitudinal joints
                        in cylindrical or conical components;

                        Curved or spherical components whose
                        concave side is toward the source and
                        when the source to material distance is
                        less than the inside radius of the
                        component;
                           " ,i , "       '    /   ' ,   '  • ' '   ' '  -        '
                        Curved or spherical components whose
                        convex side is toward the source.
            a.
            b.
            c .
R-237.1. 2   Film Side Markers.
            a.  Film side markers shall be used when
                radiographing curved or spherical
                components whose concave side is toward
                the source and when the source to mater-
                ial distance is greater than the inside
                radius.

            b.  As an alternate for source side markers
                in R-237. 1.1 (a), film side markers may
                be used when the radiograph shows cover-
                age beyond the location markers to the
                extent demonstrated by Fig. T-275 (e)
                and when this alternate is documented in
                accordance with R-293.
R-237 .1.3   Either Side Markers .
            Either source side or film side location
            markers may be used when radiographing curved
            or spherical components whose concave side
            is toward the source and the source to
            material distance equals the inside radius
            of the component.

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         R-237.2
            Double-Wall viewing.
R-250

R-251
            For double-wall viewing at least one location
            marker shall be placed on the outside surface
            adjacent to the weld  (or on the material in
            the area of interest) for each exposure.

R-237.3     Location Marking with a Map.
                                             /    '      •
            When inaccessibility or other limitations
            prevent the location of markers as stip-
            ulated in R-237.1 and R-237.2, a dimension-
            ed map of the geometric arrangement includ-
            ing marker locations shall accompany the
            radiographs and shall show that full coverage
            has been obtained.

SHARPNESS OF RADIOGRAPHIC IMAGE.

Geometrical Unsharpness Limitations.

When requjired by the referencing Code Section, geometric
unsharpness of the radiograph shall not exceed the
following:
            Material Thickness, inches
                Under 2 - -	. - .
                2 through 3 - - - - - .
                Over 3 through 4  - - -
                Greater than 4  -• - - -
                                     Ug Maximum, inches
                                    	0.020
                                    - - - -  0.030
                                    - - - -  0.040
                                    -•-•	0.070
            Note:  Material thickness is the thickness on which
                   the penetrameter is based.

R-252   Geometrical Unsharpness.

        Geometrical unsharpness equals source size times thick-
        ness over object to source distance.
 '• • - .      "      ''          -     ' .            FT
                                         Ug =	
        where:                                D

            Ug = geometrical unsharpness

            F  = source size, inches-the maximum effective dimen-
                 sion (diameter) of the radiation source (or
                 focal spot) in the plane of the distance D from
                 the weld, see table R-251.

            T  = thickness in inches of the weld or other object
                 being radiographed assuming the film is against
                 the weld or object; otherwise it is the thick-
                 ness of the weld or object plus the space
                 between the film and the weld or object.

            D  - distance in inches between the source and the
                 weld or other object being radiographed.
                               8

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                            TABLE R-251
Determination Factor
Length

       Dia. X Length

        1/32 X 1/32

        1/32 X 1/16

        1/16 X 1/16

        1/16 X 3/32

        1/16 X 1/8

        .10  X .10

        1/8  X 3/32

        1/8  X 1/8
.Isotope Source Projected


       F ='" inches

           0.044

           0.070

           0.088

           0.112

           0.140

           0.141

           0.156

           0.177
NOTE:  Refer to Recommended Practice SE-94, Section 10, for a
       method of determining geometric unsharpness.  Alter-
       natively, a nomograph as  shown in Recommended Practice
       SE-94 may be used.

R-253   Calibration of Source  Size.

        The equipment manufacturer's certification of the maximum
        effective dimension of the source shall be acceptable.

R-260   Image Quality Indicators (IQI).

R-261   IQI  (Penetrameter) Sensitivity.

        Radiography shall be performed with a  technique of suffi-
        cient sensitivity to show the penetrameter image and the
        specified hole,  which  are essential indications of the
        image quality of the radiograph.  The  radiographs shall
        also display the identifying numbers and  letters.

R-262   IQI Design and Selection.

        R-262.1  IQI Design.

            Penetrameters  shall  be manufactured and identified
             in accordance with the requirements or alternates
             allowed  in SE-142  and Appendices.  ASME standard
             penetrameters  shall  consist of  those  specified in
             Table R-233.1.

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R-263
R-262.2  IQI Selection.

    The essential hole size and designated penetrameter
    shall be as specified in Table R-276.
    A smaller hole or a thinner penetrameter than listed
    for each range may be used, provided all other
    requirements for radiography are met.

    R-262.2.1  Welds With Reinforcements.

         For welds with reinforcements the thickness on
         which the penetrameter is based is the nominal
         single wall thickness plus the maximum rein-
         forcement permitted by the referencing Code
         Section.  Backing rings or strips are not to be
         considered as part of the weld or reinforcement
         thickness in penetrameter selection,  i

    R-262,2.2  Welds Without Reinforcements.

         For welds without reinforcements the thickness
         on which the penetrameter is based is the
         nominal single wall thickness .  Backing rings
         or strips are not to be considered as part of
         the weld thickness.                           •.   '_

Use of Penetrameters to Monitor Radiographic Examination.

R-263.1  Placement of Penetrameters.

a. Source Side Penetrameter (s ).  The penetrameter (s) shall
   be placed on the source side of the part being examined,
   except in the condition described in R-263.1 (b) ...

b. Film Side Penetrameter (s ).  Where inaccessibility
   prevents hand placing the penetrameter (s) on the
   source side, it shall be placed on the film side in
   contact with the part being examined.  A lead letter
   "F" at least as high as the penetrameter      .
   identification number (s) shall be placed adjacent to
   or on the penetrameter (s) , but shall not mask the
   essential hole where hole penetrameters are used.

c. Penetrameter Location for Welds - Hole Type.  The
   penetrameter (s) may be placed adjacent to or on the
   weld.  The identification number (s) and the lead
   letter
                       when used, shall not be in the area of
           interest unless either part geometry makes it
           impractical to place the penetrameter outside the
           area of interest or the weld metal is not
           radiographically similar to the base metal.
                               10

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d. Penetrameter Location for Welds - Wire Type.  The
   penetrameter (s) shall be placed on the weld so that
   the length of the wires is perpendicular to the length
   of the weld.  The penetrameter(s) shall not be placed
   in the area of interest unless conditions exist as
   stated in R-2 6 3.1 (c).

R-263.2  Number of Penetrameters .

a. For components where one or more film holders are
   used for an exposure, at least one penetrameter
   image shall appear on each radiograph except as
   outlined in R-263.2 (b) through (f).

b. If the requirements of R-261 are met by using
   more than one penetrameter, one shall be in the
   lightest area of the radiograph and the other
   in the darkest; the intervening densities on
   the radiograph shall be considered as having
   acceptable density.  If the density of the
   radiograph anywhere through the area of interest
   varies by more than minus 15% or plus 30% from the
   density througth the body of the penetrameter,
   within the miniTTOTn/maxlT'""" allowable density ranges
   specified in R-234.1 then an additional penetrameter
   shall be used bor each exceptional area or areas
   and the radiograph retaken.  When calculating the
   allowable variation in density, the calculation
   may be rounded to the nearest 0.1.

   For cylindrical vessels or flat components where
   one or more exposure cassettes are used for an
   exposure, at least one penetrameter image shall
   appear on each radiograph except where the
   source is placed on the axis of the object and
   a complete circumference or portion of the
   circumference is radiographed with a single expo-
   sure, in which case, at least three penetrameters
   shall be spaced approximately 120 degrees apart.
   When the source is placed on the axis of the
   circumference and a portion of the circumference
    (four or more film location) is radiographed
   during a single exposure, at least three
   penetrameters shall be used.  One penetrameter
   shall be in the approximate center of the
   section exposed, and one at each end.  When the
   section exceeds 240 degrees, three penetrameters
   spaced 120 degrees apart may be used.  In each
   case, additional film locations may be
   required around the circumference to
   establish  120 degree penetrameter spacing,
   otherwise  at  least one penetrameter image shall
   appear on  each radiograph.  Where portions of
   longitudinal welds adjoining the circumferential
   weld are being examined simultaneously with the
   circumferential weld, additional penetrameters
   shall be placed on the longitudinal welds at
                        11

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           the ends of the sections most remote from the
           source of those welds being radiographed.  When
           an array of objects in a circle is radiographed,
           at least one penetrameter shall show on each
           object image.         ^

        d. For spherical vessels, where the source is
           located at the center of the vessel and one or
           more exposure cassettes are simultaneously
           exposed, at least three equally,spaced penetra-
           meters per 360 degree circumferential seam plus
           one additional penetrameter for each other seam
           shall be used.

        e. If the required penetrameter image and specified
           hole does not show on any film in a multiple
           film technique, but does show in composite view-
           ing, interpretation shall be permitted only by
           composite film viewing.

        R-263.3  Shims Under Penetrameters.

              a. A shim of material radiographically similar to
                 the weld metal shall be placed under the pene-
                 trameter if the weld reinforcement and/or back-
                 ing strip are not removed.

              b. The shim thickness shall be selected so the
                 total thickness being radiographed under the
                 penetrameter is at least the same as the nprm-
                 inal single wall thickness plus the maximum
                 reinforcement permitted by the referencing Code
                 Section (if reinforcement is not removed) plus
                 backing strip (if not removed) and other thick-
                 ness variations such as in nozzle geometries.

              c. When shims are used the plus 30% density
                 restriction of R-263.2 (b)  may be exceeded,
                 provided the required penetrameter sensitivity
                 is displayed and the density limitations of
                 R-234.2 are not exceeded.

              d. The shims dimensions shall exceed the penetra-
                 meter dimensions such that the outline of at
                 least three sides of the penetrameter image
                 shall be visible in the radiograph.

R-270   RADIOGRAPHIC TECHNIQUE.

R-271   Single Wall Technique.

        R-271.1  Radiography, regardless of the configuration
                 of the material, shall be done using a single-
                 wall radiographic technique whenever pract-
                 icable.  Penetrameter size and placement
                 shall be per R-262 and R-263,'as applicable.
                               12

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        R=271.2  For complete radiographic coverage of cylind-
                 rical girth welds, a minimum of four expos-
                 vires 90 degrees apart is required when the
                 source is placed outside and the film inside
                 the object.

R-272   Double-Wall Technique

        R-272.1  Double-Wall Viewing.

                 Unless otherwise specified, for materials and
                 for welds in pipe and tubes 3.5 inches (89 mm)
                 or less in nominal outside diameter, a technique
                 may be used in which the radiation passes
                 through two walls and the weld (material) in
                 both walls is viewed for acceptance on the same
                 film.  For welds, the radiation beam may be off-
                 set from the plane of the weld at an angle suff-
                 icient to separate the Images of the source side
                 and film side portions of the weld so there is
                 no overlap of the areas to be interpreted in
                 which case a minimum of two exposures taken at
                 90 degrees to each other shall be made for each
                 joint.  As an alternate, the weld may be radio-
                 graphed with the radiation beam positioned so
                 the images of both walls are superimposed, in
                 which case at least three exposures shall be
                 made at 60 degree to each other.  For double-
                 wall viewing a source side penetrameter shall be
                 used and placement shall be as indicated in
                 R-263.1.

        R-272.2  Single Wall Viewing.

                 a. For material and  for welds  in pipe and tubes
                    with a  nominal outside diameter  greater than
                    3.5 inches  (89 mm), radiographic examination
                    shall be performed for single-wall viewing
                    only. An adequate number of exposures shall
                    be taken to ensure complete coverage.

                 b. For welds in pipe or tubes  with  a nominal
                    outside diameter 3.5 inches (89  mm) or  less,
                    single-wall viewing may be  used  provided the
                    source  is offset from the plane  of the weld
                    certerline  as  outlined  in R-272.1.  As mini-
                    mum, three  exposures  120 degrees apart  shall
                    be required.   A film-side penetrameter  shall
                    be used and placement shall be as  indicated
                     in  R-263.1  (c)  and (d).

         R-273.3  Penetrameter Selection.

                 The  designated hole penetrameter with
                 essential hole or wire  diameter shall be
                 as specified in Table R-276.
                                13

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R-274   selection of Energy of Radiation.
        R-274.1
        R-274.2
X-Radiation.  Except as provided in R-274. 3,
the maximum voltage used in the examination
shall not exceed the value shown in Figures
T-272.1(a), (b), or(c), as applicable.
                  Except as provided in R-274. 3,
                        thickness for which
Gamma Radiation.
the recommended
radioactive isotopes may be used is as follows:

                         Minimum Thickness (in.)
                             IT 392    f?o 60
                             0.75      1.50
                             0.65      1.3
                             2.5       	
                 Steel
                 Copper or Nickel
                 Aluminum
                 The maximum thickness for the use of radioactive
                 isotopes is primarily dictated by exposure time;
                 therefore, upper limits are shown.  The minimum
                 recommended thickness limitation may be reduced
                 when the radiographic techniques used demonstrate
                 that the required radiographic sensitivity has
                 been obtained.
R-280   PROCEDURE REQUIREMENTS.                .

R-281   Procedure Compliance Without a Written Procedure.

        Compliance with the density and penetrameter image
        requirements on production radiographs shall be consid-
        ered evidence of qualification of the procedure used.

R-282   Requirements for a Written Radiographic Procedure.

        When required by the referencing Code Section, a written
        procedure shall contain, as minimum, the following tech-
        nique variables: '

            a.   material and thickness range
            b.   isotope used or maximum x— ray voltage
            c.   minimum source- to film distance
            d.   maximum source size
            e.   film brand or type
            f.   screens used.
R-290   EVALUATION OF RADIOGRAPHS.
             "             v-                 -  .    •   -

R-291   Facilities for Viewing Radiographs.

        Viewing facilities shall provide subdued background
        lighting of an intensity that will not cause troublesome
        reflections, shadows, or glare on the radiograph. Equip-
        ment used to view radiographs for interpretation shall
        provide a light source sufficient for the essential
        penetrameter hole to be visible for the specified density
        range .  The viewing conditions shall be such that light  .
                               14

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        from around the outer edge of the radiograph or coming
        through low-density portions of the radiograph does not
        interfere with interpretation.

R-292   Evaluation by Manufacturer.

        Prior to being presented to the inspector for acceptance,
        the radiographs shall be examined and interpreted, by
        qualified Level II radiograhic personnel as complying
        with the referencing Code Section and with radiographic
        procedure.  The qualified Level II or Level III radio-
        graphic personnel shall record, on a review form accomp-
        anying the radiograph, the interpretation of each radio-
        graph and disposition of the material examined.

R-293   Radiographic Setup Information.

        To aid in proper interpretation of radiographs, a sketch,
        drawing, written procedure, or equivalent record shall be
        prepared to show the setup used.  The information shall
        accompany each group of radiographs if the same informat-
        ion applies.  Reference to a standard setup is acceptable
        if descriptions of this standard setup are readily avail-
        able.  As a minimum, the information shall include:

            a.   Number of films.

            b.   The data specified in R-236 and R-237.3 when
                 applicable.

R-294   QUALIFICATION OF RADIOGRAPHIC PERSONNEL.

R-295   Requirements.

        Personnel shall be qualified in accordance with the
        requirements of SNT-TC-1A, 1984 Edition.

        a.  NDT LEVEL I - An NDT Level I individual shall be
            qualified to properly perform specific calibrations,
            specific tests and specific evaluations according to
            written instruction and to record the results.  He
            shall rece'ive the necessary guidance or supervision
            from a certified NDT Level II or III individual.

        b.  NDT LEVEL II - An NDT Level II  individual  shall be
            qualified to set up and calibrate equipment and to
            interpret and evaluate results  with respect to
            applicable codes, standards and specifications. He
            shall be thoroughly f amiliar with the scope and
            limitations of the method and shall exercise  assigned
            responsibility for on-the-job training and guidance
            of trainees and NDT Level I personnel.  He shall be
            able to prepare written  instruction, and to organize
            and report nondestructive testing investigations.
                                15

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c.
NOT LEVEL III - An NDT Level III individual shall be
capable of and responsible for establishing
•techniques, interpreting code, standards and specif-
ication, and designating the particular test method
and technique to be used.  He shall be responsible
for the complete NDT operation he is qualified for
and assigned to and shall be capable of evaluating
results in terms of existing codes, standards and
specifications.  He shall have sufficient practical
background in applicable material, fabrication, and/
or product technology to establish techniques and to
assist the design engineer in establishing acceptance
criteria where none are otherwise available.  It is
desirable that he have general familiarity with other
commonly used NDT methods.  He shall be responsible
for the training and examination of NDT Level I and
Level II personnel for certification.  The actual
administration of training and grading of examina-
tions may be delegated to a duly selected represent-
ative of the Level III individual and so recorded.
                       16

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         TABLE T-233.1
PENETRAMETER DESIGNATION .THICKNESS,
       AND HOLE DIAMETERS
Penetrameter
Designation
5
7
10
12
15
17
20
25
30
35
40
45
50
60
80
100
120
160
200
Penetrameter
Thickness
0.005
0.007
0.010
0.012
0.015
0.017
0.020
0.025
0.030
0.035
0.040
0.045
0.050
0.060
0.080
0.100
0.120
0.160
0.200
IT Hole
Diameter
0.010
0.010
0.010
0.012
0.015
0.017
0.020
0.025
0.030
0.035
0.040
0.045
0.050
0.060
0.080
0.100
0.120
0.160
0.200
2T Hole
Diameter
0.020
0.020
0.020
0.025
0.030
0.035
0.040
0.050
0.060
0.070
0.080
0.090
0.100
0.120
0.160
0.200
0.240
0.320
0.400
4T Hole
Diameter
0.040
0.040
0.040
0.050
0.060
0.070
0.080
0.100
0.120
0.140
0.160
0.180
0.200
0.240
0.320
0.400
0.480
0.640
                 17

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         APPENDIX B

Baseline Testing Procedures and
     Data Collection Forms
                                      Ssction No. App. 6
                                      Revision No.   1
                                      Date: October 4.1995
                                      Page:  1  of  12

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                           FIELD EQUIPMENT NEEDS

                               for Tank Inspections
1.    Clip Board
2.    Data Forms
3.    Pens
4.    Tape Measure (25 ft)
5.    Chalk Sticks
6.    Wax Marker
7.    Chalk Line
8.    Chalk Powder
9.    Twine or Strong String
10.   6-ft Step Ladder
11.   Extension  Cords
12.   Multiple Outlet  Adapter
13.   High Intensity Light (500 W)
14.   Jack Knife
15.   Hammer
16.   Center Punch
17.   Small Cold Chisel
18.   Work Gloves
19.   Camera
20.   Film
21.   Flash
22.   Screw Drivers
23.   Vise Grips
24.   DM4 DL Ultrasonic Thickness Gauge
25.   Couplant and Applicator
26.   Calibration Blocks
27.   Laptop Computer
28.   Hand Calculator
29.   Micrometer Depth Gauge
30.   Micrometer Wall Thickness Gauge
31.   Heavy Duty Drill Motor
32.   5/16 in Drill Bits (2)
33.   , 5/8 in Drill Bits (2)
34.   ' Safety Glasses with Side Shields
35.   Oil Can
36.   Extra Oil
37.   Hand Files
38.   Shop Vac (supplied by sandblaster?)
39.   Drinking Water
40.   Brush or Wisk Broom
41.   Wire Brush
42.   Hard Hats
43.   First Aid Kit

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                GENERAL INSTRUCTIONS FOR INSPECTING TANKS
 1.

 2.


 3.


 4.


 5.



 6.

 7.


 8.
9.

10.


11.


12.
 Complete the Initial Tank Data and History form.  .

 After the tank is removed from the ground, have a 4-ft by 4-ft or larger opening cut in
 one end for safe access.

 If possible, allow the outside of the tank to dry off, if wet,  and  sweep or scrape off
 excessive soil.

 Grid the inside and outside of the tank to allow for future location references. See
 special instructions for doing this.

 On at least four locations (two inside and two outside,  on opposite sides of the tank),
 mark off and label the  subsection lines  for future reference.   (See illustration for
 guidance.)

 Complete the Tank Welding Details form and the Tank  Views chart.

 Conduct internal and initial  external inspection of the tank, using the Tank Visual
 Inspection forms provided.

 Conduct the ultrasonic  inspection.  The  Krautkramer Branson DM4 DL ultrasonic
 thickness gauge or equivalent should be used after checking its calibration.  Preferably,
 it should be used with its data logger capability and the data then-transferred to a PC'
 Otherwise, use the Ultrasonic Inspection form.  (Note, this step may be conducted before
 or after steps 9 and 10.)

 Have the exterior of the tank  sandblasted.

 Conduct a second exterior inspection of the tank, using the Tank Visual Inspection forms
 provided.

 Take pit depth measurements of the deepest pits found, using the Starrett micrometer
 depth gauge and the Pit Depth forms provided.

 Drill sentry holes.  For 1/4 inch plate, first, drill a 5/16 in pilot hole, followed by a 5/8
 in sentry hole. Back off the larger nut on the anvil side of the thickness micrometer and
pull  anvil against spring tension until it  can be rotated 90°.  Then feed anvil through
 sentry hole, rotate the anvil back to its normal position, and using the ratchet stop on the
 spindle take a thickness measurement.  Rocking the micrometer slightly will enable you
to get the minimum reading.  Record reading on.the Wall Thickness forms provided

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                   INSTRUCTIONS FOR GRTODING THE TANK
1.
2.
3.
5.


6.
 8.
The tank is to be divided into 3 ft by 3 ft (or less)  segments with a grid work.  First,
measure the diameter and length of the tank.  In all of the following, the process may
be made easier if at some point the tank can be rolled 90° so you don't have to work on
the top of the tank.

The number of circumferential segments is equal to the diameter, in feet. Thus, an 8-ft
diameter tank should have 8 circumferential segments, a 10-ft diameter tank 10 segments,
etc.

The length of the tank should be divided into equal  increments, with each increment to
be  no more  than one meter.   Tanks  eight feet  in  diameter  should be divided
longitudinally as follows:
              6,000 gal
              8,000 gal
              10,000 gal
              12,000 gal
                           5 segments
                           7 segments
                           8 segments
                           10 segments
For the interior of the tank, determine the length of the arc needed for the grid.  For
example, if the diameter is 8 feet, the circumference is IIxD = 301.6 in. One eighth of
this is 37.7 in, or approximately 37.75 in. Then, at both ends of the tank mark off with
chalk or a wax marker the eight (approximately) equal segments. It is best to start from
the top of the tank, as the top is more easily identifiable than any other reference.

Using a carpenter's chalk line, snap longitutinal grid lines between the marks placed in
step 4.                                                                        .

Lay out the longitudinal segments.  For example, for a 6000 gal tank, which is 16 ft
long, use 16/5 ft,  or about 38.5 in!  Make a set of marks this distance apart for the
length of the tank at three or four locations around the circumference (eg., at 60, 180,
and 300 degrees from the top).  Then, using a piece of chalk or wax marker,  draw a set
of circumferential grid lines through the marks. (There will be 4 such  lines for a 16-ft
tank.)

The process on the outside of the tank is basically the same. It is recommended that the
initial marks at each end of the tank around the circumference  be augmented with a
center punch or chisel,  so  they can be readily relocated after sandblasting or rain.  A
carpenter's chalk line can be used for both the longitudinal and  circumferential grids,
unless the surface  is wet or extremely dirty. In that case, use a piece of regular string
as a guide and draw the lines with a wax marker.

For the circular ends of the tank, locate the center.  Mark  a vertical diameter and a
horizontal diameter, dividing the end into 4 parts.  Mark a circle 20.3 in hi diameter in
the center.  The center circle becomes one section, the other 4 sections are  defined by

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       the center circle and the vertical and horizontal marks. This gives approximately 9 ft2
       areas for an 8-ft diameter tank.  If it is necessary to divide the end into 1 ft2 areas, begin
       with the vertical diameter and mark a vertical line every ft in both directions.  Then
       begin with the horizontal diameter and mark a vertical line  every ft in both directions.
       The result  divides the end into  1 ft2 sections. A division into square feet for tanks of
       different diameters is shown in the figure.                                       ,

Note:  1 meter = 39.36 inches;  1 gallon = 231 cubic inches.

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            Top
          Opening
        H  _m_ A
        E ^~ 1 —  D


Example Subgrids:
    ._.

    .4_L5J_6.

     7  I.  8  I  9
       B2 Exterior
B2 Interior
                                         4

r
HI
TJ
0)
c
(1)
Q.
o
<&--
0)














I
V
if
/
/
/



















•tf *





A
--
B


C


D
Nomenclature: This is subsection B2-9.
2
"
5
R

1

4
7






1
9

6
3

1
8 , 7
1
5 | 4
2 | 1
I





7 , 8
I
_4_L5_
1 ] 2
I
9

6
3

G2 Exterior
  Note:  Interior and exterior notations are identical for same portion of tank.
         Also, notation does not change with rotation of tank.
G2 Interior
                                               95-24 SEV gltuz Km 1 062095

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                                   TOP
12FOOTDIA
10FOOTDIA
 8FOOTDJA
 6 FOOT DIA'.
      LEFT


OUAORANTUNE
SUBDIVISION LINE
QUADRANT LIKE
SUBDIVISION LINE

 RIGHT
                           BOTTOM FLOOfl OF TANK

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         INSTRUCTIONS FOR COMPLETING TANK VIEW INFORMATION
1.     Provide proper project tank identification number and location of site.

2,     Sketch the locations of all tank openings. Show bung locations on the top, and indicate
       their diameters (eg., 4 in or 2 in). Indicate the size and location of the manway.  Sketch
       the size, shape,  and location of the tank end wall opening.

3.     Show  locations of all tank welds except the head joints.   Include longitudinal and
       circumferential welds on the cylindrical portion and any welds on the heads.

4.     Sketch and label the grid system used on the two heads, with 4 or 5  sections per head.

5.     Show the approximate locations of any holes visible before exterior sandblasting.

6.     Indicate whether or not the tank had obviously been coated, locations where coating has
       deteriorated or is missing, and the general condition of the coating.

7.     Indicate the  approximate locations  of visually unusual sections of the tank prior  to
       exterior sandblasting, if any.  This would include areas of major damage, discolored
       areas,  areas symptomatic of product leakage,  etc.

8.     Provide additional comments on your initial impression of the tank. See example below.

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Tank No.
Date:

Tank Location:
Data entered by:
1.



2.



3.



4.



5.



6.



7.



8.



9.



10.



11.



12.



13.
                       INITIAL TANK DATA AND HISTORY
Site contact, name and phone
Tank capacity, diameter, and length



Tank manufacturer	 ''
Tank nominal wall thickness
Tank serial no. or other identification
Tank age, if known
Product stored in tank.
Was cathodic protection used (yes/no) ?




Was tank coated internally (yes/no)? 	




Was tank coated externally (yes/no)? _



Backfill material       	._	
Evidence of product leakage in backfill




Leak and repair history, if available	•-
14.    Other observations

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Tank No.
Date:

Tank Location:
Data entered by:
Internal/External
     TANK VISUAL INSPECTION FORM
    	           Sandblasted Q7N) ——
                       Page.
Grid ID
Hole Subgrid
Many Shallow Pits?
Comments	
 Percent Area Corroded	
	   V. Deep Pit Subgrid
	Pattern? —'.	
      Subgrid of Large Dent.
           Deep Pit Subgrid _
           General Corrosion?
Grid ID
 Percent Area Corroded
      Subgrid of Large Dent.
Hole Subgrid
Many Shallow Pits?
Comments	
       V. Deep Pit Subgrid
       Pattern? ______
            Deep Pit Subgrid _
            General Corrosion?
Grid ID
 Percent Area Corroded
      Subgrid of Large Dent,
Hole Subgrid
Many Shallow Pits?
Comments	
       V. Deep Pit Subgrid
       Pattern?		
            Deep Pit Subgrid _
            General Corrosion?
Grid ID
Hole Subgrid.
Many Shallow Pits?
Comments	
 Percent Area Corroded	
	   V. Deep Pit Subgrid
	Pattern?	
—   Subgrid of Large Dent
            Deep Pit Subgrid —
            General Corrosion?
Grid ID
 Percent Area Corroded
      Subgrid of Large Dent.
Hole Subgrid
Many Shallow Pits?
Comments —I	
       V. Deep Pit Subgrid
       Pattern?	
            Deep Pit Subgrid _
            General Corrosion?

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  Tank No.
  Date:
                                      Tank Location:
                                      Data entdred by:
                                   TANK WELDING DETAILS
1.      Comparing with°-i „ • racF
' jr*" ^ *a"*"~ * ™^™ "•
J- 9 1 f — ^*ij f i ^aaa^^ ~ i

.— j |-l/2'Mm.(l2.7mm)
N0.4-MAX. DIAM No. 5- ALL DIAM. No. 6-ALL OIAM.
— -J [— 5/32* <4 JO mm) Min. Stoorotion
F~°~1 ySCr t t 	 1 	 — • 	 __J '
L 	 . .. < 1 h-l/2" Min.
MJajmrnr
Na 7-MAX OIAM. 65- No 8.ALL D|AM.
(1.65 m)

B   — Overlap — 1/2 inch (12.7 mm) minimum.

C   — Continuous welds.

CF  — AH lap welds shall be continuous full fillet welds..

0   — Overlap —1/2 inch (12.7 mm) minimum for,
       diameters 48 Inches (1.2 m) or less; 3/4 inch (19.1
       mm) minimum for diameters over 48 inches (1.2 m).

E   — 1/2 inch (12.7 mm) minimum diameter lock weld,
       not over 12 Inches (305 mm) apart.

T   — Tack weld 1 Inch (25 mm) spots, not over 12 inches
       (305 mm) apart..

t   — Thickness of backup bar to be same as shell
       thickness. .
                                                                   HEAD JOINTS
                                                              ^T-^^i^^)
                                                                 N0.22 U          N0.23  u        N0.24  u
                                                            B   — Overlap —1/2 Inch (12.7 mm) minimum.

                                                            C   — Continuous welds.

                                                            CF  — Shan be continuous full fillet welds.

                                                            F   — Not less than five times head thickness — minimum
                                                                   1/2 inch (12.7 mm).

                                                            J   — Joint No. 21 — Minimum thickness of 0.167 inch
                                                                   (4.24 mm).

                                                            K   — Joint No. 22 — Heads require bracing, (see No. 1
                                                                   and 2 of Figure 6.2). Minimum thickness of 0.167
                                                                   (4.24 mm).

                                                             T   — Tack weld 1 inch (25 mm) spot*, not over 12 Inches
                                                                   (305 mm) apart.

                                                            t    — Minimum. 1 X shed thickness.

                                                                     Heads may be fiat, dished, or cone.  -
                                                                     Height of cone heads — not less than one-
                                                                     twettth diameter.

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1 Tank No.
Date:

Tank Location:
Data entered by: |
                     ULTRASONIC INSPECTION FORM
Subgrid
               Grid
               Thick.
                               Thick.
               Subgrid
               Thick.-
               Grid	
               Subgrid
               Thick.-
Thick.
               Subgrid
               Thick. _
Thick.
Thick.
Grid	
Subgrid
Thick.-
Subgrid.
Thick. _
               Thick.
Thick.
Grid	
Subgrid
Thick. _
Subgrid
Thick. _
Subgrid
Thick.-
               Subgrid
               Thick. _
Thick.
               Grid	
               Subgrid
               Grid	
               Subgrid
               Thick. _
Subgrid
Thick. _
               ThirV
Thick.
Subgrid
Thick. _
Subgrid
Thick. _
Subgrid
Thick. -
               Subgrid
               Thick. _
Thick.
Subgrid
Thick. _
Subgrid
Thick. _
Grid	
Subgrid
Thick.-
                                              Grid
                                              Thick.
                               Thick.
Grid,
               Thick.
                               Thick.
               Grid	
               Subgrid,
               Thick.-
               Grid	
               Subgrid
               Thick.-
Subgrid,
               Subgrid.
               Thick. _
Subgrid
Thick. _
Grid	
Subgrid.
Thick. _
Subgrid
Thick.
               Grid
Grid
Subgi
Thick.
                                              Thick
               Subgrid
               Thick.-

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                                          Section No.  ftpp.C
                                          Revjsion No.  0
                                          Date: August 16.1995
                                          Page: 1  of __
             APPENDIXC

*               .      •        •
Vendors' Standard Operating Procedures


 (To be inserted upon receipt from vendors)

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       SECTION 2
Results of Evaluation Forms

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                           Results of Evaluation Forms
                  Integrity Assessment Procedure for Steel USTs
, This form tells whether an integrity assessment procedure used .to assess steel USTs prior to
 upgrading with cathodic protection meets the performance standards recommended by the
 EPA.  The evaluation is of a vendor procedure for assessing tank integrity, and was conducted
 by a third party acting as a consultant to the vendor. The vendor procedure was evaluated
 according to the Quality Assurance Project Plan (QAPP), "Field Evaluation of UST Inspection
 Assessment Technologies" of October 1995 or equivalent protocol. The full  evaluation report
 includes a form summarizing the test data.

 The evaluation consisted of the vendor applying the procedure to a number of tanks or sites.
 After the vendor's conclusions were reported, the baseline results were determined by
 removing the tanks from the' ground and inspecting the tanks. The baseline inspection  .
 determined that a tank was not suitable for upgrading if the tank had any perforations or had
 any pits (either external or internal, depending on the assessment procedure) that were deeper
 than ,50% of the required minimum wall thickness for tanks of that size.

 Where the UST program implementing agency allows or requires evaluations for compliance,
 UST owners and operators of steel tanks that have been upgraded by the addition of cathodic
 protection should keep this form on file to prove compliance with the federal regulations.
 Tank owners should check with State and local agencies to make sure that this form satisfies
 their requirements.

 Vendor Procedure
 Procedure Name
 Version	;	'	
 Vendor Name	
 Vendor Address.
 Vendor Phone __
-E-mail
Fax
 Description of Procedure

 This vendor procedure assesses the integrity of a steel UST by (give a brief description below
 of the operating principles of the procedure):

-------
This procedure is operated in accordance with the following standard operating procedures or
national codes (List any applicable procedures and codes below):
Test Conditions During Evaluation
The evaluation used a total of.
ranged from	years to	
           	tanks at	different sites. The ages of the tanks
           . years with a mean average age of	years.
Groundwater was found above the bottom of the tank at the time of the evaluation at	
sites with	tanks. The evaluation data included	tanks with a minimum wall
thickness of 3/16 inch,.
nominal), and	
        .tanks with a minimum wall thickness of 0.24 inch (1/4
. tanks with a minimum wall thickness greater than 1/4 inch.
Evaluation Results
List the vendor's criteria for declaring a tank unsuitable for upgrading with cathodic
protection. Note that these are the criteria according to the vendor's standard operating
instructions, and not the EPA's evaluation criteria. (List below.)
In some cases, assessments done in the normal course of business are not completely
              . • i;;       i   a  ' 	        ,       '     ,.,'",     ,     •*•
conducted only by a single vendor company. Instead, part or all of the assessment procedure
is conducted by a licensee or other company or person.  The assessments within an evaluation
must not have more involvement of the original vendor that is seen in normal practice.

A licensee or other company or person besides the original vendor	was  	was not
involved in the assessments that were a part of this evaluation.  If licensee or other company
or person was involved, the nature and level of involvement was (describe below):
The evaluation resulted in data summarized in the table below. The data are reported in the
Reporting Form for Evaluation Data: Integrity Assessment Procedures for Steel USTs.  Note
that some assessment procedures report results on a per tank basis, while others report on a
per site basis.  See the instructions for an explanation of reporting on a per site basis. Indicate
by checking the appropriate box which reporting basis was used in this evaluation:

The evaluation data were reported on a   O per tank  D per site  basis.

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 BASELINE
                     VENDOR RESULT (without leak test knowledge)
SUITABLE
                                  UNSUITABLE
INCONCLUSIVE
TOTAL
 SUITABLE
 UNSUITABLE
 TOTAL
 BASELINE
                   VENDOR RESULT (after inclusion of leak test results)
SUITABLE
                                  UNSUITABLE
INCONCLUSIVE
TOTAL
 SUITABLE
 UNSUITABLE
 TOTAL
Note that the performance estimates are to be interpreted as applying on a per tank or per site
basis, depending on the way that the data were reported.  The results are based on the
calculations described in Section 5 of the QAPP "Field Evaluation of UST Inspection
Assessment Technologies."  Based on the data summarized above obtained during the
evaluation, the following performance estimates were found based on the vendor's results
after including the results of any leak tests:
       Correct Decision Rate
               _%.  (This is the number of tanks [or sites] declared
1.
suitable by both the vendor and baseline, plus the number declared unsuitable by both vendor
and baseline, divided by the total number of tanks [or sites] and converted to percent.)
       The 95% confidence interval was from _____ to	___%.
2.    Proportion of Correct Approvals (Accuracy)
                                     _%.. (This is the number of
tanks [sites] ^.declared suitable by both the vendor and baseline, divided by the number found
suitable by the baseline tests, converted to percent.)
       The 95% confidence interval was from   •    to	   %.     ,
3.    Proportion of Correct Detections (Reliability)
                                     _%.  (This is the number of
tanks [sites] declared unsuitable by both the vendor and baseline, divided by the number
found unsuitable by the baseline tests, converted to percent. EPA recommends that this
proportion be 95% or greater.)
      The 95% confidence interval was from	1 to	 •  %.

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4.     Proportion of False Alarms.
                                   _%. (This is the number of tanks [sites]
declared unsuitable by the vendor but found suitable by the baseline tests, divided by the total
number found suitable by the baseline tests, converted to percent.)
       The 95% confidence interval was from	to	%.
5.     Proportion of Missed Detections
                                      _%.  (This is the number of tanks [sites]
declared suitable by the vendor, but found unsuitable by the baseline tests, divided by the total
number found unsuitable by the baseline tests, converted to percent.)
       The 95% confidence interval was from	to	%. ,
6.
7.
8.
Proportion of Inconclusive Results of total results.
The 95% confidence interval was from	to _
Proportion of Inconclusive Results for Suitable Tanks.
The 95% confidence interval was from	to	
Proportion of Inconclusive Results for Unsuitable Tanks
The 95% confidence interval was from	to	_%.
In order to meet the performance requirements, the proportion of correct detections (the
proportion of unsuitable tanks correctly detected as other than suitable) must be at least 95%.
The proportion of correct detections is computed as 100% minus the percent reported in
number 5 above, and was	%. Based on the results from this evaluation the procedure
(mark  applicable box)

D     does meet the performance standards, or
CD     does not meet the performance standards.
Limitations on Results

The performance estimates above are only valid when:

•      The procedure is performed in accordance with the standard operating instructions
       used in this evaluation; and
•      The procedure has not been substantially changed.

Other limitations specified by the vendor or determined during the evaluation are (list below):

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Evaluator Certification of Results
Procedure Name
Version      ':
Vendor Name
I certify that the vendor conducted the assessment of the integrity of steel tanks prior to
upgrading with cathodic protection in accordance with the vendpr's standard operating
procedure,                                                                     >

I also certify that this vendor procedure was evaluated according to the plan in "Field
Evaluation of UST Inspection Assessment Technologies" and that the results presented above
are those obtained during the evaluation.       ,

I also certify that, outside this evaluation, I and my organization have no financial interests in
the vendor company, and that the vendor company has no financial interests in myself or my
organization.
 Name (person)
Organization performing evaluation
 Signature
Address of Organization
 Date
Phone

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Vendor Certification of Independence
              in     '     .    ••        ,    .         .'''„',.':''         
-------
                   Reporting Form for Evaluation Data
          Tank Integrity Assessment Procedures for Steel Tanks
              •  (Use as many pages as needed.) Page	of	.
(Indicate whether reported on tank or site basis by circling appropriate word in column 1 or 2)
Tank .
ID


















Site
ID







-










Tank
Age


















Baseline Results
Perforation
(Y/N)

















Deepest Pit
Depth
(Indicate
internal or
external)
















. .• •
Inspection
Conclusion
'_ >. ;• .;

. .



-










Vendor Conclusion
Without
Leak Test

















After Leak -
Test

















                                     7

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             SECTIONS
Instructions for Filling Out Results Forms

-------

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                        Instructions for Filling out Results Forms

       The evaluation is based on the procedures outlined in the "Quality Assurance Proj ect
 Plan: Field Evaluation of UST Inspection Assessment Technologies" (QAPP) of October 1995,
. or an equivalent protocol. The standard test procedure document supplements the QAPP and
 provides instructions for completing the results form for the evaluation of a tank integrity
 assessment method for steel USTs prior to upgrading with cathodic protection.

 Vendor Procedure
           '  -     h,.  ''•"."' v   .       ,         .              '        -       ._  f  -

     •  In this section, provide the name of the vendor procedure. This is usually a trademarked
 name. If there is a version of the system or a date, list that under the version. The vendor name
 is the name of the company that performs the assessment or supplies the specific procedure used
 by licensees or users.  The company's address and phone number should be supplied. An
 optional FAX number and/or e-mail address could also be supplied.

 Description of Procedure

       Give a brief description of the type of assessment here. Examples might be an internal
 video camera or a corrosion model.  If the procedure is performed or operated according to an
 industry standard code or standard operating procedure, give the appropriate reference(s) as the
 answer in the next section.                  *

 Test Conditions During Evaluation
 -'                                  '          v        -
       This section documents the conditions and data used in the evaluation.  Record the
 number of tanks investigated and the number of distinct sites. Typically all tanks in a single
 excavation would be a single site. However if there were two separate tank excavations
 separated by some distance, this could be two sites even if it was a single address or facility.
 Report the youngest and oldest age of tanks in the study.  Also report the average tank age. If
 there are tanks with unknown ages, use the best approximation of age in computing the average
 and the minimum and maximum. Report the number of tanks of different wall thicknesses. If
 the wall thickness is not known, use the minimum required by the Underwriters Laboratory
 Standard 58 based on the capacity of the tank.

       The QAPP was developed on a per tank basis and called for investigating about 100
 tanks. With an average of about 2.5 tanks per site, this would translate to about 40 sites. For
 procedures that report on a site basis, the evaluation should include at least 42 sites, with at least
 21 sites that were determined by the baseline tests to be unsuitable for upgrading.  Note that this
 will probably involve more than 21 tanks at these sites. No minimum requirement is specified
 for the number of suitable sites. Procedures that report on a per tank basis should include at least
 42 .tanks,- with a minimum of 21 unsuitable tanks as determined by baseline tests.           .

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Evaluation Results

       Describe briefly how the vendor determines that a tank is unsuitable for upgrading. For
example, the vendor's decision might be based on a visual review of the internal video of the
tank, or it might be based on the predicted life of the tank compared to its age based on a
corrosion model,

       Indicate whemer the vendor procedure makes a determination separately for each tank, or
whether one decision is made that applies to the site (with possibly multiple tanks). If the vendor
reports results on a per site basis, the site as a whole is judged suitable for upgrading by the
addition of cathqdic protection or the site as a whole is judged unsuitable. If the vendor reports
on a site basis, the baseline results must also be reported on a site basis rather than on a per tank
basis. For this purpose the baseline testing results are interpreted to mean that a site is not
suitable for upgrading by the addition of cathodic protection if any of the tanks at the site is not
suitable.  For a site to be judged suitable for upgrading, all tanks at the site must be suitable for
upgrading with cathodic protection.

       The QAPP calls for the vendor to report findings first in the absence of information about
whether the tank has passed a leak detection test, and then again using the results of a leak
detection test. Correspondingly, the results form has a table for the vendor's conclusions in the
absence of knowledge about the leak detection test and a subsequent table for results including
that knowledge. The data to be entered in the table are described in detail with examples in
Section 5, page 5 of 7, of the QAPP.

       Compute the percentages for items 1 though 8 as described in the QAPP, Section 5, pages
5 and 6 of 7, and report them in the indicated blanks.  Note that these items are based on the
vendor's results including knowledge of any leak detection test results.

       The performance requirements are based on the probability^ of correct detection. The
probability of a correct detection is computed as 100% minus the percent reported in item 5. For
example, if item 5 were computed as 2% (based on incorrectly declaring 1 unsuitable tank out of
50 unsuitable tanks as suitable), then the probability of correct detection would be 98%.

       Mark the "does" box if the estimated probability  of detection is at least 95%. Otherwise,
mark the "does not" box.
Limitations on Results

       List any and all restrictions or special requirements of the procedure here. For example,
if there are any special cleaning requirements for the tanks hi preparation to performing the
assessment, these should be described here.  Similarly, if the evaluation only reflected certain
situations, and not the full range of variables that might be encountered in the field, then these
should also be described as limitations.

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Certification of Results

       Repeat the procedure name, version and vendor's name as indicated. Give the name of
the person in charge of the evaluation in the first position, followed by the name of the evaluating
organization. On the second line, the person in charge of the evaluation should sign the form.
This is followed by the address of the evaluating organization. On the next line, enter the date
followed by the evaluating organization's telephone number.

Vendor Certification of Independence

       The vendor's representative should complete and sign.

Reporting Form for Evaluation Data

       The QAPP contains detailed data reporting forms for the baseline inspections of the
tanks.  The indicated data should be summarized for each tank on this .reporting form. This
includes the identification of the tank and site, whether or not each tank had a perforation, and
the depth of the deepest pit found during the inspection, leading to the  inspection conclusion as
to whether the tank was suitable or not. Note that a specific procedure is required to assess only
one side of the tank shell, but must identify all perforations. The baseline conclusion should be
based on the deepest pit found on the same side of the tank  shell (interior or exterior) that is
assessed by the vendor's procedure.  The vendor's conclusions both without knowledge of the
leak test results and with that knowledge are also reported.  These data form the basis for the
tables in the reporting form.                ,                   .
                                           3

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                     SECTION4

  "Guidance on Alternative Integrity Assessment Methods
for Steel USTs Prior to Upgrading with Cathodic Protection'
                 EPA Memorandum            :

                    July 25,1997

-------

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\
                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                     Mail Code 5401G

                                      JUL  25 I997                •-.""•
                                                                          OFFICE OF
                                                                   SOLID WASTE AND EMERGENCY
                                                                          RESPONSE
 MEMORANDUM
SUBJECT:
FROM:
TO: ,.
               Guidance On Alternative Integrity Assessment Methods,For Steel USTs Prior To
               Upgrading With Cathodic Protection
                     :  TxZLAtt-^
                     lopkins Virbick, Director
               Office of Underground Storage Tanks

               EPA UST/LUST Regional Program Managers
               State UST Program Managers
      , This memorandum provides guidance that pertains only to a relatively smallsubset of all
underground storagfe tanks (USTs). This subset>,of USTs consists of steel USTs that are not yet
protected from corrosion, that will not be internally lined to meet the 1998 deadline for corrosion
protection, and that will-be" assessed by alternative methods other than either human-entry
internal inspection or leak detection before cathodic protection is added.
       In our memorandum of October 21, 1996, we recommended to UST program
implementing agencies that they continue to follow their current policies regarding allowed
integrity assessment methods for this subset of tanks until more information and guidance  .
became available.  On March 6, 1997, we circulated additional mformation and draft guidance.
Today's memorandum finalizes our guidance on this subject. The guidance promotes protective
and affordable integrity assessments while maintaining regulatory flexibility for implementing
agencies.

Guidance On The Use Of Alternative Integrity Assessment Methods
       Federal UST regulations require that existing steel tanks without corrosion protection
must be assessed for structural integrity before cathodic protection can be Idded to meet
corrosion protection requirements.  Basically, tanks that are not structurally sound must not have
their operational lives extended. Specifically, the federal UST regulations at 40 CFR
§ 280.21(b)(2) state that an assessment method may be used to ensure the integrity of steel tanks
prior to upgrading with cathodic protection if the assessment method is listed in the regulations
or if the implementing agency determines that an alternative assessment method prevents
releases in a manner that is no less protective of human,health and the environment than those
listed.  Today's guidance pertains to determinations of alternative integrity assessment methods
that are not listed in the federal regulations.

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       EPA recommends that implementing agencies determine that an alternative
integrity assessment method that meets either Option A or Option B below be considered to
prevent releases in a manner that is no less protective of human health and the
environment than the methods listed in 40 CFR § 280.21(b)(2)(i) through (Hi), which
include human-entry internal inspection and, for tanks less than 10 years old, certain leak
detection methods.

Option A.  Ensure tank integrity by using an alternative integrity assessment method that is
       in accordance with a standard code of practice developed by a nationally recognized
       association or independent testing laboratory.

Option B.  Ensure tank integrity by using a vendor-supplied procedure that has been
       successfully evaluated and certified Jby a qualified independent third party to meet
       specified performance criteria regarding detection of perforations and detection of
       either internal or external damage. Within Option B, the criteria for proving tank
       integrity are as follows:
             1. Detect all perforations; and
             2. One of the following:
                   a)   Detect external pits deeper than 0.5 times the required minimum
                        wall thickness, OR
                   b)   Detect internal pits deeper than 0.5 times the required minimum
                        wall thickness AND any internal cracks or separations.
       To meet a criterion, a method must demonstrate a probability of detection of at least
       95 percent and a probability of false alarm of no more than 5 percent.

       After March 22,1998,  EPA recommends that implementing agencies approve the
use only of alternative integrity assessment methods meeting either Option A or Option B.
Before March 22,1998, agencies should maintain their current policies for alternative
integrity assessment methods that do not meet either Option A or Option B.  Also, before
March 22,1998, agencies should allow upgraded tanks that have used alternative integrity
assessment methods meeting either Option A or Option B to select a leak detection method
from those available after March 22,1998 (as discussed below  in today's guidance).

       This guidance is not intended to discourage the use of human-entry internal inspection as
an assessment method or tank lining as an acceptable upgrade option. EPA's UST regulations
allow for interior tank lining to be used as an upgrade option for tanks lacking corrosion
protection (40 CFR § 280.21(b)(l)). This guidance addresses only § 280.2l(b)(2)(iv), which
regards methods not specifically listed in the federal regulations.

The Difference Between "Method" And "Vendor-Supplied Procedure"
       Option A addresses "integrity assessment methods" and Option B addresses "vendor-
supplied procedures." Both "methods" and "procedures" share the common essential task of

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verifying the integrity of the tank, but they differ in the guidance as follows. A "method" is a
                 ji>         "                 •                                          •,
general technology (such as the use of robotic devices of diagnostic modeling) that is in
accordance with a standard code of practice.  A "vendor-supplied procedure" is an application of
a technology, usually marketed as a patented brand name and procedure. Under Option B, a
"vendor-supplied procedure" must be successfully evaluated and certified by a third party.    .
However, the guidance does not recommend the certifying of'each individual contractor who
may be the local provider of a "vendor-supplied procedure."          .

Option A: Standard Codes Of Practice
       Option A recommends that each alternative integrity assessment methocl comply with a
standard code of practice developed by a nationally recognized association or independent testing
laboratory. Compliance with a standard code is a requirement in almost all other areas of the
federal UST technical regulations. Codes of practice are often updated over time, and so the
code used must be the code applicable at the time that the alternative assessment is conducted.
       The American Society for Testing and Materials (ASTM) has been the most active code
body for alternative integrity assessments.  A standard is being drafted by a joint task group
under Subcommittees E50.01 on Storage Tanks and GO 1.10 on Corrosion in Soils. The first
draft of the "Standard Guide for Three Methods of Assessing Buried Steel Tanks" was recently
balloted, and is very similar to the expired ASTM ES 40, "Emergency Standard Practice for
Alternative Procedures for the Assessment of Buried Steel Tanks Prior to the Addition of
Cathodic Protection." Since balloting is within G01.10 only, interested parties should contact
ASTM's Robert Held at (619) 832-9719 for information about participating in this standard
development activity.                                   •
       Although ASTM committees have been the most active, other nationally recognized
associations and independent testing laboratories are not precluded from developing standard
codes of practice.     ,   •

Option B: Evaluation And Certification Process
       Option B recommends that each vendor-supplied procedure intended to ensure tank
integrity must receive third-party evaluation and certification that it meets criteria for
establishing the integrity of a tank. Implementing agencies  should allow the use only of those
vendor-supplied procedures successfully evaluated and certified by a qualified independent third
party to meet specified performance criteria regarding detection of perforations and detection of
either internal or external damage.                -
       In an evaluation and certification process, a vendor first contracts with a third party for
evaluation. This third party should be a qualified test laboratory, university, or not-for-profit
research organization with no financial or organizational conflict of interest. Based on the nature
of the performance criteria, evaluations will likely be qualitative, but quantitative evaluations
also are acceptable. The evaluation is performed first without and then with information about
the leak status of the tank divulged to the vendor. The method's performance characteristics,,
both with leak data and without, are determined, summarized on a "short form," and certified by
the evaluator. Owners and regulators can then use this documentation, along with other
information, to make decisions mat are right for their particular situations.   ~

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       We have determined that an independent evaluation and certification process is already
available for use in the UST community. This finding is based on discussions with vendors and
third-party evaluators and industry's experience with other UST system technologies.
       In an evaluation, the determination of whether or not a vendor-supplied procedure meets
the criteria may be based in part on leak detection data. This is allowed because protectiveness is
based on the performance of the complete vendor-supplied procedure, and leak detection results
often play a large role in integrity assessments.  However, the performance of a vendor-supplied
procedure without inclusion of leak detection data should still be reported on the short forms for
informational purposes.
       As is clear from the recommendations, no  integrity assessment methods or vendor-
supplied procedures that have been in use before March 22, 1998 should be "grandfathered" or
considered exempt from following  a standard code or from evaluation after March 22, 1998.
However, those vendor-supplied procedures that were part of the 1996 field study conducted by
EPA's Edison lab can use applicable data generated in that study as part of a more
comprehensive evaluation. In addition, even if a company follows a standard code of practice, it
may voluntarily put its vendor-supplied procedure through this evaluation process in order to
obtain independent third-party documentation of performance characteristics.

Evaluation Protocols For Option B
       More detailed information on evaluation can be found in the "Quality Assurance Project
Plan" (QAPP) prepared for EPA's engineering study conducted in  1995 and 1996. We consider
the original QAPP written for the EPA field study to be a viable, peer-reviewed evaluation test
protocol. We recommend that evaluations conducted in accordance with it be considered valid.
However, removal and examination as detailed in the QAPP may not be necessary, at least not
for all tanks used in an evaluation.  An approach that uses data in lieu of physical testing can be
used if all relevant data requirements are factored in. An evaluator may choose alternative
evaluation protocols or procedures, because of the potentially high cost of following the QAPP to
the letter or because of special characteristics of the vendor-supplied procedure under evaluation.
(The QAPP calls for an assessment method to be used on approximately 100 tanks, which are
then removed from the ground for testing and inspection.)  The development of other protocols is
not precluded, but rather is encouraged.
       We have investigated the EPA/private sector Environmental Technology Verification
program, and found that it probably cannot provide assistance in the needed time frame.  EPA
will Hot be involved in the writing of additional protocols or in the funding of evaluations.
However, EPA staff will be available to comment on draft protocols and to provide guidance to
implementing agencies. In addition, we will provide optional summary forms, or "short forms,"
for the QAPP, as suggested by commenters. These will help industry give implementing
agencies and owners relevant information in a consistent and understandable format.

Evaluation Criteria In Option B
       The criteria in Option B above are based on those found in the QAPP. On each criterion,
methods must demonstrate a probability of detection of at least 95% and a probability of false
alarm of no more than 5%. Note that 100% accuracy is not specified. We have found it

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 protective and cost-effective to rely on a series of multiple, complementary, and high-quality
 measures to achieve the greatest protection at a reasonable cost.
        In addition to a mandatory criterion on perforations, a method must pass evaluation of a
 criterion for either external or internal damage. We structured the criteria in this way based
 partly on consistency with internal (human-entry) inspection standard codes. In addition, these
 criteria are based on our belief that not allowing the upgrading of tanks with either significant
 interior or exterior damage (unless they are repaired) yields significant benefits over the costs
 incurred.  We do not believe, however, that the additional cost of assessing a tank for both
 internal and external damage provides a net benefit in significantly greater protection.

       A criterion for loss of wall thickness over a wide area of the tank is not included, because
 our research found that failures due to uniform corrosion are very rare.  Likewise, a criterion for
 tank deformation is not included, because it is generally found to be an issue only in fiberglass
 tank installations.
                                                                   c

 Recommended  Commencement Date
       Setting the recommended commencement date of March 22, 1998 allows time for
 standards to be developed and evaluations to be conducted, and comes before a significant
 portion.of the anticipated assessment work. We extended the date proposed in our draft guidance
 in response to comments requesting more time. Note: the December 22,1998 deadline for all
 existing UST systems to meet spill, overfill, and corrosion protection requirements will not be
 extended.

 Monthly Leak Detection Not Required
       We earlier proposed to include stand-alone monthly leak detection monitoring in
 combination with the integrity assessment options.  However, this monitoring is no longer part of
 our recommendation for integrity assessment methods fulfilling Option A or vendor-supplied
 procedures fulfilling Option B. We deleted monthly monitoring based on technical merit,
 consistency, and simplicity. We believe that if an integrity assessment method complies with
 either a standard code of practice or evaluation procedures as described above, then leak
 detection monitoring beyond that required in the federal regulations is not warranted on a
 nationwide basis, and we have not found performance data that indicates otherwise.  In addition,
 deleting the additional monitoring brings all assessment methods in line with each other and
 simplifies the compliance picture.                                         "••'.-••
       If the implementing agency follows today's guidance, compliant USTs (correctly
upgraded through alternative assessment, cathodic protection, protected piping, and spill/overfill
protection) could follow the requirements of §  280.41(a)(l) allowing either stand-alone monthly
monitoring or, for up to ten years, the combination of inventory control and tightness testing
every five years.  Note that the period during which this combination leak detection method is
valid may be less than 10 years if the tank itself meets the 1998 standards for corrosion
protection before other UST system components meet 1998 standards for spill, overfill, and
corrosion protection, as clarified in our memorandum of July 25, 1997, "Applicability Of A
Combination Leak Detection Method For Upgraded Underground Storage Tanks."

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Recommendation Against Leak Detection As An Integrity Assessment
       The question of whether leak detection alone should be used to assess older tanks prior to
upgrading with cathodic protection has been raised from time to time. We received numerous
comments on this subject, nearly all in agreement that leak detection alone is not sufficient.
Although we recognize the important role leak detection generally plays and allow the use of
leak detection results in evaluations of integrity assessment methods, EPA does not recommend
that leak detection alone be'considered sufficient to assess the integrity of USTs 10 years old or
older.

State Program Approval
       A decision either to adopt or not adopt EPA's recommendations regarding integrity
assessment  would not affect the status of state program approval or of an application for
approval. This is because EPA is providing recommendations only and not amending its
regulatory criteria for state program approval.                          \

Federal And State Consistency                     ,
       We  hope mis guidance is accepted by implementing agencies because there are benefits
to having consistency across jurisdictions.  However, EPA recognizes that State and local
requirements may differ from Federal requirements. We have included in Attachment 1
additional items that implementing agencies may consider in developing their integrity
assessment  policies.

Guidance Intended To Ensure Quality Of Integrity Assessments
       EPA believes today' s guidance will benefit the UST community and protect human
health and the environment by ensuring quality alternative integrity assessments that can lead to
extended operational life of older steel tanks. Option A can ensure that alternative integrity
assessment  methods are valid by being in accordance with national codes of practice.  Option B
can ensure that vendor-supplied procedures have met rigorous third-party evaluation and
certification. However, for these Options to be most successful, UST owners will need to be
informed to use only methods that meet code or vendor-supplied procedures that have been
certified. Implementing agencies should make concerted attempts to inform their UST owners
about what  they need to look for to make sure they get a reliable integrity assessment.

Acknowledgments
       Our March 6 draft guidance package sought input on  the general approach, specific
evaluation criteria, costs of evaluations, compliance and enforcement implications, and timing.  I
thank the state and EPA representatives who provided comments to our draft, including those
from Arizona, District of Columbia, Michigan, Tennessee, and EPA's Office of General
Counsel. I  also thank the many other individuals and organizations that provided comments.

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Disclaimer
       EPA's Office of General Counsel advises that the policies set out in this document are not
final agency action, but are intended solely as guidance. They are not intended, nor can they be
relied upon, to create any right, benefit or trust responsibility, enforceable by any party, in
litigation with the United States.
cc:
^ EPA UST/LUST Regional Program Managers' Supervisors
 OUST Program Directions Team
 OUST Desk Officers                         .
 Betty Arnold, OUST Compendium
 Carolyn Esposito, EPA NRMRL, Edison, NJ
 Dariiel Sullivan, NRMRL, Edison, NJ
 Kathy Nam, EPA OGC                             •
 Joan Olmstead, EPA OECA
 Larry Magni, American Petroleum Institute
 Dennis Rounds, Chair, ASTM Subcommittee E50.01
 Susan Canning, ASTM Staff Liaison, Committee E50
 Richard Huriaux, DOT Office of Pipeline Safety
 Shelley Leavitt Nadel, NACE International
 Marc Katz, National Association of Convenience Stores
 Chappell Pierce, OSHA Directorate of Safety Standards Programs
 Bob Renkes, Petroleum Equipment Institute    -  •  •
 John Huber, Petroleum Marketers Association of America
 Mark Morgan, Petroleum Transportation & Storage Association
 Roy Littlefield, Service Station Dealers of America
Tom Osborne, Society of Independent Gasoline Marketers of America
John Worlund, Converse Environmental Consultants Southwest
James Bushman, Bushman and Associates
Michael Baach, Corrpro Companies
George Kitchen, International Lubrication and Fuel Consultants
Derick Sharp, National Leak Prevention Association
John Piazza, Southern Cathodic Protection
Bud Mattox, Tanknology-NDE
Warren Rogers, WRA Environmental

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                                   ATTACHMENT!
                                  ......

                  ADDITIONAL ITEMS FOR CONSIDERATION IN
                DEVELOPING INTEGRITY ASSESSMENT POLICIES

Agencies that implement underground storage tank programs may find the following items
useful in conjunction with EPA's guidance in constructing their integrity assessment policies:
*   Requiring certain documentation be submitted by vendors to UST owners or implementing
    agencies (or both).  An example for human-entry assessments following NLPA 631 is Form
    CF-2, "Internal Inspection Affidavit," which must be maintained by the owner, according to
    the standard. An example for an alternative assessment would be a certification by the
 .   vendor that the work meets code or a short form summarizing the evaluation and limitations
    of a particular method.
*   Requiring that companies, individuals, or both be licensed in order to perform assessments.
*   Requiring monthly stand-alone leak detection monitoring following assessment and upgrade.
*   Limiting the time between assessment and upgrade (for example, limit the time to six
 •   months),'                                  •           ,
*   Putting mechanisms in place to make the vendor responsible for a tank failure due to
    improper assessment.                              ,                  .
*   Reviewing each vendor-supplied procedure before allowing it to be used, even if a vendor
    claims the procedure complies with a standard code of practice, to ensure the procedure
    meets all requirements of the code and of the agency.
G:\Share\OUST\TechIsue\ImegAss\I_A_Gui 11 .wpd

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