UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460
                                                       OFFICE Of
                                              SOL.O WASTE ANO
MEMORANDUM
SUBJECT:  Hazardous Waste Tank Systems Inspection Manual
              s^     y •   *~
              <1 _  /'-4
           . Winston por
FROM:
             J. Winston porter
             Assistant Administrator
        TO:  Regional Waste Management Division  Directors
             Environmental Services Division  Directors
             Regions I-X

     Attached ia a copy of the Hazardous Waste Tank  Systems
Inspection Manual developed by the RCRA Enforcement  Division  of
OWPE.  The manual was written as guidance to  RCRA  inspectors  far
inspections of hazardous waste treatment and  storage tank  systems
pursuant to 51 PR 2S422/ July 14, 1986.  Support for the
development of the manual was provided by RCRA personnel  from the
Regions/ States, and Headquarters.  Additionally,  the manual  was
reviewed by the Office of Solid Waste, the Office  of Enforcement
and Compliance Monitoring, and the Office of  General Counsel.
         manual provides an explanation of the  applicability  of
the tan* system regulations in addition to:

  o  a complete regulatory overview; and

  o  detailed inspection procedures and inspection
     checklist*

     Thi* annual complements the March 1988  RCRA  Inspection
Manual (QSNER 9338.2A) and expands on the  inspection  procedures
contained therein.

     If you have any questions concerning  the manual,  please
contact Tim Kaaten or Ken Gigliello, RCRA  Enforcement  Division,
F'i'S 475-9320.        .

Attachment

cc:  Regional Counsels
     Hazardous Waste Branch Chiefs
     RCRA Enforcement Section chiefs
     Regions Jb-X

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Hazardous Waste Tank Systems
       Inspection Manual
      RCRA Enforcement Division

  Office of Waste Programs Enforcement
          September 1988

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                                                     OSWER 9938.4


                        TABLE OF CONTENTS



1.0  INTRODUCTION		  1-1

     1.1  Background	  1-1
     1.2  structure and Use	  1-2
     l. 3  Relationship to Other Guidance Manuals	  1-3

2.0  OVERVIEW OF HAZARDOUS WASTE TANK SYSTEMS REGULATIONS..  2-1

     2.1  The Regulatory Approach/Framework	  2-1
     2.2  Applicability of the Regulations	  2-1

          2.2.1  Existing Tanks	  2-2
          2.2.2  New Tank Systems	  2-3
          2.2.3  Less Than 90-day Accumulation Tank	  2-4
          2.2.4  Small Quantity Generators	  2-5
          2.2.5  Exemptions	;.	  2-6

     2.3  Variances	  2-6
     2.4  Summary of Regulation	  2-7

          2.4.1  Primary containment/Tank Integrity Asses..  2-8
          2.4.2  Tank Installation	  2-8
          2.4.3  Secondary Containment and Detection	  2-8

               2.4.3.1  Liners	  2-9
               2.4.3.2  Vault Systems	  2-10
               2.4.3.3  Double-walled Tanks	  2-10
               2.4.3.4  Ancillary Equipment	  2-11

          2.4.4  Inspections/Operations and Maintenance....  2-11
          2.4.5  Response to Leaks/Spills	  2-12
          2.4.6  Closure and Post-Closure Care...	  2-14
          2.4.7  Small Quantity Generators	  2-15
          2.4.8  Special Wastes	,		  2-16

3.0  Enforcement Approach	  3-1

4.0  Preparing for the Inspection	  4-1

5.0  On-Site Inspection Procedures	  5-1

     5.1  Small Quantity Generators	  5-1
     5.2  Recordkeeping and Inspection Logs	  5-4

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                                                     OSWER 9938.4
                  TABLE. OF CONTENTS (continued)
          5.2.1  New and Existing Tank Systems	    5-4
          5.2.2  Existing Tank Systems	    5-7
          5.2.3  New Tank Systems	    5-11
          5.2.4  Special Wastes	    5-15
          5.2.5  Release Response.	    5-16

     5. 3  Tank System Inspection	    5-17

          5.3.1  Visual Inspection of Tank System	    5-17
          5.3.2  inspection of Closed Tank Systems	    5-22


6.0  Post-Inspection Review	    6-1
Figures

3    Deadlines for Secondary Containment	   3-2

4A   Applicability of the July 14, 1986 Hazardous Waste Tank
     Regulations	   4-2

4B   How to Use Checklists in Appendix A	   4-3
Appendices

     Appendix A - Inspection Checklists

     Appendix B - Technical Appendix

     Appendix C - Glossary

     Appendix D - References
                                ii

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                                                     OSWER 9938.4


1.0  INTRODUCTION

1.1  Background

     On July 14, 1986, EPA published the final rule governing
hazardous waste storage and treatment tank systems.  The rule
went into effect on January 12, 1987.  These regulations
establish standards applicable to both new and existing tank
systems, and include requirements for onground, inground,
aboveground, and underground tank systems.  These standards are
applicable to permitted, interim status, and accumulation tank
systems.  An interim status requirement for small quantity
generators is also part of this rule.

     Section 3004(w) of the Hazardous and Solid Waste Amendments
of 1984 (HSWA) required EPA to promulgate final permitting
standards for hazardous waste underground storage tanks that
cannot be entered for inspection.  Section 3001(d) mandated
promulgation of standards applicable to tank systems owned and
operated by small quantity generators and section 3004(o)(4)
stipulated that EPA must promulgate standards requiring any new
underground tank system to incorporate an "approved leak      ••
detection system".  Thus, permitting standards for underground
storage tanks that cannot be entered for inspection, interim
status requirements for small quantity generators and leak
detection requirements for all new underground tank systems were
promulgated pursuant to HSWA.

     All other sections of the July 14, 1986 rule applying to
aboveground, inground, onground, and underground tanks that can
be entered, were promulgated pursuant to pre-HSWA (or RCRA)
authority.   This dual HSWA-RCRA authority within one rule makes
the determination of applicability difficult.   All inspectors
should carefully read Section 2.2 Applicability of the Hazardous
Waste Tank Svst^ffl Regulations,, before conducting tank system
inspections.

     The purpose of these regulations is to protect human health
and the environment by preventing releases of hazardous materials
from storage and treatment tanks to soils, ground water and/or
surface water.  EPA's approach to obtaining this goal through
these regulations is by:

     o  maintaining the integrity of the primary
        containment system
     o  monitoring to detect leaks from the primary containment
        system
                               l-l

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                                                     OSWER 9938.4


     o  requiring secondary containment for all new tank
        systems and phasing in secondary containment for
        all existing tank systems.

     Proper response to releases of hazardous wastes from tank
systems, careful operation, and frequent inspections are central
to the final rule and will be reflected in this inspection
guidance document.
 1 . 2  Stmcf.tiT'g and Use of the Hagarflp.uf1 jfag<-e TanJr
     The purpose of this guidance manual and the accompanying
checklists is to provide guidance to inspectors so that they can
assess compliance with the requirements of the July 14, 1986
rule. Inspection is. the principal means available to EPA for
enforcing the hazardous waste tank regulations.  Authority to
conduct inspections is explained in section 3007 of the Resource
conservation and Recovery Act or applicable .state authority.
[Inspection authority is discussed in more detail in the RCRA
Inspection Manual (see No. 7 in appendix D).]

     This manual contains an overview of the hazardous waste tank
system regulations and a summary of EPA's enforcement approach.
Three sections on conducting inspections are included:

     o  inspection preparation,
     o  the on-site inspection (which includes sections
        on inspecting facility records and conducting
        visual tank inspections) , and
     o  post-inspection review

     The on-site. inspect ion section is designed to go hand-in-
hand with the compliance checklists provided in Appendix A.
Based upon the inspection preparation review, the inspectors
will select checklists that are applicable to the facility under
review.  Checklists corresponding to the general facility and to
each tank type located at the facility will be selected by the
inspector prior to the site visit.  The evaluation section of the
guidance document will provide the information necessary to
assess the compliance of the facility to the general requirements
of the rule  (e.g. inspection logs) and the compliance of
individual tank systems to specific standards  (e.g.. documented
correct installation of a new tank system).  More detailed
technical information applicable to t'he assessment of compliance
of a specific tank type,  (e.g. concrete on-ground tank containing
50,000 gallons of liquid, sul fate bearing hazardous waste) is
                                1-2

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                                                     OSWER 9938.4


provided as a separate reference section in Appendix B.   This
appendix will be used to supplement the evaluation section.

     Additional appendices include a glossary and a reference
section.  This document can also be used as a general reference
to the hazardous waste storage and treatment tank rule along with
the other documents listed below.  This manual .can also be used
as a training tool.


 1.3  Relationship of this Document to Other Guidance Manuals

     The Hazardous Waste Tank Inspection Guidance is specific to
the tank rules and is designed to be supplemented with other
guidance documents.  EPA has developed the RCRA Inspection Manual
(see appendix D, No. 7), which provides overall guidance for RCRA
inspections, including information on administrative procedures,
entry, and a general approach for conducting inspections.  The
Hazardous Waste Tank Systems Inspection Manual is designed to
complement the RCRA Inspection Manual.                         '

     Additional guidance documents that may be useful in
providing more detailed information on hazardous waste tank
systems or on specific areas of the hazardous waste tank rule
are:

     o  RCRA Technical Case Development Guidance Document,
        OSWER 9938.3, June 1988.

     o  Technical Resource Document for Obtaining Variances from
        the Secondary Containment Requirement for Hazardqus Waste
        Tank Systems, Vol. I and II, OSWER Policy Directive No.
        9483.00-2  (EPA/530-SW-87-002A & 002B).

     o  Technical Resource Document:  The Storage and
        Treatment of Hazardous Waste in Tank Systems,
        OSWER Policy Directive No. 9483-00-12  (EPA/530-
        SW-86-044).

A brief description of these and other helpful references is
provided in Appendix D.
                                1-3

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                                                     OSWER 9938.4


Z.O  OVERVIEW OF HAZARDOUS WASTE TANK SYSTEM REGULATIONS

2.1  The Regulatory Approach/Frarogyork,

     The July 1986 rule is designed to protect human health and
the environment by preventing releases of hazardous wastes from
tanks and by rapidly detecting and addressing accidental releases
that do occur.

     The rule outlines design and operating requirements for new
and existing permitted tank systems, small quantity generators,
and 90-day accumulation tanks including requirements for the
following:

     o  sound primary containment
     o  secondary containment
     o  adequate detection and monitoring technology
     o  detailed recordkeeping
     o  daily inspections
     o  independent evaluations of tank integrity and tank
        installation

     The following regulatory overview is to provide the
inspector with a brief summary of the existing hazardous waste
regulations.  It is not meant to, and should not, preclude the
inspector from reading and becoming familiar with the complete
rule.  If something in this guidance does not answer a specific
question, the inspector should check the original rule or call
the RCRA hotline (1-800-424-9346).
2.2  Applicability of the Hazardous Waste Tank System Regulations

     The regulations apply to owners and operators of facilities
that use:

     o  aboveground,
     o  onground,
     o  inground, and
     o  underground

tank systems vised for storing or treating any hazardous wastes.

   All sections of the rule applicable to aboveground, onground,
inground,  and underground tanks that can be entered for
inspection, are promulgated pursuant to RCRA (Pre-HSWA)
authorities.  Tank systems in these categories, which are
located in unauthorized states, must meet all federal
requirements. Tank systems in these categories in authorized

                               2-1

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                                                     OSWER 9938.4


states are not required to comply with the July 14th Rule until
such time as the authorized state amends its statute.

     These regulations do not apply to underground tanks storing
petroleum or hazardous substances listed under Super fund (other
than hazardous waste).  Tanks that store petroleum and hazardous
substances (other than hazardous waste) must comply with Subtitle
I of RCRA (Underground Storage Tank Program) and are likewise not
regulated under 40 CFR Subpart J (Hazardous Waste Tank Systems).
The hazardous waste tank system regulations should not be
confused with the Underground Storage Tank Program (UST) .

     The requirements for leak detection for all new underground
tank systems, the technical and permitting standards for
underground tank systems that cannot be entered for inspection
and the interim status requirements applicable to small quantity
generators operating tank systems are promulgated under HSWA and
are effective in all states, regardless of authorization status.
   2.2.1  RXlStrinq Tajik.

     Existing tank systems are defined as:

     o  tank systems already in operation on July 14, 1986
     o  tank systems for which installation commenced prior to
        July 14, 1986

The definition of existing tank systems under this rule is
different from the definition of existing and new. facilities for
the purposes of determining eligibility for interim status.

     The regulations require that:

     o  secondary containment and interstitial monitoring be
        phased in for existing tanks according to the
        following schedule:

        - for existing tanks storing or treating listed dioxin-
          containing wastes, by January 12, 1989

        -for existing tank systems of known and documented age,
          by January 12, 1989 or when the tank system has reached
          15 years of age, whichever comes later

        - for existing tank systems for which the age cannot be
          documented, by January 12, 1995; but if the age of the
          facility is greater than seven years, by the time the
          facility reaches 15 years of age or by January 12, 1989
          whichever comes later

                               2-2

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                                                     OSWER 9938.4
        — any component of a tank system that cannot
          be visually inspected and has been found to
          be leaking, must be provided with secondary
          containment prior to being returned to
          service

     Existing interim status or permitted tank systems that have
not implemented secondary containment:

     o    must obtain and keep on file at the facility
          a written assessment of the tank system's
          integrity reviewed and certified by an
          independent, qualified, registered engineer.

     The owner/operator of permitted tanks must comply with
permit conditions. Therefore, a permitted facility with hazardous
waste storage or treatment tanks may have to obtain a permit
modification if their permit does not incorporate the July 14,
1986 regulations (S270.4(a)].
   2.2.2  New TanJt

     A new tank system is defined as:

     o  a system or component that will be used to store or treat
        hazardous waste or for which installation has commenced
        after July 14, 1986

        - this includes tank systems that are already
          manufactured before July 14, 1986, but put
          into service after July 14, 1986

        - this includes existing tank systems that have
          not been used for the storage or treatment of
          hazardous waste bat are then put into service
          or converted to use as hazardous waste
          storage or treatment tank systems subsequent
          to July 14, 1986

        - this includes tank systems previously used
          for storing or treating hazardous waste that
          were taken out of service before July 14,
          1986, but put back into service after July
          14, 1986
                               2-3

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                                                     OSWER 9938.4
      The regulations require that:

     o    secondary containment and leak detection
          capability must be provided for all new
          hazardous waste tank systems

     o    the owner/operator must submit, with the Part
          B application, a written assessment, reviewed
          and certified by an independent, qualified,
          registered professional engineer attesting
          that the tank system has sufficient
          structural integrity and is acceptable for
          the storing and treating of hazardous waste

     o    the installation of a new tank system roust be
          directly supervised by an independent,
          qualified installation inspector or an
          independent, qualified, registered,
          professional engineer and that the same
          inspector or engineer must carefully
          inspect the system prior to covering,
          enclosing or placing the new tank system or
          component in use

     o    all new tanks and ancillary equipment must be
          tested by an independent, qualified,
          registered, professional engineer for
          tightness prior to being covered, enclosed,
          or placed in use

   2.2.3  Less TlTrlli 90—Dav Accmnilfltion Tajik. SYStSBfi

          Effective for all 90-day accumulation tank
          systems in unauthorized states and in all
          states for 90-day accumulation tank systems
          that are new underground tanks or
          underground tanks that cannot be entered by
          inspection —

     Generators may accumulate hazardous waste in tanks on-site
for 90 days or less without a permit or without interim status
provided:
                               2-4

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                                                     OSWER  9938.4


     o    the generator  complies with Part  265 Subpart
          J  (tanks)  [this  includes compliance with
          secondary  containment requirements] except
          for §265. 197 (c)   (closure and post-closure
          requirements for tanks) and § 265.200  (waste
          analysis and trial  tests)

     p    the generator  complies with Part  265 Subparts
          C  (Preparedness  and Prevention) and D
          (Contingency Plan and Emergency Procedures)

     o    the generator  complies with other applicable
          requirements of  §262.34.

Generators accumulating  hazardous waste on  site  for 90 days or
less are exempt  from Part  265 Subparts G  (general closure and
post-closure requirements)  and H (financial responsibility),
except for §265.111  (closure  performance standard) and §265.114
(disposal or decontamination  of equipment,  structures and soils).

     A generator who accumulates waste for more  than 90 days is
subject to the requirements of 40 CFR, Parts 260-266 and Part
270.  The Regional Administrator has the authority to grant an
.extension of 30  days [§262.34(b)J to the 90-day  limit.
    2.2.4  ?Tffalil  OuaT^ifcv Generators

          Effective  in all states  —

     Facilities  generating between 100 and 1,000 kg/mo of
hazardous waste  that accumulate the waste in tanks may operate
tanks without a  permit provided:                        •

     o-   the generator accumulates waste in the tank
          systems  for less than 180 days  (or 270 days
          if the generator ships the waste greater than
          200 miles)

     o    the generator does not accumulate over 6000
          kg of  waste on-site  at one time

     o    the generator complies with other applicable
          requirements of §265.201.

     Generators  of between 100 and 1000 kg/month of hazardous
waste, which accumulate waste  for  less than 180 days  (or 270 days
if  waste is shipped  over 200 miles) and do not accumulate more
than 6000 kg at  one  time, must comply with §262.34(d).


                               2-5

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                                                     OSWER 9938.4


      Generators who accumulate hazardous waste in tanks on-site
for more than 180 days (or 270 days), or who accumulate more than
6000 kg at one time, are subject to 40 CFR, Parts 260-266 and
Part 270.

   2.2.5
     The following tank systems are exempt from the July 14, 1987
rule:

     o    tank systems which are a part of a closed-
          loop system that store secondary materials
          intended to be reclaimed

     o    treatment tanks discharging wastes through an
          outfall with an NPDES permit

     o    tank systems operated by generators
          generating 100 kg/month or less hazardous
          waste (unless waste is acute hazardous
          waste).

     The containment and detection requirements (S264.193 and
 S265.193) do not apply to:

     o    tanks that are used to store or treat
          hazardous waste which contain no free liquids
          and are situated inside a building with an
          impermeable floor

     o    a tank that serves as part of a secondary
          containment system designed to collect or
          contain accidental releases of hazardous
          waste

     o    a sump, defined as any pit or reservoir that
          meets the definition of a tank and those
          troughs/trenches connected to it (see
          glossary in  Appendix C), that serves as part
          of a secondary containment system designed to
          collect or contain accidental releases of
          hazardous wastes.
2.3   Variances

     There are two types of variances from the secondary
containment and detection requirements:
                               2-6

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                                                     OSWER 99-38.4
    o  technology-based variance
               the owner/operator must demonstrate
               that alternative design and
               operating practices, together with
               location characteristics, will
               prevent the migration of any
               hazardous constituents into the
               ground water or surface water at
               least as effectively as secondary
               containment during the active life
               of the tank system

     o  risk-based variance

               the owner/operator must demonstrate
               that in the event of a release that
               does migrate to ground water or
               surface water, no substantial
               present or potential hazard will be
               posed to human health or the
               environment

     New underground tank systems are not allowed a risk-based
variance.

     Where interim status facilities are concerned, the Regional
Administrator must notify the public, allow for a 30-day comment
period, provide an opportunity for a hearing, and approve or
disapprove the request in 90 days.
2.4  y^imjnary of Regulation

     The seven major issues addressed in the regulations are:

     o  Primary Containment/Tank Integrity Assessments
     o  Tank Installation
     o  Secondary containment and Detection
     o  Response to Leaks/Spills
     o  Inspections/Operation and Maintenance
     o  Closure and Post-Closure
     o  Small Quantity Generators
                               2-7

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                                                  OSWER 9938.4
  o    tanks must be constructed witn materials
       compatible with the wastes stored or treated
       in them

  o    for new and existing tanks a written
       assessment, reviewed and certified by an
       independent, qualified, registered,
       professional engineer, of the tank's
       structural integrity and adequacy for
       storing the wastes it is meant to store must
       be obtained and placed on file at the
       facility; for  new tanks the assessment must
       be filed with the Part B permit application

2.4.2  Tanlc Installation

  o    new tank owner/operators are responsible for
       the tank being properly installed

  o    the installation of a new tank must be
       directly supervised by an independent,
       qualified, installation inspector or an
       independent, qualified, registered,
       professional engineer

  o    before covering, enclosing, or placing a new
       tank system or component in use the
       independent, qualified installation
       inspector or the independent, qualified,
       registered professional engineer must inspect
       the system for a number of structural
       problems outlined in the regulations

  o    all new tanks and ancillary equipment must be
       tested for tightness prior to being covered,
       enclosed or placed in use
2.4.3  'Sfjconflgry Contai \ nflftTVt fllKJ

  All secondary containment systems must be:

  o    designed, installed, and operated to prevent
       any migration of wastes or accumulated liquid
       out of the system to the soil, ground water,
       or surface water at any time during the use
       of the tank
                            2-8

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                                                     OSWER 9938.4


     o    capable of detecting and collecting releases
          arid accumulated liquids until the collected
          material is removed

     o    constructed of, or lined with, materials  that
          are compatible with waste(s)  to be placed in
          the tank system

     o    equipped with a means of release detection
          which is capable of detecting the failure of
          either the primary or secondary containment
          structure or the presence of  any release  in
          the secondary containment system within 24
          hours or the earliest practicable time

     o    sloped or otherwise designed  or operated  to
          drain and remove liquids resulting from
          leaks, spills, or precipitation

     Secondary containment for tanks must include one or more of
the following:

     o  a liner
     o  a vault
     o  a double-walled tank .
     o  an equivalent device as approved by the Regional
          Administrator

       2.4.3.1  Liners

     External liners must be:

     o    designed to contain 100 percent of the
          capacity of the largest tank  within its
          boundary

     o    designed or operated to prevent run-on or
          infiltration of precipitation into the
          secondary containment system  unless it
          contains sufficient capacity  to contain
          precipitation from a 25-year, 24-hour
          rainfall event in addition to the capacity of
          the largest tank within the boundary of the
          secondary containment system

     o    free of cracks or gaps
                               2-9

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                                                     OSWER 9938.4
     o    designed and installed to surround the tank
          completely arid to cover all surrounding earth
          likely to come into contact with the waste if
          released from the tank

       2.4.3.2  Vault Systems

     Vault Systems must be:

     o    designed to contain 100 percent of the
          capacity of the largest tank within its
          boundary

     o    designed or operated to prevent run-on or
          infiltration of precipitation into the
          secondary containment system unless the
          collection system has sufficient excess
          capacity to contain run-on or infiltration
          from a 25-year, 24-hour rainfall event in
          addition to the capacity of the largest tank
          within the boundary of the secondary
          containment system

     o    constructed with chemical-resistant- water
          stops in place at all joints

     o    provided with an impermeable interior coating
          or lining that is compatible with the stored
          waste and will prevent the migration of waste
          into the concrete

     o    provided with the means to protect against
          the formation of and ignition of vapors
          within the vault, if the waste being stored
          or treated meets the definition of ignitable
          waste or reactive waste (§262.21)

     o    provided with an exterior moisture barrier or
          be otherwise designed or operated to prevent
          migration of moisture into the vault if the
          vault is subject to hydraulic pressure
       2.4.3.3  rfrWhlft-Walled Tanks

Double-walled tanks must be:

     o    designed as in integral structure so that any
          release from the inner tank is contained by
          the outer shell

                               2-10

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                                                     OSWER 9938.4
     o    protected, if metal, from both corrosion of
          the primary tank interior and of the external
          surface of the outer shell

     o    provided with a built-in continuous leak
          detection system capable of detecting a
          release within 24 hours or the earliest
          practicable time

       2.4.3.4  Ancillary Equipment

All ancillary equipment must be provided with secondary
containment except, for:

     o    aboveground piping (exclusive of flanges,
          valves, joints and other connections) that is
          visually inspected for leaks on a daily basis

     o    welded flanges, joints and connections that
          are visually inspected on a daily basis
          Note:  this exception is currently under
          review by EPA.  The inspector should look
          for updated information concerning this.

     o    seal less or magnetic coupling pumps that are
          visually inspected on a daily basis

     o    pressurized aboveground piping systems with
          automatic shut-off devices that are visually
          inspected on a daily basis
   2.4.4  InSPec;'tip,ng/Ope,ration and

     The owner/operator must:

     o    use spill and overfill prevention controls

     o    maintain. sufficient freeboard in uncovered
          tanks to prevent overtopping by wave or wind
          action or precipitation

     o    develop a schedule and procedure for
          inspecting overfill controls

     o    inspect at least once every operating day
          aboveground portions of the tank system, data
          gathered from monitoring equipment, the area
          immediately surrounding the externally

                               2-11

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                                                  OSWER 9938.4
       accessible portions of the tank system,
       including the secondary containment system,
       to detect erosion or signs of releases of
       hazardous waste

  o    confirm the proper operation of the cathodic
       protection system, if present, within- six
       months of installation and annually
       thereafter

  o    inspect or test all sources of impressed
       current at least bi-monthly

  o    maintain detailed operation and maintenance
       records.

2.4.5  Response to Leaks/SoilIs

  In the event of a leak or spill:

  o    the owner/operator must remove the tank
       system from service immediately and must stop
       the flow of hazardous waste into the tank
       system or into the secondary containment
       system and determine the cause of the release

  o    within 24 hours after detection the
       owner/operator must remove as much waste as
       necessary from the tank system to prevent
       further release to the environment

  o    all hazardous materials released to the
       secondary containment must be removed within
       24 hours or in as timely a manner as is
       possible to prevent harm to human health and
       the environment

  o    any release to the environment must be
       reported to the Regional Administrator within
       24 hours of detection unless the leak or
       spill of hazardous waste is less than or
       equal to a quantity of 1 pound and is
       immediately contained and cleaned up

  o    within 30 days of detection of a release to
       the environment that is greater than one
       pound or of any quantity that is not
       immediately cleaned up, the owner/operator
       must submit a report to the Regional

                            2-12'

-------
                                                  OSWER 9938.4
  O    remove and properly dispose of any visible
       contamination of the soil or surface water

2.4.6  Closure and Post-Closure Care

  o    the owner/operator must remove or
       decontaminate all waste residues,
       contaminated containment system components,
       contaminated soils, and structures and
       equipment contaminated with waste and manage
       them as hazardous waste

  o    if the owner or operator demonstrates that
       not all contaminated soils can be practicably
       removed or decontaminated then the
      .owner/operator  must close the tank system
       and perform post-closure care in accordance
       with the closure and post-closure care
       requirements that apply to landfills
       (§264.310)

  o    if an owner/operator has a tank system that
       does not have secondary containment that
       meets the requirements of §264.193 and has
       not obtained a variance then:

     - the closure plan for the tank system must
       include both plan for removing or
       decontaminating all waste residues and tank
       equipment and managing them as hazardous
       waste as well as a contingency plan for
       closing the tank system and performing post-
       closure care requirements under the same
       requirements as for landfills

     - a contingent post-closure plan must be
       submitted with the permit application

     - the estimated costs for closure and post-
       closure care must reflect the costs of
       complying with the contingent closure plan
       and the contingent post-closure plan, if
       those costs.are greater than the costs for
       closing the tank system as a tank system and
       not a landfill
                            2-14

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                                                     OSWER 9938.4


        - financial assurance must be based on the
          highest estimated costs

        - for the purposes of the contingent closure
          and post-closure plans, such a tank system is
          considered to be a landfill and the
          contingent plans must meet all of the
          closure, post-closure, and financial
          requirements for landfills under Subparts G
          and H.

   2.4.7  Sffl9.ll Qu.flnti.tv Generators

      Generators of between 100 and 1000 kg/month hazardous waste
must comply with the following general operating requirements:

     o    treatment or storage of hazardous waste in
          tank systems must comply with §265.17(b)
          [general requirements for ignitable,
          reactive, or incompatible wastes]

     o    hazardous wastes or treatment reagents must
          not be placed in a tank if they could cause
          the tank or its inner liner to rupture, leak,
          corrode, or otherwise fail before the end of
          its intended life

     o    uncovered tank systems must be operated to
          ensure that at least 60 cm (2 feet) of
          freeboard is maintained unless the tank
          system is equipped with a containment
          structure, a drainage control system, or a
          diversion structure with a capacity that
          equals or exceeds the volume of the top
          2 feet of the tanks

     o    where hazardous waste is continuously fed
          into a tank system, the tank system must be
          equipped with a means to stop this inflow

     Generators of between 100 and 1000 kg/month hazardous waste
that are accumulating wastes in tanks must inspect, where
present:

     o    discharge control equipment at least once
          each operating day
                               2-15

-------
                                                     OSWER 9938.4


     o    data gathered from monitoring equipment
          at least once each operating day to ensure
          that it is in good working order

     o    the level of waste in the tank at least once
          each operating day

     o    the construction materials of the tank at
          least weekly to detect corrosion or leaking
          of fixtures or seams

     o    the construction materials of, and the area
          immediately surrounding, discharge
          confinement structures at least weekly to
          detect erosion or obvious signs of leakage,
          and

     o    the owner/operator must remedy any .
          deterioration or malfunction found.

     Generators of between 100 and 1000 kg/month hazardous waste
that are accumulating wastes in tanks must, upon closure of the
facility, remove all hazardous waste from the tank system,
discharge control equipment, and discharge confinement structures
and must manage any hazardous wastes in accordance with all
applicable requirements of Parts 262 (standards applicable to
generators), 263 (standards applicable to transporters) and 265
(interim status standards for owners and operators of TSD
facilities) .

     Small quantity generators that generate more than one
kg/month of acute hazardous waste, or more than 100 kg/month of
any residue or contaminated soil, waste, or other debris
resulting from the spill or cleanup of acute hazardous waste, are
subject to 40 CFR, Parts 262-266 and Part 270.

   2.4.8  Speciq 1
     An owner /operator storing or treating hazardous waste in a
tank system (including small quantity generators and those
operating 90-day accumulation tank systems) must comply with the
following special requirements for ignitable and reactive wastes:

     o    ignitable or reactive waste must not be
          placed in a tank unless:
                               2-16

-------
                                                     OSWER 9938.4
        - the waste is treated, rendered or mixed
          before or immediately after placement in a
          tank so that the resulting waste, mixture or
          dissolution of material no longer meets the
          definition of ignitable or reactive waste and
          the owner/operator takes precautions to
          prevent reactions which may be hazardous to
          human health or the environment [§265.17(b)]
          or

        - the waste is stored or treated in such a way
          that it is protected from any material or
          conditions that may cause the waste to ignite
          or react or

        - the tank system is used solely for
          emergencies

        - the owner/operator of a facility,which treats
          or stores ignitable or reactive waste in
          covered tanks must comply with the buffer
          zone requirements for tanks contained in
          Tables 2-1 through 2-6 of the National Fire
          Protection Association's Flammable and
          Combustible Liquids Code (1977 or 1981)

     An owner/operator storing or treating hazardous waste in a
tank system must comply with the following special requirements
for incompatible wastes:

     o    incompatible wastes or incompatible wastes
          and materials must not be placed in the same
          tank unless the owner/operator takes
          precautions to prevent reactions which may
          be hazardous to human health and the
          environment [$265.17(b)]

     o    hazardous waste must not be placed in an
          unwashed tank which previously held an
          incompatible waste or material unless the
          owner/operator takes precautions to prevent
          reactions which may be hazardous to human
          health and the environment (S265.17(b)]
                               2-17

-------
                                                     OSWER 9938.4
3.0  ENFORCEMENT APPROACH

     As stated in Section 1.0, the goal of the hazardous waste
tank systems regulations is to prevent the release of hazardous
wastes to the environment from tank systems.   Therefore,
inspectors should focus on:

     1.   The phasing in of secondary containment for
          existing tank systems

          - inspectors should ensure that secondary containment
            is provided when required (see Figure 3)

     2.   Documentation of the proper installation and
          integrity assessment for new tank systems

          - inspectors should review documentation to verify that
            each tank system has been installed properly

     3.   violations of inspection requirements

          - because the documentation of the tank system
            inspection requirements is central to the goal of
            identifying and stopping releases, a violation of
            those same recordkeeping requirements can be a
            serious impediment to the goals of this program

     4. Implementation of spill and overfill prevention
        and control measures

          - inspectors should carefully inspect tank systems to
            ensure that the proper spill and overfill prevention
            controls are in place and working
                               3-1

-------
                                                               OSWER 9938.4
                              Figure 3
     •Deadlines for Secondary Containment of Tank Systems
              Is tni link tyittm n»w?
              do., eonitruclod ifl*r
                  July 14, Itei)
                                     Yoi
                      Bifon putting Iho
                       link tyitofn
                       Into torvlco
                     I
N»
                  0o»i MM link
                 •tori/ trill dloxln
                eotitiMng hizird«ui
              F020-F023, FO J», F027
Jan.
12. H8»
                        Ml
                  li th» ••• ol
                 lh» link iytt*m
                  known Mitf
                      Jin. 12, 1f«t
                   ir whin Mi* link i»itim
                   r*icn*i 18 yi«r« •!•••,
                    wMch*v*c li lit**.
                                               Jin. 12, 1«a»
                                             or wh»n tk« fi«M»»
                                            roicnn 1 8 yuri of igi,
                                             wMehovw li lilot . .
                         No
Jin. 12,
IMS
* Deadlines may vary depending on state authorization.
  Review Chapter 2.2 (Applicability) of this manual
                              3-2

-------
                                                     OSWER 9938.4
4,0  PREPARING FOR THE INSPECTION
     Prior to conducting an inspection of a facility operating
hazardous waste tank systems, the inspector will want to answer a
number of questions to determine how the July 14, 1986 rule
applies to the individual facility in question.   Figure 4A is a
flow chart showing applicability of the July 14  rule.  After
charting a tank system through Figure 4A, the inspector should
follow through with Figure 3 to determine the secondary
containment deadlines for each regulated tank system.

     The following documents, which can be obtained from the
states or regions prior to the inspection, may be used as
information sources to determine applicability of the rule:

     o  Permit applications: Part A and Part B
     o  Permits
     o  Notification forms:  EPA Notification of  Hazardous Waste
        Activity
     o  For new tank systems, a written assessment of tank
        integrity (Part B)
     o  EPA or state inspection reports
     o  Report to the regional administrator of  any spills/leaks
     o  Any other correspondence to the states or regions
     o  Record of a granted variance

     Based on the information gathered during inspection
preparation, the inspector should assemble the necessary
checklists to take on-site.   The checklists will form the basis
of the on-site inspection and post-inspection review. There are
eight checklists, some of which will or will not be used
depending on the type of facility (e.g., small quantity
generator) or type of tank (e.g., existing or new tank system)
being inspected.  Figure 4B illustrates the relationship between
the different checklists and how they are to be  used during an
inspection.

     The regulatory provisions for permitted and interim status
tank systems are essentially parallel, so there  are no
distinctions made between permitted and unpermitted tank systems
in the checklists.  However, permits need to be  reviewed before
inspecting a permitted tank system so that compliance with
permit-specific requirements can be checked.  In addition,
because 90-day accumulation tank systems are only exempt from
financial and closure requirements and are still subject to
provisions requiring secondary containment, Checklists III and IV
(Existing and New Tanks) should be used for 90-day accumulation
tanks.
                               4-1

-------
                                                                Figure 4A.
                        Applicability of the July  14, 1986  Hazardous  Waste Tank Regulations
                                                                             The ••n*r*.t*r mint
                                                                             comply wllh I«S. 94
D*** liclllty h*v*
link *y*t*mi u**d
l«r the *tor*g*
•r treatment of
h*i*rdou* w**l**?
                                                                      Vo  .^
                                                   D*** In* g*n*r*l*r
                                                   •ccumul*!* w**l*
                                                   •n-*lt* f*r )•••
                                                   thin *0 d*y*T
      The Unk *y*l*m I*
      •••mptlr«mS«4.1f3
      (••ccntfary ••nl*lnm«nl
Tank •y«l«m (• *n«w*
•M HHMl comply
with Pert* 2«4 *n< !••
•t lukpcrl J
    Ar* th* link '
    •yclomi ut*d for
    •lorlng ••cond«ry
    m*t«ri«li intended
    lor racUmalion in
    • doled loop •yslom?
     Ar* the tecondiry
     m«l*ti*lt (lorod lor
     ovor  12 month* In
     lh« Unk (yilomt?
              No
      Do** teclcmalion
      Involve controlled
      flem* combuetion?
           I
No
      I* Ih* reclamed
      materiel uied lo
      produce • luel?
        Regulation*
        do not opply
                              U Ih* Unk *y*l*m
                              u**d l*r lr**lm*nl
                              •I w**l** dl*ch*rg*d
                              under •« NPOCI p*fmll7
                         No
                                                                        Ar* Id* lank* «•••) U
                                                                        •l*r* *r lr**l HW
                                                                        which e*nl*m* n* Ir**
                                                                        M>0d* end *r* illuoUd
                                                                        m*ld* • kulldlnf with
                                                                        •n lmp*rm*)«M* ll*»f ?
                                                                                                                 \
                    Ar* lh« link* u**d
                    •• • **e*nd*ry
                    conl*lnm*nl «y*l*m
                    I* c*H*cl *r cinUIn
                    r*l***** •• HWT
 W*r* Ih* l*nk*
 •p*r*lmf *r tM

 prlvrl* 7/14/t«t
                                         Do** the g*n*r*tor
                                         •ccumyl*!* MW Ur
                                         mor* then  1tO d«y*
                                         (or 270d*y*lf TIP
                                         ta >200 mil** *w*y>?
T
                                                                                             V**
                         V**
                                         1* the lolil (mount
                                         •1 HW *ccumul*Ud
                                         mor* lh*n (000 kf
                                         •t *n* Urn*?
                                                                                                                                      v*«
                                             Tank *y*t*m I* •
                                             •nd mo*l c*mp4y
                                             wllkMrU 1 •« «nd 21 •
                                             •I tukp.rl J
                                                                                              Y*»
                         V**
                         V**
                                         Th* |*n*r*l*r mu*l
                                         comply with 2(6.201
                                                             4-2

-------
                                                  FIGURE 4B
                                      How to Use Checklists in Appendix A
                                                                                                  OSWER  9938
	PRE-INSPECTION
ON-SITE INSPECTION
     Review facility files
     and assemble appropriate
     checklists
     [One checklist per tank
     system]
                                      	Record Review-
                          Visual Inspection
4
Facility ID
V
\

SQG
Checklist 1

New Tank
Checklist IV

Existing Tank
Checklist III

Closed Tank
Checklist VIII
4
Doe
^ General Inspection nan
Requirements 9** jgnj
^ Checklist II or r
Special Wastes ""che^is^l*38*
Checklist V
4 '
Yes Yes
' ^ ' a tanLr ' 	 	 	 	 	 '
wastes f "iw •"••"
system?

                                                 4-3

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                                                     OSWER 9938.4
5.0  ON-SITE INSPECTION PROCEDURES

     This chapter is intended to walk the inspector through an
on-site inspection.  For the convenience of the inspector, the
chapter is organized by checklist with each section providing
the explanations and additional references for checklist items
that may not be self-explanatory.  The inspector should review
Chapter 4.4 of the RCRA Inspection Manual (March 1988)  on the use
of inspection checklists.  Note:  Questions included in the
checklists that do not directly pertain to requirements of this
rulep but are used to "flag" or alert the inspector to  conditions
that mav lead to future-violations.  are marked with an  asterisk.

     One facility identification form will be filled out per
facility.  This form is simply a way of summarizing the vital
statistics of- the facility being inspected.

     Generally, the inspector should plan to start the  inspection
with a record review.  After examining facility records, the
inspector will conduct a visual inspection of the tank  system(s).


5.1  Small Quantity Generators  [Checklist I]

     Generators of between 100 and 1000 kg/month hazardous waste
are treated as a subset of the hazardous waste tank universe.
Inspections of these facilities will not include checklists II,
III, IV, VII, and VIII.  Because only one checklist win be
used, some universal tank questions  which may not appear on other
checklists appear on the SQG checklist (I).  Since many SQG's
have only tanks, this might very well be the only inspection by
EPA at a facility.  Therefore, general compliance questions are
included here whereas the other lists only cover the July 1986
hazardous waste tank regulation.

A.I* The inspector should have the owner/operator provide
     the volume of the tank.  During the visual inspection
     the inspector should verify that the tank size is
     appropriate for the volume that it is stated to hold
     (e.g., a 100 gallon tank would not be a cylindrical
     tank of 4.5 feet diameter and a height of 8 feet.
     That size tank would be closer to a 1000 gallon
     tank).  5265.201(a) stipulates that those SQG's which
     accumulate over 6 000 kg of hazardous waste at one
     time must, obtain a permit and comply with 40 CFR,
     Parts 264, 265 and 270.  The inspector should be aware
     that aqueous wastes exceed the 6,000 kg cutoff at
     1,585 gallons.  If you suspect that a generator keeps
     more than 6,000 kg on-site before shipment, you can

                             .  5-1

-------
                                                     OSWER 9938.4
     calculate the approximate weight based upon the size
     of the tank system and the general density of the
     waste type.

A.2  The inspector should provide a general description of
     the tank type in the following areas:

          (a) in-, above-, on-, underground
          (b) steel, stainless steel, FRP, concrete, other
          (c) lined, unlined, open-topped

B.I  The inspector should try to obtain as specific a waste
     analysis as possible.

B.2" A small quantity generator will probably not have a
     permit so the inspector should find out from the
     owner/operator what wastes have been stored in the
     tank.  Verify the information using hazardous waste
     manifests.  This is to provide information on any
     potential mixing of incompatible wastes.  If the tank
     holds more than one waste type, the inspector can
     refer to waste incompatibility tables (Appendix B,
     9a-f) to note potential problems.

     The inspector should check if the generator is
     generating acute hazardous waste.  A list of acute
     hazardous wastes can be found in Appendix B-25, a-d.
     If a generator is generating more than one kg/month of
     acute hazardous waste or more than 100 kg/month of any
     residue or contaminated soil, waste, or other debris
     resulting from the cleanup of a spill of acute
     hazardous waste, the generator is subject to Parts
     262-266 and Part 270.  If the owner/operator is
     storing/treating acute hazardous waste in a tank
     system, the inspector should refer to 40 CFR §261.5(e)
     and turn to the appropriate checklists (i.e., new or
     existing tanks, etc.).

3.3  The inspector should indicate whether the waste and the
     tank material are compatible by using Appendix B, 4a-e.

C.I  The inspector should examine the manifest file to
     determine whether or not the generator is storing
     waste on-site beyond the number of days allowed.

c:.2-C.4
     If the generator, ships waste 200 miles or less, waste
     can be accumulated for 180 days [§265.201(a)].  If
     waste is shipped more than 200 miles, it can be

                               5-2

-------
                                                     OSWER 9938.4
     accumulated in tanks up to. 270 days.  If the number of
     days allowed for accumulating waste in tanks has been
     exceeded, the generator must comply with 40 CFR, Parts
     264, 265, and 270.

C.5  The owner/operator must inspect the tank system
     according to the criteria of §265.201(c), however,
     they are not required to maintain documentation.
     It is important for the inspector to phrase these
     questions so that the owner/operator provides
     information on the frequency and type of inspec-
     tions.  For example, "Please describe your tank
     inspection procedures and frequency".

D.    Requirements for SQG's that handle special wastes are
     the same as for other facilities.  If a SQG facility
     handles ignitable or reactive wastes,  refer to
     Checklist V.

E.    This part of the checklist refers to the visual
     inspection of the SQG.

E.I  As long as SQG's accumulate hazardous waste on-site
     they are required to clearly label tanks with the words
     "hazardous waste" [$262.34(a)(3)].  The inspector
     should verify this during the visual inspection.

E.2  The presence of any of these conditions indicates
     corrosion of the tank system [§265.201(b)(2)].

E.3  The inspector should be careful to note if there have
     been any apparent leaks or spills.

E.4  SQG tank systems must comply with §265.201(b)(3), which
     requires 2 feet of freeboard on open tanks

E.5  SQG's must comply with $265.201(b)(4) , which requires
     that tank systems be equipped with a means to stop
     inflow where waste is continuously fed into the tank
   '  system

F.    This section covers the general requirements under 40
     CFR, Part 262 for SQG's.  Because these facilities do
     not undergo routine facility inspections, verification
     of adequate emergency response measures are important.
                               5-3

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                                                     OSWER 9938.4
5.2  Recordkeeoing and Inspection Logs

     The regulations require that owner/operators of hazardous
waste treatment and storage tank systems (that are not otherwise
exempt) and generators operating 90-day accumulation tank
systems maintain detailed records documenting the age and
integrity of the tank system as well as the operation and
maintenance of the system.  The recordkeeping requirements are an
integral:part of the regulatory strategy because:

     p    the recordkeeping procedures force the  .
          owner/operator to test the integrity of tank
          systems and to inspect and properly maintain
          tank  systems so as to prevent leaks

     o    the records themselves may provide the
          information needed by inspectors to determine
          if there are violations at the facility.

     Because the recordkeeping requirements are designed to aid:
in enforcement of the regulation, a violation of those same
requirements should be documented and some enforcement action
should be taken in response.

     The records that the inspector should examine while on-site
are outlined below.

   5.2.1   New and Existing Tanks
                 [Checklist II:  Documentation of General
                  Inspection Requirements]

      This checklist includes 90-day accumulation tanks.

A.l  The inspector should determine if the owner/operator
     has an adequate inspection procedure.  The inspector
     can request to see a written plan/procedure for
     conducting the required inspections.  If not available,
     the inspector should ask the owner/operator for a
     verbal description of daily inspection procedures.

     The inspector may also want to review chapter 10 of the
     OSWER Policy Directive (see appendix D, No. 11), or
     Section 5.3.1 of this chapter (Visual Inspection of
     Tank System) for the appropriate steps owner/operators
     should take to conduct tank inspections.

A. 2  If the tank is permitted, the owner/operator should
     have a schedule and procedure for inspecting overfill
     controls [§264.195(a)].  If the tank is unpermitted

                               5-4

-------
                                                     OSWER 9938.4
     (interim status) the owner/operator must inspect
     overfill controls each operating day [J265.195(a)(l) ].

     The inspector should ask the owner/operator  to see the
     schedule and procedure to determine if the procedures
     are adequately documented and, if so, to determine if
     the schedule/procedure is appropriate (e.g., it is
     not acceptable if the owner/operator inspects overfill
     controls monthly).

A.2a The inspector should then examine logbooks where
     results of inspections by facility personnel are kept
     and note if the inspections of overfill controls are
     taking place as scheduled, if the inspection procedures
     are followed and if clear and concise notes  are taken.

A.3  The inspector should review the logbooks to  verify that
     all aboveground portions of the tank system  have been
     inspected daily [5264.194(a)(1)].

A.3a Various inspection tools may be used by the
     owner/operator in conducting daily inspections of the
     aboveground portions of tanks.  These devices may
     include scrapers or hammers used to locate corroded
     areas.  A more detailed description of inspection tools
     and how to use them is provided in the OSWER Policy
     Directive (see appendix D, No.11) Chapter 10.  This
     question is included to flag a facility that may not
     have inspection procedures adequate to identify unfit
     tank system components.

A. 4  The type of tank and/or leak-detection equipment
     employed at the facility will determine how  the
     owner/operator monitors for leaks.  The leak-
     detection device may print out a reading, or the
     owner/operator may have to read and record data from an
     instrument or from a visual inspection.  The inspector
     should examine printouts or logbooks to ensure that the
     data from leak detection devices is recorded each
     operating day and that equipment is working.

     The inspector should examine logbooks to ensure that
     the owner/operator is recording data from all
     temperature and pressure gauges and from any other
     monitoring devices.

     (The inspector may want to choose a period of time
     (e.g., one month) randomly to examine the
     owner/operators logbook to determine if daily

                               5-5

-------
                                                     OSWER 9938.4
     inspection procedures are being followed properly).

A.5  The owner/operator is required to inspect both the
     construction materials of the tank system and secondary
     containment each operating day.  The inspector should
     determine either from the owner/operator or from a
     written plan that the daily inspection includes: signs
     of releases or corrosion around nozzles and ancillary
     equipment of the tank system; signs of corrosion on
     tank tops or roofs; defective manhead gaskets;
     corrosion or releases, cracks, and buckles on seams and
     plates of the tank wall and bottom; possible erosion
     around the foundation, pads, and secondary containment,
     if any, and; deterioration of protective coatings
     as indicated by corrosion, blisters, discoloration,  or
     film lifting.  [§264.194(b)(3)].

A. 6  The owner/operator must confirm the proper operation of
     the cathodic protection system within six months after
     the initial installation.  The owner/operator is
     required to have a record of the confirmation on file
     at the facility (S264.194(c)(1)].  The owner/operator
     should also provide dates as to the installation of the
     cathodic protection system on an existing tank system
     if it is different from the tank installation date.

     Confirmation of the proper operation of the cathodic
     protection system should be conducted by a corrosion
     expert.  A tank structure-to-soil potential measurement
     should be conducted to ensure a minimum level of
     -0.85 volts.  The owner/operator's logbook should
     contain a detailed description of the method used to
     determine proper operation and the results of the
     method used.

A.6a The owner/operator is required to conduct an annual
     inspection of cathodic protection [S264.I94(c)(l)].
     The logbook or records at the facility should indicate
     that a corrosion expert conducted tank structure-to-
     soil potential measurements and that the minimum level
     was -0.85.

A. 7  The owner/operator is required to inspect any
     impressed-current system bimonthly.  The
     owner/operator should inspect the timing device that
     controls the rectifier to make sure that there has
     been continuous output from the impressed-current
     system.  The inspector should also check for
     electrical shorts, ground connection, circuit

                               5-6

-------
4B
                                                     OSWER 9938.4


     resistance, and meter accuracy and efficiency.  More
     information on impressed-current systems is provided in
     the OSWER Policy Directive (see appendix D,  No. 11).

A.7a*The inspector should determine and record how the
     owner/operator inspects the impressed-current system.

    5.2.2  Existing Tanks  [Checklist III, Existing Tank
                              Systems]

     Existing tank systems are those that are in operation on
July 14, 1986 or for which installation had commenced prior to
July 14, 1986.  See the glossary,  Appendix C, for the complete
definition of an existing tank system (see also Figures 4A and
for applicability of regulations and use of the checklists).

A.I  The inspector should record the tank volume.  For
     permitted tanks, the volume should correspond to the
     permit.  For interim status tanks, this question
     provides information which the inspector might not be
     able to obtain elsewhere.

A.2  The inspector should record the tank type.   Depending
     on whether the tank system is underground or above-,
     on- or inground.  In addition, depending on whether or
     not the state is authorized,  some tank types
     (underground, non-enterable)  may be required to be in
     compliance with the regulations before other tank types
     (see Section 2.2 on applicability of the regulation).

B.I  The inspector, should determine the waste content of the
     tank by using documentation in the files (e.g., the
     written assessment of the  tank's integrity  or any
     manifests filled out if waste is shipped off-site for
     disposal).   The EPA Hazardous Waste Numbers are
     provided in 40 CFR, S261.30-33, Subpart D.

     If the wastes stored or treated in the tank are dioxin-
     containing wastes (F020, F021, F022, F023,  F026, or
     F027)  secondary containment.  if not already installed,
     must be provided by January 12. 1989 [S264.193(a)(2)].

C.2  If the tank system has been granted a variance, then
     the system does not have to have secondary  containment.
     The existence of an application for a variance does not
     mean anything in terms of  the regulatory requirements;
     it is only when a variance is granted that  there is an
     impact on the facility inspection.


                               5-7

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                                                     OSWER 9938.4
C.3-C.4
     By January 8, 1988 the owner/operator must have on file
     at the facility a written assessment attesting to the
     tank system's integrity [§264.191(a)].  The written
     assessment must be reviewed and certified by an
     independent, qualified, registered, professional
     engineer.  The language necessary for certification is
     provided in Appendix B-l and in 40 CFR 270.11(d).

     Tank Age Documentation
     (Review Figure 3)

C.5  The written assessment must document the age of the
     tank if the owner/operator has that information
     (§264.191(a)(4)].  The age of the tank is necessary to
     determine when secondary containment is required.

C.5a If the tank age is not documented (that is, if dated
     plans/contracts or other appropriate information
     identifying the tank are not provided by the
     owner/operator) then it is important to mark 'unknown'.
     Secondary containment is required by 1/12/89 or when
     the tank is 15 years old, whichever comes later
     [§264.193(a>(3)].

C.6  The age of the facility should be recorded to determine
     when secondary containment is required if the age of
     the tank is not documented [S264.193(a)(4)].  if the
     facility is seven years or less, the tank must be
     provided with secondary containment by January 12,
     1995.  If the facility is greater than seven years old
     then the tank must be provided with secondary
     containment by the time the facility is 15 years old or
     by January 12, 1989 whichever comes later.

C.6a Acceptable documentation of the facility age will
     include:  dated blueprints, contracts, and insurance
     forms.  If documentation is not on site, it may be
     possible to date the facility before or after the
     inspection using other sources  (see appendix D, No. 7).

C.7  Based on the wastes stored in the tank system and/or
     based on the tank or facility age, the inspector
     should determine when secondary containment is
     required.  The inspector should inform or confirm with
     the owner/operator during the post-inspection review
     the date that secondary containment must be installed.
                               5-8

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                                                     OSWER 9938.4
     If the date for installing secondary containment has
     passed prior to the date of inspection and secondary
     containment is not provided, nor is a variance granted,
     a serious violation has occurred.

     Tank Design and Waste Compatibility

D.I  The written assessment must describe the wastes
     stored/treated "in tanks [§264.191(a) (2) ].   Tank
     material information may be used by the  inspector
     to determine compatibility with wastes stored/treated
     in them.  This is particularly important for 90-day
     accumulation and/or interim status tanks since waste
     compatibility will be reviewed solely by the inspector
     and not a permit writer.

D.2  The written tank integrity assessment must include a
     description of the design standards of the tank and
     ancillary equipment [$264.191(a)(i)]. Appendix B, 2a-c
     provides references for nationally accepted tank design
     standards.  Appendix B-3 provides  a list of
     organizations with up-to-date information on design
     standards.

D.3  To determine if the tank material  is compatible with
     the wastes stored or treated please see  Appendix B,
     4a-e.

     Corrosion Protection

E.I  The written tank integrity assessment must be on file
     at the facility by January 12, 1988, and must include a
     description of existing corrosion protection methods
     [S264.191U) (3) ].

E.2* The inspector should record the kind of  corrosion
     protection in place for the tank.   If the tank system
     is permitted the inspector should make sure that the
     protection provided is the same as that  specified on
     the permit.  This question provides a flag for
     unpermitted facilities.

 F.  Mon-enfrflfphig r underground tanks—Regulations effective
     in all states.  Because underground tanks cannot be
     visually inspected, the determination of the soundness
     of underground tank systems will rely primarily on
     records verifying the tanks integrity.
                               5-9

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                                                     OSWER 9938.4
F.la The written tank integrity assessment be on file at the
     facility by January 12, 1988, and must include the
     method used to test the tank system for leaks
     ES264.191(a)(5) ]..

F. ib-F.ic
     The owner/operator is required to conduct a tank
     integrity test annually [§264.193(i)] and must have the
     results of the tests on file at the facility
     [§264.193(i)(4)].  The inspector should inspect the
     tank integrity test results.  Tanks that are leaking or
     unfit should not be in service unless certified repairs
     are made, including secondary containment, as provided
     in [§264.196(e)).

F.ld For non-enterable underground storage tank systems, the
     leak testing device used for the annual tank integrity
     test is required to take into account the four
     variables listed [§264.191(a)(5)].

     The inspector should inspect the tank integrity test
     results.  Tanks  that are leaking or unfit should not be
     in service unless certified  repairs are made and
     secondary containment is provided [§264.196(e)].
                               5-10

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                                                     OSWER 9938.4
G.2a If the tank has -been assessed by an independent,
     qualified, registered, professional engineer who has
     conducted an inspection of the internal tanlc surfaces,
     a certification of tank integrity must be on file.

G.2b See Appendix B, 7a-b for a checklist of what should be
     evaluated when the independent, qualified, registered,
     professional engineer is conducting an internal
     inspection [$264.193(i)(2)].   Verify that the engineer
     has documented the examination of all appropriate
     factors.

     Ancillary Equipment

H.I. The written assessment requested under §264.I91(b)(1)
     must contain a description of feed systems, cutoff
     and/or bypass systems as well as pressure controls.

H.2-H.3
     A leak test or other integrity assessment approved  by
     the Regional Administrator must be conducted annually
     for ancillary equipment until secondary containment is
     provided [$264.193(1X3)].  The inspector should
     examine logbooks or other records which document that
     the leak test is conducted annually.

H.4  The inspector should both question the owner/operator
     and check through logbooks to determine if any tank
     component has leaked or-was found to be unfit.

   5.2.3  New Tanks  [Checklist IV, New Tank Systems]

New tank systems are those that were installed after July 14,
1986 or ones which commenced to handle hazardous waste after July
14, 1986.  Please review the definition of new tank systems in
the glossary provided in Appendix C.  (Also see Figures  4A and 4B
for applicability of the regulations and use of the checklists.)

A.   Checklist questions in Section A provide general
     descriptive information about the tank system.   For
     permitted facilities, or one which has submitted a  Part
     B permit application, this information verifies data
     already gathered.  For other facilities, such as those
     operating 90-day accumulation tanks, this may be the
     Agency's first description of the tank system.   In
     these cases, the inspector will be reviewing tank
                               5-11

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                                                     OSWER 9938'. 4
     material, waste compatibility and tank design criteria
     in order to identify violations and/or to flag
     potential problems.  Much of this section is self-
     explanatory.

B.   The inspector should record the specific components of
     the waste to evaluate compatibility with tank
     materials.  To obtain this information the inspector
     may want to use the Part B permit application (if one
     exists) , which contains a written assessment of the
     tank's integrity, including a description of the
     wastes.  The inspector should question the owner/
     operator and check other documents, such as manifests,
     to verify or add to information in the permit
     application.

     Certification of Installation and Tank Tightness

C.l-C.2
     The installation of a new tank system must be directly
     supervised by an independent, qualified installation
     inspector or an independent, qualified, registered,
     professional engineer who must provide written
     statements to the owner/operator certifying that the
     tank was properly installed.  The inspector should
     review the written statement(s) to ensure that the
     person supervising the installation was a qualified
     individual  (and not simply a facility employee) and
     that the tank system was inspected for the appro-
     priate deficiencies prior to covering, enclosing, or
     placing the tank into use [§264.192(b) and (g)J.  See
     Appendix B-i for the required certification paragraph.

C.3  Because supervision of installation may be performed by
     a different expert than one certifying the design of
     the tank system, the.inspector should review the
     installation log or other relevant documents to verify
     that installation was completed satisfactorily.

C.4-C.6
     Before the tank and ancillary equipment is covered,
     enclosed, or placed into use it must be tested for
     tightness [§264.192(d)].  A record of the test and its
     results must be on file at the facility.  The inspector
     should review the method used to test tank tightness as
     well as the results of the test.
                               5-12

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                                                     OSWER 9938.4
     must be removed from the secondary containment system
     within 24 hours after detection [§264.196(b)(2)].   The
     facility should provide some evidence that this  was
     accomplished and that the repairs  were made to the
     primary system prior to reuse [(S264.196(e)(3)].
     Certification is not required, however.  If no evidence
     can be provided, the inspector should look for the
     presence of waste or rain water within the secondary
     containment system that has not been removed as
     required (see Visual Inspection Checklist VII).

     Abqveground Ancillary Equipment Exemptions

E.1-E.5
     Certain aboveground components of  tank systems are
     exempt from the secondary containment requirements if
     they meet the criteria in §264.l93(f).   The inspector
     should ask if the tank system meets any of these
     criteria and verify that daily inspections are
     conducted and are documented.  During the visual
     inspection, the inspector should keep in mind that
     components without secondary containment must meet the
     S264.193(f) criteria (e.g., straight aboveground
     piping, sealless pumps, magnetic coupling rings).

     Corrosion Protection

F.1-F.2
     For new tank systems or components in which the
     external shell of a metal tank or  component will be in
     contact with the soil or with water, the owner/operator
     is required to provide the type and degree of corrosion
     protection recommended by a corrosion expert
     (S264.l92(f) ].  The inspector should verify that the
     corrosion protection employed is what was recommended.
     The expert's recommendation is required as a part of a
     written assessment of the tank system's integrity
     which must be on file at the facility ($264.192(g)].

F.3  If cathodic protection is field fabricated the design
     and installation must be supervised by a corrosion
     expert.

     Releases

     The occurrence of leaks/spills or  the lack of
     leaks/spills should be verified during the visual
     inspection.
                               5-14

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                                                     OSWER 9938.4
   5.2.4  Special Wastes  [Checklist V, Tank Systems that
                            Store or Treat Ignitable or
                             Reactive Wastes]

     The inspector may want to bring extra copies of this.
checklist to all facilities that have not submitted a permit
application, in case waste is determined to be reactive or
ignitable based upon information gathered during the site
inspection.

A.1  Ignitable and reactive wastes must not be placed in
     tank systems unless they are treated or mixed before or
     immediately after placement in a tank system so that
     the resulting mixture is no longer ignitable or
     reactive, or so that it no longer poses a threat to
     human health [$294.198(a)].   The inspector should
     carefully review the procedures used by the
     owner/operator to store/treat ignitable or reactive
     wastes in the tank system reviewing any relevant
     logbook entries and by questioning the
     owner/operator.

A. 2  The inspector should check the logbook or any other
     applicable records on site.

A. 3  The inspector should visually inspect the system to
     make sure that the temperature around the tank would
     not allow it to explode or that it is protected from
     any objects or chemicals that could cause a reaction.

A.4  Refer to Appendix B lOa-e for the National Fire
     Protection Association Standards for the distances
     that ignitable wastes (materials) must be from public
     ways and adjoining properties.

A. 5  The regulations stipulate that hazardous waste must not
     be placed in a tank system that has not been
     decontaminated and that previously held an incompatible
     waste or material unless steps have been taken to
     eliminate any risk to human health  [S264.199(b)].
     The inspector can only question the owner/operator and
     examine logbooks to answer this question.  Appendix
     B, 9a-f will provide information on incompatible waste
     types.
                               5-15

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                                                     OSWER 9938.4
   5.2.5  Release Response  [Checklist VI]

     The release response checklist will be used during the
record review and the visual inspection.  The inspector may wish
to take extra copies of the checklist to each site since a number
of tank systems may be identified as having a release during the
visual inspection, if not during the record review.

A.l-A.la
     The regulations require that, when there is a release
     to the environment of a quantity more than l pound, or
     any quantity that has not been immediately cleaned up,
     the owner/operator must notify the Regional
     Administrator within 24 hours of detection.  Within 30
     days of the release a report [as described in §264.196
     -(d)(3)] must be submitted to the Regional
     Administrator.  During the file review, the inspector
     should record the dates of each release for each tank
     system at a facility and the completeness of each
     report.  During the visual inspection, the inspector
     can verify that a release to the environment was or was
     not cleaned up.  The inspector should examine the
     notification for greater detail [§264.196(d)].

     The notification requirement is met if the release was
     reported pursuant to Part 302  (Designation, Reportable
     Quantities, and Notification).  In that case, the
     owner/operator should have some record of calling the
     National Response Center in Washington D.C.

A.2  Removal from service of the leaking tank component
     should be reflected in the owner/operator's logbook.
     Where a tank containing waste  is removed from service,
     the inspector should note what the owner/operator did
     with the waste and if there is documentation of the
     waste being shipped off-site or into another tank, etc.
     (S264.l96(a)J.

A.3  If the release was from the tank system, the
     owner/operator must remove waste within 24 hours of
     detection or:  a) the owner/operator must demonstrate
     that it is not possible to remove wastes in 24 hours
     and, b) at the earliest practicable time, remove as
     much waste as necessary to prevent further release of
     hazardous waste to the environment and to allow appro-
     priate inspection and repair.
                               5-16

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                                                     OSWER 99.38.4


      If material  is  released  to  the secondary containment
      system,  all  materials must  be removed in 24 hours or in
      as timely  a  manner  as is possible to prevent harm to
      human health and the environment.

A.4*  The  inspector should question the owner/operator about
      methods  used to contain visible releases to the
      environment.  In addition,  the inspector should check
      the  logbook  to  verify methods [§264.196(c) ].

A. 5   If the source of the release was a leak to the
      environment  from a component of a tank system without
      secondary  containment, the owner/operator must provide
      the component of the system from which the leak
     occurred with secondary containment before it can be
      returned to  service, unless the leak is an aboveground
     portion of a tank system that can be inspected
     visually [§264.196(e)(4)].

A. 6   If the owner/operator has made extensive repairs to a
     tank system  (e.g., installation of an internal liner,
     repair of a ruptured primary containment or secondary
     containment vessel) then the tank system may not be
      returned to service until the owner/operator has
     obtained certification by an independent, qualified,
     registered, professional engineer that the  repaired
     system is capable of handling hazardous wastes without
      release for the intended life of the system
      [§264.196(f)].   The required certification paragraph
     can be found in Appendix B-l.


5.3  Tank System Inspection

   5.3.1  Visual Inspection of Tank System [Checklist VII,
                                              Visual Inspection]

     After reviewing the inspection logs and other recordkeeping
requirements for the hazardous waste tank systems at a facility,
the inspector will want to see the system itself.   Depending upon
the system (e.g., above- vs.  underground, cement vs. metal),  the
inspector wi-11 be looking for different signs of non-qompliance
with  the regulations.  Obviously, the ability to visually inspect
underground tanks is severely limited.   Therefore, the
determination of  sound underground tank systems  will rely
primarily on records from tightness tests covered under
checklists III or IV.
                               5-17

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                                                     OSWER 9938.4
     Aboveground portions of tank systems can be examined by the
inspector. A complete description of how to conduct a thorough
external tank examination can be found in the OSWER Policy
Directive (see appendix D, No. 11).   This checklist provides an
easy reference to the inspector for points that should be noted
as evidence of potentially unfit tank systems.  Checklist Section
A is organized according to tank type (e.g.,  aboveground) and
tank materials (e.g., metal, FRP, concrete).   Section B covers
underground tanks.  Ancillary equipment, secondary containment,
and corrosion control are also covered.   This checklist should be
included for all tank systems except small quantity generators.
Not all sections of the checklist will be applicable to all tank
systems.

A.   §264.194(a) stipulates that hazardous waste cannot be
     placed in tanks if they can cause it to rupture, leak,
     corrode or otherwise fail.  The presence of any of the
     identified points in the checklist indicates that
     the tank may be corroding, leaking, rupturing or
     otherwise failing.

B.   Underground Tanks

B.I  If the underground tank system is a new system, the
     regulations require that the certified written
     assessment of tank integrity include a determination of
     design or operational measures that will protect the
     tank system against potential damage if the tank
     system is likely to be adversely affected by vehicular
     traffic [S264.192U) (4) ].

B.2  For new underground tank systems or components, the
     regulations require that the tank system must be
     provided witJi backfill material that is non-
     corrosive, porous, and homogeneous.  The backfill
     material must be placed completely around the tank and
     compacted to ensure that the tank and piping are fully
     and uniformly supported  [$264.I92(c)].  The inspector
     should make sure that the ground is not slumping in
     the area of the underground tank or that clays are not
     used as backfill material.

C.   Spill and Overfill Controls

C.I  The inspector should determine whether or not dry
     disconnect couplings are being used.  If they are not
     being used, the inspector should determine if the
     owner/operator is collecting and properly disposing of

                               5-18

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                                                     OSWER 9938.4
     any spilled/leaked materials.  Appendix B-15
     illustrates different types of couplings.

C.2  The inspector should determine that overfill prevention
     controls are present and in good working order.
     Appendix B-15 illustrates the elements of an overfill
     prevention system.

C.3  Small quantity generators are required to have at least
     60 cm (2 feet) of freeboard for uncovered tanks
     [§265.201(b)(3)].  This should be considered a
     minimum.

C.4  Evidence of overtopping or major spills would include
     staining/corrosion of paint on the tank or the tank
     surface itself.  Other evidence would include pooling
     of waste material in a diked area or non-point
     discharge of contaminated ground water into a surface
     water body if one is located nearby the tank system.
     If there is evidence of a release to the environ-
     ment include checklist VI (Release Response) for the
     tank system.

D.   The Inspection of Ancillary Equipment
     The inspector should ask the owner/operator to trace
     the inspection route from the process or unloading
     area to the tank where waste is stored or treated.
     The exit line from the tank system should also be
     covered by the inspector.  Note the presence of  any
     corrosion, ruptures or other indicators of system
     failure.

D.1-D.3
     The regulations require that all ancillary equipment  be
     tight and properly inspected and maintained.
     Ancillary equipment includes any device (e.g.,
     piping, pumps, valves, etc.) used to distribute, meter,
     or control the flow of hazardous waste from its  point
     of generation to a storage or treatment tank, between
     hazardous waste storage and treatment tanks to a
     point of disposal on-site, or to a point of shipment
     for disposal Off-site (§260.10).

E.   If a permitted facility changes its equipment, the
     facility is required to apply for a permit
     modification.  It is important that the inspector
     verify that the facility is using the same type  of
     equipment specified in the permit.
                               5-19

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                                                     OSWER 9938.4
F.   Secondary Containment

F.I  The regulations require that for liner systems and
     vault systems the secondary containment component must
     be able to hold 100 percent of the volume of the
     largest tank within its boundary [§264.193{e)(1)(i)  and
     (e),(2)(i)] to be designed and/or operated in such a
     way as to prevent the collection of run-on and
     precipitation from entering secondary containment
     unless sufficient excess capacity has been provided to
     contain precipitation from a 25-year, 24-hour rainfall
     event [§264.193tb)(1)(iir and (b)(2)(ii)].

     The inspector should do a rough calculation of the
     volume of the secondary containment by estimating the
     dimensions of the containment structure or by asking
     the owner/operator for the dimensions..  Ask the
     owner/operator if she/he knows or can refer to a
     document with the volume of run-on from a 25-year/24-
     hour rainfall event for this area.  If not, it is
     likely that the owner/operator has not taken into
     consideration the 25-year/24-hour-precipitation-event
     standard when designing the external liner or vault
     system.

F.2  The inspector should see if precipitation is collected
     in the secondary containment system.  If run-on or
     precipitation has collected in secondary containment,
     it must be removed within 24 hours [$264.193(c)(4)].
     Unless it has rained within 24 hours of the
     inspection, water in the secondary containment system
     constitutes a violation.

F.3  If there is water collected in secondary containment
     and it is contaminated, it must be managed as a
     hazardous waste.  Any hazardous waste leaked or
     spilled into the secondary containment system must also
     be removed within 24 hours (§264.196(B)(2)].

F.4  [S264.193(e)(3)].  Double-Walled Tanks

F.4a The inspector should determine what type of corrosion
     protection is being used.  Because these tank systems
     are typically underground, it may be that the
     inspector can only verify this in the records review.
     However, where portions of tank systems are
     aboveground, the  inspector may be able to verify that

                               5-20

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                                                     OSWER 9938.4
     corrosion protection is employed by examining the
     visually accessible portions of the outer shell for any
     blistering or rust or other signs of corrosion
     [S264.192(a)(3)(ii)J.

F.4b The inspector should examine any leak detection
     devices, if possible, to ensure that they are in good
     working order.

F.5  Vaults [S264.l93(e)(2)].

F.5a Secondary containment is required so as to prevent the
     release of hazardous wastes into the environment.
     Concrete is a porous material so the surface of any
     concrete that is used in secondary containment must be
     made impermeable, and must also, be compatible with the
     wastes stored/treated in the tank system
     [§264.193(b)(D, (b)(l)(iv) and (b)(2)(iv)].

     In addition, the inspector should review Appendix B.
     The table on B-5 provides information on the
     compatibility of lining types with particular
     chemical groups.  The table on B-6a and B-6b gives the
     general characteristics of impermeable barriers for
     concrete vaults.

F.6  Liners [S264.193(e)(1)].

F.6.a-d
     The inspector should see that the liner covers the
     surrounding earth to prevent lateral as well as
     vertical migration [$264.193(b) (IMiv) ].   In
     addition, the inspector should verify that the liner is
     free of cracks or gaps [5264.I93(b)(l)(ill)].  if the
     liner is concrete, there must be a protective coating
     or synthetic liner that is impermeable as well as com-
     patible with the waste material.

G.   corrosion Control
     The inspector should review Appendix B.  The table on
     B-13 describes several different types of localized
     corrosion and the table on B-14 describes environments
     which are corrosive to tanks constructed of different
     types of metals.  Several types of corrosion control
     devices are also illustrated.

G.I* If a tank is sitting in water it will corrode faster
     than if it is being operated in a dry environment.

                               5-21

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                                                     OSWER 9938.4
G.2  It is important that porous material such as dry
     crushed rock, gravel or sand be used as backfill
     material because it is less corrosive and promotes
     drainage and is more supportive.

G.3* Metal structures in close vicinity of the tank system
     (within 1 foot) may adversely affect the cathodic
     protection of a tank system.

G.4-G.7
     For additional information the inspector should refer
     to Chapter 5 of the OSWER Policy Directive
     (see appendix D, No. 11).

   5.3.2  Inspection of Closed Tank Systems [Checklist VIII,
                                  Closure, Post-Closure]

A.I  Tank systems with secondary containment may close under
     the requirements of §264.197(a) or §264.197(b).  If the
     owner/operator chooses to 'clean close1, the inspector
     should examine the site of the tank system to ensure
     that all waste residues and contaminated tank system
     components have been removed and that no contaminated
     materials or soils are left in the area.

B.I  If the owner/operator demonstrates that not all
     contaminated soils can be removed or decontaminated as
     required by the regulations, then the owner/operator
     must close the tank system and perform post-closure
     care as if. the tank system were a landfill
     [S264.197(b)1.

     The inspector should make sure that the owner/operator
     was unable to remove and decontaminate all wastes and
     components of the tank system.  For example, if the
     contamination is over an acre in area and is several
     feet deep, the contaminated soil would be too extensive
     to 'practicably' remove and dispose.

B.2a-B.2b
     The final cover must be designed to: minimize the
     migration of liquids into and through the tank system;
     function with minimum maintenance, promote drainage and
     minimize erosion; accommodate settling and subsidence;
     and have a permeability less than or equal to the
     permeability of any bottom liner or natural subsoils
     present [§264.310(a)].
                               5-22

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                                                     OSWER 9938.4
B.2c The inspector should refer to §264.97 (general ground-
     water monitoring"requirements).   The inspector should
     determine, through an inspection of facility records
     and a visual inspection, if there is a ground-water
     monitoring system in place and if it is adequate.

C.   Section 264.197(c) requires that if the owner/operator
     has a tank system that does not  have secondary
     containment requirements, the owner/operator must, in
     accordance with §264.193(g), develop a closure plan
     for removing all waste residues, contaminated
     containment system components, contaminated soils,
     structures and equipment [§264.I97(a)] and a
     contingency plan for closing the tank system as a
     landfill [§264.197(b)].

C.2  The contingency plans for closing a tank system as a
     landfill must be submitted with the permit application
     [§264.197(c)(2)].  The inspector should review the
     closure plan prior to the inspection if the tank system
     is permitted.   If the tank system has interim status,
     the inspector should make sure that the contingency
     plan is on file at the facility and is adequate.

     The cost estimates calculated for closure and post-
     closure care must reflect the costs of complying with
     the contingent closure plan and post-closure plans
     (that is, it must reflect the costs of closing the tank
     system as a landfill) if those costs are greater than
     closing the tank system by removing wastes and
     contaminated materials as specified under $264.197(a)
     [§264.197(c)(3)].

     In addition, financial assurance must be based on the
     highest of the two cost estimates for closure and
     post-closure care [S264.197 (c)(4)].

     For the purpose of the contingent closure plans, a tank
     system is considered a landfill and must comply with
     the closure, post-closure, and financial requirements
     for landfills under Subparts G and H of Part 264.
                               5-23

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                                                     OSWER 9938.4
6.0  POST-INSPECTION REVIEW

     Prior to leaving a "site inspection, the inspector should
inform the owner/operator of any violations that were observed.
The checklist, in addition to documenting violations, also flags
areas of concern.  With facilities that are permitted or applying
for a permit, these concerns can be brought to the attention of
the permit writer.  However, at other facilities, if there is no
direct violation, the areas of concern should be mentioned to the
owner/ operator prior to concluding the inspection.

     Because the inspector examines and collects a great deal of
data while inspecting a facility operating hazardous waste tanks,
it is imperative that the inspector carefully review and
summarize the information after conducting the inspection.  The
post-inspection review should be used to fill in any information
gaps (e.g. ,  if there was not proper documentation of the tank age
for an existing facility, age information may be available
elsewhere) to evaluate more complex information which could not
be evaluated on site (e.g., whether or not wastes are compatible,
or whether or not the environment is corrosive), and to summarize
any regulatory violations.

     A form is provided in Appendix A for inspectors to use to
summarize the results of the inspection.  The inspector should
ask himself/herself the following questions:

  o  Is the owner/operator maintaining complete files?
  o  Are the owner/operator's records verified by the visual
     inspection of the tank site?
  o  Will the owner/operator (existing tanks) meet the
     regulatory deadline for installing secondary
     containment?
  o  Were there any signs of unreported releases,
     particularly if they are not contained or cleaned up?

     Although a facility may not have violated specific
regulations, the inspector may have noticed conditions at the
facility which may indicate potential problems or violations.
The  inspector should note the following in the summary sheet:

  o  High resistivity or other indicators of high corrosion
     potential where metal tank components are exposed to
     the soil
  o  Poor maintenance
  o  Poor procedures for inspecting the tank system
  o  Incomplete, illegible, and/or inconsistent logbook
     notes.
                               6-1

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APPENDICES

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     APPENDIX A
INSPECTION CHECKLISTS

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             HAZAROOUS WASTE TANK  SYSTEM  INSPECTION GUIDANCE
                                                  Inspector Nane
Hazardous Waste Tank System Inspection
Checklist
                                                 Address  (Region)
                                                  telephone Number
                                                 Date of  Inspection
   Facility Identification
   A.I
            Facility Nane
   3.1           	  3.2
            Facility Address                            City
   8.3           	  8.4
            Stata                                       lip
   1.5	_____r___  R-6 	'
            Mailing Address (if different)County

   c.i	;	
            Nature of business; identification of operations

   0.1  '           	__
       "•    EPA 1.0. Number

   E.I	'  E.2  '           	
            Facility Contact                            Job Title

   P.3      (     )       	
            Contact Work Phone

   F.I  Identification of Hazardous Waste Tank Systems at this  Facility

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             HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE

             Hazardous Waste Tank System Inspection Checklist

I.  Snail Quantity Generators - Compliance  with  $  255.201

A.I                  	__   A.2
A.3
     Tank volume (gallons)                   • *"*  description
                                            (e.g.  aboveground,  steel,  lined)
     Tank location (e.g. inside on cement floor,  outside  on  aspnalt  pad
 .1  Material Stored:  3e as specific as poss:ble(  e.g.,  201
     chloride,- 301 1,1 ,-trichloroethane, 50% mineral  spirits)
     Hazardous *aste no.      description

8.2  Does this tank ever contain waste other than the above?
                                                                yes             no
      If so, list other waste:

      EPA Hazardous Waste Nunfce''      Wasta Description
                                                               yes            no
8.3  Are hazardous wastes placed in tanks  that  are  compatible
     with the waste so that the tank or inner liner nay  not
     fail prematurely?


C.I  Are wastes being stored in tanks for  greater than        	.	     	
     180 days?                                                 yes             no

C.2  Is the disposal site greater than 200 miles away?        	     	
                                                               yes            no

 C.3  Are wastes being stored in tanks for greater  than	    	
      270 days?                                                yes            no

 C.4  SQG, who store waste greater than 180 days  (270  days
      if shipped over 200 miles) or who exceed the  6,000  kg
      limit.  Has the owner/operator applied for  an
      operating permit?               .                      	    	
                                                                yes              no

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        Facility Id. 	   Tank  System Id.
I.  Small Quantity Generators - Compliance with  $ 265.201

C.5  Does the owner/operator inspect the tank  system routinely  for the
     following:

         Discharge control equipment each operating day    	
                                                              yes             no
         Data from monitoring equipment (e.g.  gauges)
         each operating day                                   y"elno"

         Level of waste in tank each operating day	     	
                                                              yes             no"
         Materials for signs of corrosion weekly            		
                                                              yes             no"
         Area around tank for spills or leaks  weekly	
                                                              yes             no"

3.  Special wastes

D.I Is the owner/operator storing iqnitable or reactive wastes so  that
    it does not generate heat, fire, violent reactions, gases that are
    flanmable, toxic dusts, or other means to  threaten human healtn?
           yes                 no                 NA

D.2 Does the owner/operator follow appropriate procedures for reactive
    of ignitabl* wastes? (See Special Wastes, Checklist VI)
           yes                 no                 NA

    Is the tank labeled  'Hazardous waste"?
                                                               yes            no

E.2 Tank Condition -  Indicate presence of any of the following

    discolored paint  or rust anywhere on tank system   _     _
                                                           yes            no
    blister, cracks,  bulges or other signs of
    potential  failure                                     yes            no

    worn  hoses,  rips In  liners,                          ,	     	
                                                           yes            no
 E.3 Does  the  area  around the tank show a-ny evidence
    of  spills (e.g.  discoloration, dead vegetation)?
                                                           yes            no
 E.4  Are  uncovered  tanks operating with a minimum of
     Z  feet  (60 cm) freeboard  or  are they equipped with
     containment structure?                    _____	    	
                                                RXyes             no

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        Facility Id.  	  Tank  System Id.
I.   Small  Quantity Generators - Compliance with $ 265.201

E.5  lo tanks *itn a continuous feed systems,
     is the system equipped «*ith a cut-off or
     by-pass system?
                                               NA         yes              no

F.   Preparedness and Prevention °lan Compliance

F.I  Is there an emergency response plan?             	      	
                                                          y*s              -no

c.l  Internal communication or ala«"i system available  	     	
                                                          yes               no

F.2  Is telephone or other device capable of summoning
     emergency assistance f^on local police, fire or
     other emergency response teams available?           •             	
                                                          yes               no

F.3  Are portable fire extinguishers and spill
     control equipment available and in operational   		
     condition?                                           yjs               no

-A  Water avai'aole to supply *ater hose streams      	      	
                                                          yes               no

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                       Facility Id.
             HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE
             Hazardous Waste Tank Syste
-------
          Facility Id.	    Tank  System  Id.
             HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE

             Hazardous Waste Tank System Inspection Checklist

III. Existing Tank Systems - Compliance with  §  264.191, 265.191

A.I                       	   A.2	
  '  Tank volume (gallons)Tank  type  (above-,on-,in-,below ground)

B.I  Material Stored:  Be as specific as possible  (e.g.,  20% Methylene
     chloride, 30% 1,1,-trichloroethane, 50%  mineral  spirits)

      EPA Hazardous Waste Number      Waste Description
C.   Secondary containment

C.I  Does this tank system have secondary containment?
                                                          yes            no
     If yes, see Checklist IV, if no continue below

C.2  Has facility been granted a variance from         	    	
     secondary containment?                               yes            no

C.3  Is a written assessment of tank system            	    	
     integrity on file?                                   yes            no

C.4  If assessment 1s provided, has it been reviewed and
     certified by a  registered, professional engineer?  	    	
                                                          yes            no

C.5        	   C.5a Documented  	     	
     Tank Ageyes             no
C.6                                      C.6a Documented
      Facility Age                                            yes             no

C.7
      Date when  secondary containment is required

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IH.  Existing Tank Systems - Compliance with  § 264.191,  265.191

0.    Design standards

0.1   The tank is constructed with:  (be as  specific  as  possible e.g.  fiberglass-
      reinforced plastic, mild steel,  nickel  based alloy).


0.2   Oocjment evaluates tank system in accordance with
      the most recent applicable design standards         	    	
                                                            yes              no
0.3   Is tank material generally compatible with waste?  	    	
                                                             yes              no


E..   Corrosion protection measures (applicable to tank  systems with metal  component
      in contact with soil or water)

E.l   Document describes existing corrosion protection
      measures?
E.2   Type of system employed (Coatings, Wraps, Electrical  isolation
      devices, Sacrificial-anode, Impressed-current)
F.    Non-enterable, underground tanks

F.la  Method of leak testing used 	
                                                             yes             no
F.lb  Verification of annual testing                      	     	
                                                             yes            no
F.lc  Tank found  to be tight                              	•        	
                                                             yes            no
 F.ld  Leak testing device accounts for following changes:
      Temperature                                         	     	
                                                             yes             no
      High water table                                    	     	
                                                             yes             no
       Tank end  deflection	     	
                                                             yes             no
       Vapor pockets                                       	        '
                                                             yes             no

 G.     Other  tank  types

 G.la  Method of  leak  testing  used 	
 G.lb   Verification of  annual  testing                      	     	
                                                             yes            no
 G.lc   Tank  found to be tight                              	     	
                                                             yes             no

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III. Existing Tank Systems - Compliance with  $  2fi4.191, 265.191

G.2  Internal Inspections

G.2a Certification by registered, professional  engineer
H.4  Have any of the leak tested tank system components
     been found to be leaking or unfit?
                                                           yes             no

G.2b Has the engineer checked and documented inspection
     of all appropriate factors?                        	     	
                                                           yes             no

H.   Tank ancillary equipment

H.I  Feed systems, Safety cutoff and/or bypass systems,
     pressure controls are described in written
     assessment                                         	     	
                                                           yes             no
H.2  Has ancillary equipment been leak tested or under-
     gone other approved integrity assessment annually?
                                                           yes             no
H.3  Method of leak testing used	'            	
                                                            yes             no
 If  any of the tanks  system components have failed the examinations or  leak
 tests, Release Response Checklist VI should be included for this  tank
 system.

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           Facility Id. 	  Tank  System Id.
             HAZARDOUS WASTE TANK SYSTEH INSPECTION  GUIDANCE

             Hazardous Waste Tank System Inspection  Checklist

IV.  New Tank Systems - Conpliance with  §264.192

A.   New Tank design

A.I                                      A.2
     Tank volume (gallons)                   Tank  typefabove-,on-,in-,be!ow  ground

4.3              	   A.4	
     Tank Dimensions:Tank  shape  (spherical,  cylindrical,et

A.5  The tank is constructed with: (be as specific as  possible e.g.  fiberglass-
     reinforced plastic, mild steel, nickel  based  alloy)


8.   Material Stored:  Be as specific as possible  e.g. (20% Methylene  •
     chloride, 30% 1,1,-trichloroethane, 50% mineral  spirits)

      EPA Hazardous Waste Number      Waste Description
C.  Tank System Installation

C.I Certification of inspection and supervision   	   	
    of installation and design by independent          yes                no
    installation expert or qualified engineer

C.2 Did the  Inspection Include the following: Weld breaks         	
                                              Punctures           	
                                              Scrapes on
                                              protective coating  	
                                              Cracks              	
                                              Corrosion	
                                              Other damage or
                                              inadequate construction	
 C.3 Has  a detailed  description of the installation 	     	
     been provided?                                   yes               no

 C.4 Has  the tank  passed a  test for tightness     	     	
     prior to being  covered or placed in use?          yes               no

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0.5 Type of leak detection equipment employed
0.6 Record of leak detection operation available?
                                                     yes               no
IV.  New Tank Systems


C.5 Has the ancillary equipment (e.g.
    piping) passed a test for tightness?


C.5 Has a detailed description of the tightness    	     	
    testing been provided?                            yes                no

0.  Secondary containment - Compliance with §264.193

0.1 Has the facility been granted a variance?      	      	
    If yes, go to Section F on this checklist.        yes                no

0.2 Is secondary containment for new tanks and
    ancillary equipment installed?                 	      	
                                                      yes                no
0.3 Secondary containment is:  (circle one)
    liner, vault, double-walled component

Q.4 Secondary containment materials are 	
                                                        yes               no
0.7 Have any leaks from the primary system into      	      	
    secondary containment been detected?                yes               no

n.3 Was leaked waste removed from the secondary      	      	
    containment system within 24- hours?                 yes               no

0.9 W-as the repair to the primary system documented
    prior to returning tank into service?            	      	
                                                        yes              no

E.  Exemption of secondary containment for tank systems or component   §264.193(f)

E.I Is all aboveground, straight piping that is
    not covered by secondary containment inspected
    daily?                                            	     	
                                                         yes             no
                                                          yes             no

 E.2  Are  all  welded  flanges,  welded  joints,  and
     welxled  connections  inspected  for  leaks  daily?     	     	


 E.3  Are  all  sealless  or magnetic  coupling punps
     visually inspected  for  leaks  daily?               	    	
                                                         yes              no
 E.4  Are  all  pressurized, aboveground  piping systems
     with automatic  shutoff  devices  visually
     inspected for  leaks daily?                       	    	
                                                         yes              no

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IV.  New Tank Systems


F.  External Corrosion Protection for metal  components  or  equipment   §264.192

F.I Has a corrosion potential assessment been prepared
    by a corrosion expert?                             	
                                                           yes              no
F.2 Type of corrosion protection installed  _____	_._
    (coatings, wraps, electrical Isolation devices,  sacrificial-anode,
    inpressed-current)

F.3 Has a corrosion expert supervised the              	    	
    installation of any field fabricated                   yes             no
    corrosion protection (e.g. cathotic-
    p.-otection devices)

If any of the tank system components have failed  tightness  testing or have
resulted in leaks that had releases outside the secondary containment,
Release Response Checklist VI should be includedvfor this tank  system.

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Facility Id.  	   Tank System Id.
             HAZARDOUS WASTE TANK-SYSTEM INSPECTION GUIDANCE

             Hazardous Waste Tank System Inspection Checklist

V.    Tank Systems that Store or Treat Ignitable or Reactive  Wastes

       Compliance with § 254.198

A.   Special Requirements for Ignitable or reactive wastes

A.I  Has waste been treated, mixed or otherwise rendered nonreactive
     or not ignitable  (except in emergency conditions) so that the
     mixture is no longer ignitable or reactive?
        yes .no

A.2  Has complete  chemical  identification of waste compatibility been
     determined prior  to mixing of wastes?
        yes                  no

 A.3   Is the  tank  protected  from conditions that may cause it to ignite
      (e.g. use  of spark  proof tools) or protected from contact with
      materials  that  may  cause it to react?
         yes                   no

 A.4   Is  the  required  National Fire Protection Association distance between
      waste management area  (ignitable wastes) and public ways and adjoining
      properties  maintained?
         yes                   no

 A.5  Has an  appropriate method of tank  system decontamination been
      selected based on the type  of waste  residues remaining in a
      receiving vessel?

         yes                   no

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         Facility Id. 	'            Tank  System Id.
                 HAZARDOUS WASTE TANK  INSPECTION  GUIDANCE


             Hazardous Waste Tank System Inspection  Checklist

VI.   Release Response - Compliance with § 264.195

A.I  Notification of releases to Regional  Administrator  (from  file  review)
     date:	  ..  description:	
A.la Did the 0/0 report to the Regional  Administrator within  30  days  of
     each release with the following information
     - likely route of migration of release
     - characteristics of surrounding soil
     - results of sampling
     - proximity to downgradient drinking water,  surface  water and population
     - description of response actions planned or taken                  :
        yes                  no                  N7A

A.2  Did the 0/0 immediately remove the tank component from service after
     spill/leak?
                             no            not able to veri fy          N/A

A.3  Was waste removed from leaking component of the tank  system and
     from secondary containment?
        yes                  no

A.4  Were visible releases to the environment contained?
        yes""                 no                  N?A


A.5  Has: secondary containment, repair, or closure of the tank system
     been provided?
        yes                  no                  N/A

 A. 6  Was the repair certified by an independent, qualified, registered,
     professional engineer?
        yes                  no

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      Facility Id. 	     Tank  System Id.
             HAZARDOUS WASTE TANK SYSTEM INSPECTION  GUIDANCE
             Hazardous Waste Tank System Inspection  Checklist
VII.  Visual  Tank System Inspection  General  Operating  Requirements  §264.194
A.   Above-ground Portions 5 264, 265.194(a)
A.I  Metal Tanks -
Look for:                                                     Indicate  Presence
             Gross leakage,                                         	
                                        •\
             Major corroded areas                                   	
             Deterioration  (e.g bl isters)                           	_____
             Discolored paint                          ^             	
             Cracks
             (nozzle  connections,  in welded seans, under rivets)
                   s and bulges
             Defective manhead gaskets
             Corrosion of  tank tops  or roofs
             Corrosion around nozzles and valves
             Erosion around  foundation,  pads and
             secondary containment
             Cracks  in concrete  curbing  and  ringwalls
             Rotting of wooden supports
             Welds and anchor bolts  between  tank bottoms
             and ringwal1s
             Deterioration of protective coatings  such  as
             discoloration and  film  lifting
 A.2   Fiberglass-Reinforced Plastic Tanks -
 Look for:
           Gross leakage
           Bending, curving or  flexing
           Longitudinal  cracks  In horizontal  tanks,
           Vertical cracks X1n vertical tanks

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         Facility Id.	  Tan*  System  Id._	

VII. Visual  Tank System Inspection



A.3  Concrete Tanks - Above Ground  Portions

Look for:                                                      Indicated Presence
          Gross leakage                                            	
          Cracks                                                   	___

          Porous areas permeable to liquid (wet spots)          .    	

          Deterioration of protective coatings such as
          discoloration and film lifting                           	

3.  Underground ta^ks  $254.192

B.I   Is the (new) tank protected from vehicular traffic  	   	
      (paving over tanks should extend at least 1 ft        yes        no -';    NT"
      beyond perimeter in all directions)                                 ;

3.2   If the backfill  is not covered, is it porous
      and homogeneous?                                    	   	  	
                                                          yes        no      NA
3.3   Is there water pooling or depressions in  the
      area of the tank?
                                                          yes        no      NA

 C.   Spill  and Overfill  Prevention Measures  §264.194

 C.I   Are  spill  prevention  controls  (e.g.  check  valves,
      dry  disconnect  couplings)  in ase?
                                                              yes-             no

 C.la Is there any evidence  of  spillage  from disconnect
      or uncoupling operations                               	    	
                                                              yes             no
 C.2  Are overfill prevention controls  (e.g. level  sensing
      devlcesv high, level  alarms)  present  and operational?
                                                              yes             no
 C.3  Is sufficient freeboard maintained in uncovered
      tanks to prevent overtopping due to wave or wind
      action or by precipitation?
                                                               yes             no

 C 4  Is there any evidence of overtopping or major spills   	     	
                                                               yes            no

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         Facility Id.
 Tank System Id.
VII. Visual  Tank System Inspection
0.   Inspection of Ancillary Systems  $ 264.194
0.1  Inspect piping for the fallowing:
          Pipe bends, elbows, tees, and other restrictions
          for.leaks, external corrosion and rust spots
          Deterioration (e.g Misters) and discolored paint
          Orifice plates deteriorated
          Throttle valves w/broken stems, missing handles
          Wear and tear in  flexible hoses
          Traffic passing ov»r noses
          Vibration or swaying of  pipe systems while punpfng
 0.2  Inspect  punps  and compressors  for the  following:
          Foundation cracks
          Excessive vibration or  cavitation of  pumps
          Laa'
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         Facility Id. 	  Tank  System  Id.


VII.  Visual  Tank System Inspection

F.   Secondary Containment § 264.193

F.I  Will the secondary containment  (liners  and  vaults)
     contain  100% of the design  capacity  of  the  largest
     tank in  its boundary  plus  a 25 yr-24 hr  rainfall?

F.2  Is water collected in secondary containment  system?
                                                                yes          no

F.3  Does any water in secondary containment  system  appear
     discolored or otherwise contaminated  or  is  there        	     •
     evidence of waste within the'containment system?            yes          no~

F.4. Double-walled tanks:   §264.193(e)(3)

F.4a If metal, is there appropriate corrosion protection          	   	
     for the outer shell?                                           yes       no~

F.4b Does it have an operational, built-in continuous
     leak-detection system?                                      	   	
                                                                   yes       no~
F.5  Vaults:§ 264.193(e)(2)

F.5a Does all concrete, including sumps, have liners or coatings? 	   	
                                                                   yes       no

F.5b Is a vault constructed with chemically resistant water  stops
     at all joints?               •                               	   	
                                                                   yes       no
F.5c Is there deterioration of protective  coatings such as
     discoloration and film lifting?                             	   	
                                                                   yes       no
F.5d Are there any cracks  visable in the concrete?                 	   	
                                                                   yes       no
F.6  Liners: § 264.193(e)(l)

F.6a Does the liner cover  all the surrounding earth  likely
     to come into contact  with wastes,  including berms and dikes? 	
                                                                  yes         no
F.6b If clay liners, do liners show signs  of drying  and
     cracking ?                                                 	      •
                                                                  yes        no
F.6c If polymeric liners,  do liners show signs of punctures
     deterioration due to  sun light, chemical spills,  rips,      	   	
     tears, gaps, or cracks?                                      yes        no

F.6d If a concrete liner,  is there any  deterioration of          	   	
     its protective coating?                                      yes        no

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          Facility  Id. 	 Tank System Id.
 G.7d   Is the impressed-current  system properly
.VII.  Visual  Tank  System Inspection

 G.    Corrosion  Control  (metal  tank "and  metal components in-on-or underground)

 •.1   Presence of  trapped water near  tank  system          	   	
      (If underground  tank system,  is water  pooling         yes           no
      in  area above tank location?)

 j.2.  The use of dry,  crushed  rock  or gravel  as
      backfill material                                   	   	
                                                           yes           no

 •"..3  Existence  of nearby visible metal  structures        	   	
                                                           yes           no

          Coat'ngs or wraps

       Is the coverage complete?                         	   	
                                                           yes           no
       Has the cover or wrap dried, cracked or
       dissolved?
                                                           yes           no
 •i.4c  Mas the coating or wrap been damaged by
       spills?                                           	  	
                                                           yes           no
 ft.5      Electrical isolation devices

 1.5a  Are they adequate depending upon the number of
       nearby, underground metal structures?             	  	
                                                           yes           no

 G.5b  Are the devices damaged in any way?	  	
                                                            yes            no
 G.6      Sacrificial-anode system

 G.6a  How long has it been in place?                     	  	
                                                            yes            no

 G.6b  Have the anodes decreased significantly in size?
                                                            yes            no

 G.6c  Is the sacrificial-anode system damaged?
                                                            yes            no
 G. 7      Inpressed-current system

 G.7a  How long has it been in place?                     	   	
                                                            yes            no

 Ti.7b  Have the current requirements changed over time?
                                                            yes            no

 G.7c  Is the impressed-current system damaged?
                                                            yes            no
       maintained?                                          yes           no

-------
          Facility Id.  	___   Tank  !
-------
                                           Facility  Id.	



                HAZARDOUS WASTE  TANK  SYSTEM INSPECTION GUIDANCE

                Hazardous Waste  Tank  System Post-Inspection Form


l..If existing tank systems are  present,  when  is  secondary containment required?

           Tank Id.            Hate Secondary  Containment  is Required
2. Description of Violation      Regulition Violated       Tank  Systen or Component

a.                 	    	
b.
d.
e.
3. Potential Problems
    If  the  facility if  applying for a permit, inspector should refer comments to
    permit  writer.  For all other facilities, inspector should discuss potential
    problems with owner/operator.


 4.   Enforcement Action Recommended

-------
    APPENDIX B
TECHNICAL APPENDIX

-------
                                   B-l
    A sample statement of the  form  required  by Sec.  264.192(g). Including the
Section 270.11(d) truthfulness  certification,  follows:

          I.  [Name],  have  supervised  a portion  of the  design or
    Installation  of  a  new  tank  system or   component   located  at
    [Address],  and owned/operated  by  CName(s)l.   Hy  duties  were:
    Ce.o.. orelnstallatlon Inspection, testing for tightness, etc.l.
    for the  following tank  system  components [e.g.. the  tank."Tent
    piping,  etc.],  as  required  by  the  Resource  Conservation and
    Recovery  Act   (RCRA)  regulatlon(s),  namely.   40   CFR   264.192
    [Applicable Paragraphs (I.e.. a-f)].

          I certify  under penalty  of  law  that  I  have  personally
    examined  and  am familiar with  the Information submitted  In this
    document  and  all  attachments and that,   based on  my  Inquiry of
    those  Individuals  Immediately  responsible   for obtaining  the
    Information, I  believe  that  the  Information  is true,  accurate,
    and complete.   I  an  aware that  there are significant penalties
    for submitting  false Information,  Including  the possibility of
    fine and Imprisonment.
                                     Signature
                                     Title
                                     Registration No., if applicable


                                     Address

    The certification  statements must be kept on file Indefinitely at the  tank
facility, as specified  In Sec. 264.192(g).

-------
                                  B-2A
                   NATIOHALLY ACCEPTED TANK DESIGN STANDARDS
Document Numbtr
AA-ASO-1
A A- ED- 3 3
AA-SAS-30
ACI-344R-70
ACI-350R-77
AISI-PS-268-685-5M
AISI-TS-291 -582-1 OM-N8
ANSI 896.1
API 128
API 120
API 12F
API 620
API 650
ASME BPV-VIII-1
ASTN 0 3299
Title
Aluminum Standards and Data, 1970-71
Engineering Data for Aluminum Structures
Specifications for Aluminum Structures
Design and Construction of Circular
Prestressed Concrete Structures
Concrete Sanitary Engineering Structures
Useful Information on the Design of
Plate Structures
Steel Tanks for Liquid Storage
Standard for Melded Aluminum-Alloy
Storagt Tanks
Specification for Bolted Tanks for Storage
of Production Liquids. 12th Ed.
Specification for Field Welded Tanks
for Storage of Production Liquids, 8th Ed.
Specification for Shop Welded Tanks for
Storage of Production Liquids. 7th Ed.
Recommended Rules for Design and Construction
of Large, Melded, Low-Pressure Storage Tanks
Welded Steel Tanks for Oil Storage
ASME Boiler and Pressure Vessel Code
Standard Specification for Filament-Mound
Date
1984
1981
1982
1970
1983
1985
1982
1981
1977
1982
1982
1982
1984
1980
1981
                         Glass-Fiber Reinforced Thermoset Resin
                         Chemical Resistant Tanks

ASTH D 4021              Standard Specification for Glass-Fiber           1981
                         Reinforced Polyester Underground
                         Petroleum Storage Tanks


Continued on next page.

-------
                                  B-2B
Document Number
AWWA-0100
NFPA 30
UL 58
Title
Standard for Helded Steel Tanks for
Water Storage
Flammable and Combustible Liquids Code
Standard for Steel Underground Tanks
Date
1984
1984
1976
                         for Flammable and  Combustible  Liquids

UL 80                    Standard for Steel  Inside  Tanks  for  Oil           1980
                         Burner Fuel

UL 142                   Standard for Steel  Aboveground Tanks for         1981
                         Flammable and Combustible  Liquids

UL 1316                  Standard for Glass-Flber-Relnforced  Plastic      1983.
                         Underground  Storage Tanks  for  Petroleum Products .

-------
                                B-3
   ORGANIZATIONS WITH UP-TO-DATE  INFORMATION ON DESIGN  STANDARDS
 Tht Alualnum Association (AA)
 818 Connecticut Avenue, N.M.
 Hashington. O.C.   20006
 (202) 862-5100

 American Concrete  Institute
   (ACI)
 22400 West Seven Mile Road
 Detroit. MI  48219
 (313) 532-2600
  American Petroleum Institute
  1220 L Street.  N.M.
  Washington.  D.C.   20005
  (202) 682-8000

  American Society for Testing
    and Materials (ASTM)
  1916 Race Street
  Philadelphia,  PA  19103
  (215) 299-5400
(API)
American Iron and Steel
  Institute 
1000 Sixteenth Street, N.H.
Washington. O.C.  20036
(202) 452-7190
American National Standards
  Institute. Inc. (ANSI)
1430 Broadway
New York. NY  10018
(212) 354-3300

National Fire Protection
  Association (NFPA)
Batterymarch Park
Cjulncy. MA  02269
Publications:  (800) 344-3555
'American  Society of Mechanical
   Engineers  (ASHE)
 Publications
 22 Law Drive
 Falrfleld. NJ   07007
 (201)  882-1167

 American  Mater  Works  Association
   (AHHA)
 6666 West Qulncy Avenue
 Denver. CO   80235
 (303)  794-7711

 Underwriters Laboratories.  Inc.  (UL)
 333 PfIngsten  Road
 Northbroo*.  IL  60062
 (312)  272-8800

-------
                                B-4A
        COMPATIBILITY OF MATERIALS OF CONSTRUCTION HITH VARIOUS  CHEMICALS
Material
Compatible Hlth
Incompatlblt Hlth
Minerals
    SuTfurlc.acId*1'
    Nitric acid
    Phosphoric acid
Organic Acids
    Acetic acid

Bases
    Sodium hydroxide
    Ammonium hydroxide
FRP<2>
Mild Steel
Rubber-lined
    Hydrochloric ac1d<3>     FRP
FRP«>
FRP
Concrete—slow disinte-
gration at 101 phosphoric
acid

FRP
FRP
Mild steel<5>
Concrete (101)
Concrete (101)
Mild steel
concrete. Including
steel at 101-371
hydrochloric acid

M11d steel concrete.
with 21 and 401
Nitric acid

M1Id steel
Mild  steel


Mild  stee1<5>



Mild  steel<5)
                             Concrete
Sources:   "Permit Mrlter's Guidance  Manual  for Hazardous  Haste  Tanks".  U.S.
Environmental  Protection Agency. EPA Contract  68-01-6515 (undated  draft),  pp.
8-5 through 8-4.

"Effects  of  Substances  on Concrete  and  Guide  to  Protective   Treatments,"
Portland Cemtnt Association (1981). pp. 7-11.

Footnotes at end of table.

Continued on next page.

-------
                                 B-4b
Material
Compatible Hlth
Incomoatlble Hlth
Aqueous Salts
    Calcium chloride
    Sodium sulfate
    Copper sulfate



    Ferric chloride



    Sodium hypochiorlde

    Stannous chloride


    Sodium chloride
FRP
Concrete (If concrete
Is alternately wet and
dry with the solution.
then calcium chloride
can Induce slow disinte-
gration).

FRP  -
Concrete—d 1 s 1 ntegrat! on
of concrete with inade-
quate sulfate resistance.
Concrete products cured
In high-pressure steam
are highly resistant to
sulfates.

FRP
Concrete—slow
disintegration

FRP
Concrete—slow
disintegration

Special metal alloys

Noble metals
Stainless steel to 501

FRP
Concrete—unless concrete
Is alternately wet and dry
with the solution.
Mild steel<7>
Mild steel
M1ld steel



Mild steel



Mild steel

FRP


Mild steel
Footnotes at end of table.

Continued on next pagt.

-------
                                  B-4c
Material
Compatible Hith
Incompatible With
Aqueous Salts (Continued)
    AlUM
Solvents
    Perchloroethylene
    Carbon tetrachlorlde
    Ethyl alcohol (11)
    Methyl ethyl Ketone
    Acetone
Miscellaneous
    Benzene
    Hexane

    Aniline
FRP
Concrete—disintegration
of concrete with  Inadequate
sulfate resistance.   Con-
crete products cured 1n
high-pressure steam  are
highly resistant  to  sul-
fates.
FRP(8)
Concrete*^

FRP<10)
Concrete*9*

Mild steel/ Stainless
steel,  Concrete

FRP(12)
Concrete

FRP<14)
Concrete; however,
acetone nay contain
acetic acid as Impurity.
FRP(16)
Concrete

Mild stee1(17)

Stainless stee1('8>
Mild steel
Mild steel


Mild steel
Mild steel <13)


M11d steel(15>
Mild  steel
 FRP

 FRP
 Mild  steel
Footnotes at end of table.

Continued on next page.

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                                  B-4D
MattHal
Compatible Hlth
Incomnatlble Hlth
Miscellaneous (Continued)
    Nitrobenzene
    Phenol




    Chlorobenzene


    Naphthalene

    Benzole acid


    Olethyl amlne

    Formaldehyde
FRP<19>
Hi Id steel                   FRP

H11d steel
Stainless steel
Concrete—slow disinte-
gration

Mild steel
Stainless steel

Mild steel<20)               FRP<21>

Special metals               Hi Id steel
(nickel-base alloys)

Hfld steel<22)

FRP                          Hi Id steel
Stainless steel
Concrete—Slow disin-
tegration due to formic
acid formed In solution
                                     NOTES:
 (1)  Needs the attention of a  corrosion  specialist.   FRP Is good  up to  701
      concentration.  HI Id steel (H.S.) is  good  for concentrations  from  93% to
      981.

 (2)  Fiberglass-reinforced  plastics   (FRP)  have   been   considered   here.
      However, there art fiberglass-reinforced epoxy  resins  available that are
      not considered 1n this  table.
Continued on next page.

-------
                                  B-4E
                                     NOTES:
 (3)  FRP  Is  good  to  301  concentration.   No  organic  solvents  should  be
      present.   The  National   Association  of  Corrosion  Engineers  (NACC),
      Houston. TX, has a  graph  for the compatibility of various metals for HC1
      use.
 (4)  FRP Is good to 151 concentration.
 (S)  M.S. 1s good  only  to  25'C.   316 stainless steel  (S.S.)  1 s  recommended
      for service conditions about 25'C.
 (6)  FRP Is good to about SOt concentration.
 (7)  M.S. Is Incompatible after about 51 concentration at 100*C.
 (8)  FRP 1s good to about 25'C.
 (9)  Impervious  concrete  Is required to prevent  loss  from penetration,  and
      surface treatments are generally used.
(10)  FRP 1s good to about IZS'C.
(11)  FRP Is good for 951 concentration and 21* to 66*C.
(12)  FRP is good from 10* to 35'C.
(13)  M.S. Is incompatible for concentrations below 1001.
(14)  FRP Is good for 101 concentration and 21* to 79.5'C.
(15)  M.S. Is Incompatible for concentrations below 1001.
(16)  FRP 1$ good fro* 10* to 32*C.
(17)  M.S. Is good for 1001 solvent to 100'C.
(18)  S.S. Is good to 1001 concentration.
(19)  FRP Is good for 51 concentration and 21* to 52*C.
(20)  M.S. Is good to 1001 concentration.
(21)  FRP Is  good  for  only 1001 concentration and  21* to 27*C;  therefore.  It
      Is listed as Incompatible.
(22)  M.S. Is good only at 1001 concentration and up to 100*C.

-------
                                  B-5
                          COATING/LINING VS. CHEMICALS
   Coating/Lining Material
Generally Incompatible Hlth
   Alkyds



   Chlorinated rubbers

   Coal  tar epoxy

   Epoxy (aralne cured, polyamide
     cured, or esters)

   Polyesters


   S111 cones
Strong  mineral  acids, strong  alkalies.
alcohol, ketones,  esters,  aromatic hydro-
carbons

Organic solvents

Strong organic solvents

Oxidizing acids (nitric add),
ketones

Oxidizing acids, strong alkalies, miner-
al acids, ketones. aromatic hydrocarbons

Strong  mineral  acids,  strong  alkalies,
alcohols, ketones. aromatic hydrocarbons
   Vinyls (polyvlnyl chlorlde-PVC)      Ketones, esters, aromatic hydrocarbons
Source:   New York  State  Department of Environmental Conservation,  "Technology
         for  the  Storage  of  Hazardous   Liquids—A State-of-the-Art   Review"
         (January 1983).  p.  36.

-------
       GENERAL CHARACTERISTICS OF IMPERMEABLE BARRIERS FOR CONCRETE VAULTS
Severity
Of Chemical
Environment
Total Nominal
Thickness Ranqe
Typical Protective
Barrier Systems
Tvolcal Uses
Mild
Under 40 mil
(1 on)
Intermediate
125 to 375 mil
(3 to 9 mm)
Severe
20 to 250 nil
(1/2 to 6 n»>
Polyvlnyl butyral,
polyurethane, epoxy,
acrylic, chlorinated
rubber, styrene-
acryllc copolymer.

Asphalt, coal tar.
chlorinated rubber,
epoxy, polyurethane,
vinyl, neoprene, coal
tar epoxy, coal tar
urethane.
Sand-filled epoxy,
sand-filled polyester,
sand filled poly-
urethane, bituminous
materials.
Glass-reinforced
epoxy, glass-
reinforced polyester.
precured neoprene
sheet, plastlclzed
PVC sheet.
o Protection against
  delclng salts.

o Improve freeze-thaw
  resistance.

o Prevent staining of
  concrete.

o Use for high-purity
  water service^

o Protect  concrete  In
  contact  with  chemi-
  cal  solutions having
  a pH as low as 4, de-
  pending on the chemi-
  cal.

o Protect concrete
  from abrasion and
  intermittent exposure
  to dilute acids In
  chemical. dairy, and
  food processing
  plants.

o Protect concrete
  tanks and floors
  during continuous or
  Intermittent  Immer-
  sion, exposure to
  water,  dilute acids.
  strong  alkalies,  and
  salt solutions.
Source:  American  Concrete  Institute, "A  Guide  to the  Use  of  Waterproofing.
         Oampprooflng,   Protective   and   Decorative   Barrier   Systems   for
         Concrete." 515.1R-79. (1984), p. 29.

Note.—Reprinted with permission from Ad.

Continued on next  page

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                                B-6B
Severity
Of Chemical
Environment
Total Nominal
Thickness Ranqe
Typical Protective
Barrier Systems
Tvolcal Uses
Severe
20 to 280 mil      Composite  systems:

                  a)   Sand-filled  epoxy
                      system topcoated
                      with a plgmlnted
                      but unfilled epoxy;
                      and
                                b)   Asphalt  membrane*
                                    covered  with  acid-
                                    proof brick using
                                    a chemical resist-
                                    ant mortar.
o Protect concrete
  tanks during continu-
  ous or .Intermittent
  Immersion, exposure
  to water, dilute
  adds, strong
  alkalies,   and   salt
  solutions.

  Protect concrete from
  concentrated acids or
  acid/solvent combina-
  tions.
   OtherMnembranes may be used depending on chemical  environment.

-------
                                B-7A
                     CHECKLIST FOR TAN< INTERNAL INSPECTION
                              (Tank Out of  Service)
Solid Steel Tanks

(1)  Roof and Structural Supports (visual first for safety)
          no hazards of falling objects
          corrosion

(2)  Roof and Structural Supports (more rigorous)
          loss of metal thickness
          cracks, leaks at welds
          cracks at nozzle connections
          malfunctioning of floating roof seals
          water drain  system deterioration
          hammer testing, 1f necessary

(3)  Tank Shell
          cracks at seams
          corrosion of vapor space and liquid-level line
          cracking of  plate joints
          cracking of  nozzle connection joints
          loss of metal thickness

(4)  Tank Bottom
          corrosion pits
          cracked seams
          rivets for tightness and corrosion
          depressions  In bottom areas around or under roof and pipe supports
          bottom thickness
          uneveness of bottom
          hammer testing and bottom sampling. If necessary
     --   general condition of liner (holes,  cracks,  gaos,  corrosion, erosion,
          swelling, hardness, loss of thickness)
          bulges, blistering, or spalllng
     —   spark testing of rubber, glass, and organic type coatings
          ultrasonic examination of  steel  outer shell thickness.  If  possible,
          If any deterioration Is suspected.


Source:   "Permit Writer's  Guidance Manual  for Hazardous  Haste  Tanks,"  U.S.
          Environmental  Protection   Agency,  EPA  Contract  68-01-6515 (undated
          draft), pp.  8-10 and 8-11.


Continued on next page.

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                                 B-7B
Lined Steel Tanks*

(1)  Central condition of lining
     —holes
     —cracks
     —gaps
     —corrosion
     —swelling
     —hardness
     —loss of thickness    .

(2)  Proper positioning of liner


Flberqlass-relnforced-plastlc Tanks

          softening,  (dentations,  cracks,  exposed  fibers,  crazing,  checkings
          lack of surface resin,  and delami nation
          sufficiently  translucent,  discolored,  porous,  air or  other bubbles
          visible, other Inclusions, and  thin  areas
          hardness testing of specimens exposed to liquid contents
          ultrasonic  examination of laminate  thickness,   If  possible.  If  any
          deterioration is suspected In the polyester matrix.
•Tanks  may  be  lined  with alloy  steel,  lead,  rubber,  glass,  coatings,  or
concrete.  The Inspection procedures and locations  noted  for solid steel tanks
are equally applicable to lined tanks.

-------
                                   B-8
                 COMPARISON OF VARIOUS LEAK-SENSING TECHNIQUES
  Sensor
      Applications
    Advantages/Disadvantages
Thermal-
Conducttvtty
Sensors
Can monitor liquids In
soils
Primary advantage .is early
detection,  which makes it
possible for leaks  and spills
to  be  corrected  before  large
volumes  of  material  are  dis-
charged.
Electrical-
Resistivity
Sensors
Can monitor liquids In
sot Is
Primary advantage Is the
early detection of spills.
Once  a  leak  or  spill  is  de-
tected,  the  sensors  must  bt
replaced.   Can   detect  small
and largt leaks.
Vapor
Detectors
Monitors vapor in areas of
highly permeable, dry soil,
such as excavation backfill
or other permeable soils
Very useful for quick detec-
tion of highly volatile
wastes.
Interstitial
Monitoring  In
Double-Hailed
Tanks
Measures changes of pressure
or the Interstitial presence
of liquids In double-walled
tanks
Accurate  technique which  Is
applicable  to all double-
walled  tanks.
SOURCE:  New  York  State Department of  Environmental
         for  the  Storage  of  Hazardous  Liquids—A
         (January  1983). p. 92.
                                     Conservation.  "Technology
                                     Stite-of-the-Art Review"

-------
                                 B-9A
                            LIST OF CHEMICAL CLASSES
      Chemical
    Class  Number       ^____	Class Name
          1         Acids,  mineral,  non-oxidizing
          2         Acids,  mineral,  oxidizing
          3         Acids,  organic
          4         Alcohols  and  glycols
          5         Aldehydes
          6         Amides
          7         Amines, aliphatic  and  aromatic
          8         Azo compounds,  dlazo compounds and hydrazlnes
          9         Carbamates
         10         Caustics
         1)         Cyanides
         12         Dlthlocarbamates
         13         Esters
         T4         Ethers
         IS         Fluorides,  Inorganic
         16         Hydrocarbons, aromatic
         17         Halogenated organtcs
         18         Isocyanates
         19         Ketones
         20         Mercaptans  and other organic sulfldes
         21         Metal compounds. Inorganic
         22         Nitrides
         23         Nitrites
         24         Nltro compounds
         25         Hydrocarbons, aliphatic, unsaturated
         26         Hydrocarbons, aliphatic, saturated
         27         Peroxides and hydroperoxldes.  organic
         28         Phenols and cresols
         29         Organophosphates.  phosphothloates,  and phosphodlthloates
         30         Sulfides, Inorganic
         31         Epoxldes
         32         Combustible and flammable materials
         33         Explosives
         34         Polymtrlzable compounds
         35         Oxidizing agents,  strong
         36         Reducing agents, strong
         37         Hater and mixtures containing water
         38         Water reactive substances
Source:  "A  Method  for  Determining  the  Compatibility  of  Hazardous  Hastes'
         (Hatayana et al., 1980).

-------
                                 B-9B
                   LIST OF CHEMICAL REPRESENTATIVES BY CLASS
Class 1   Acids,  mineral, non-oxidizing    Class S  Aldehyde (AH  IsomersT
    Boric Add
    Chlorosulfonlc  Add
    HydHodlc Acid
    Hydrobroalc Add
    Hydrochloric Add
    Hydrocyanic Acid
    Hydrofluoric Add
    Hydroldlc Add
    Phosphoric Acid

Class 2  Adds, ml rural, oxidizing

    Chloric Add
    Chronic Add
    Nitric Add
    01tu«
    Perchloric Add
    Sulfur 1c Add
    Sulfur Trloxlde

Class 3  Adds, organic  (All  Isomers)

    Acetic Add
    Benzole Acid
    Formic Add
    Lactic Add
    Halelc Acid
    Olelc Acid
    Salycllfc Add
    Phthallc Acid

Class 4  Alcoholi and  qlvcols (All
         ISOMFS)
    Allyl Alcohol
    Chlorethanol
    Cyclohtxanol
    Ethanot
    Ethylene Chlorohydrln
    Ethylene Glycol
    Ethylene Glycol  Honomethyl Ether
    Glycerin
    Methanol
    Monoethanol Amtne
    Acetaldehyde
    Formaldehyde
    Furfural

Class 6  Amides (All Isomers)

    Acetamlde
    01 ethyl amide
    01 methy1formanl de

Class 7  Amines, aliphatic and
         aromatic  (All Isomers)

    Amlnoethanol
    Aniline
    01ethylamine
    Olamlne
    Ethylenendlaalne
    Methyfamine
    Monoethylanolamlne
    Pyrldlne

Class 8  Azo  compounds, dlazo
         compounds and hvdrazlnes

    Dimethyl  Hydrazlne
    Hydrazlne

Class 9  Carbamates

Class 10  Caustics

    Ammonia
    Ammonium  Hydroxide
    Calcium Hydroxide
    Sod luii Carbonate
    Sodium Hydroxide
    Sodium Hypochlorlte

Class 11  Cyanides

    Hydrocyanic  Acid
    Potassium Cyanide
    Sodium Cyanide
Continued on next page.

-------
                                   B-9C
Class 12  Dlthiocarbamates

Class 13  Esters (All Isomtrs)

    Butyl Acetat*
    Ethyl Acetate
    Methyl Acrylate
    Methyl Formate
    Dimethyl Phthalate
    Proplolaetone

Class 14  Ethers (All Isomers)

    Dlchloroethyl Ether
    Oloxane
    Ethylene Glycol Monomethyl Ether
    Furan
    Tetrahydrofuran

Class 15_ Fluorides. Inorganic

    Aluminum Fluoride
    Ammonium Fluoride
    Fluoroslllclc Acid
    Flucslllc Add
    Hydrofluorosillcic Acid

Class 16  Hydrocarbons, aromatic (All
          Isomers)

    Benzene
    Cumene
    Ethyl Benzene
    Naphthalene
    Styrent
    Toluene
    Xylene

Class 17  Hi]oqenated organ 1 cs (All
          Isomers)

    Aldrin
    Benzyl Chloride
    Carbon Tetrachlorlde
    Chloroacetone
    Chlorobenzene
Class 17  Hal oqenated organ IcslATi
          Isomers)  (Continued)

    Chlorocresol
    Chloroetha.no!
    Chloroform
    01Chloroacetone
    01chloroethylether
    Oichloromethane (Methylene
      Olchlorlde)
    Eplchlorohydrln
    Ethylene Chlorohydrln
    Ethylene Ofchlorlde
    Freons
    Methyl chloride
    Pentachlorophenol
    Tetrachloroethane
    Trtchioroethylene

Class 18  Isocvanates (All Isomers)

Class 19  Ketones (All Isomers)

    Acetone
    Acetophenone
    Cyclohexanone
    Dimethyl Ketone
    Methyl Ethyl  Ketone
    Methyl Isobutyl Ketone
    Qulnone (Benzoqulnone)

Class 20  Mercaptans and other
          organic sulfides (ATT
          Isomers)

    Carbon Dlsulfldt
    Ethyl Mercaptan

Class 21  Metal compounds, inorganic

    Aluminum Sulfate
    Chronic Acid
    Sliver Nitrate
    Tetraethyl Lead
    Zinc Chloride
Continued on  next page.

-------
                                  B-9D
Class 22  H1tr1dei:

Class 23  Nitrites

    Acrylonltrlle

Class 24  Nltro compounds (All Isomers)

    Nltrobenzent
    N1trophenol
    Nttropropane
    Nltrotolutnt
    Picric Acid
Class 25  Hydrocarbons. a]1ohatlc.
          unsaturated (All Isoaers)

    Butadlent
    Styrent
Class 26  Hydrocarbons, aliphatic.
          saturated
    Butane
    Cyclohexane
Class 27  Peroxides and hydroperoxldes.
          organic
    Benzoyl Peroxide
    Hydrogen Peroxide
    Chlorocresol
    Coal Tar
    Cresol
    Creosote

Class 28   Phenols and  cresols

    Hydroqulnone
    Mltrophinott
    Phenol
    Picric Add
    Resorclnol
Class 29  Orqanophosphates.  ohospho-
          thloates.  and  phosphodl-
          thloates

    Malathlon
    Parathlon

Class 30  Sulfides.  Inorganic

Class 31  Eooxldes

    Eplchlorohydrln

Class 32  Combustible and flammable
          materials
    Diesel Oil
    Gasoline
    Kerosene
    Naphtha
    Turpentine

Class 33  Explosives

Benzoyl Peroxide
    Picric Add

Class 34  Polymerlzable compounds

    Acrylonltrlle
    Butadiene
    Methyl Acrylate
    Styrene

Class 35  Oxidizing agents, strong
    Chloric Acid
    Chronic Acid
    Silver HHratt
    Sodium Hypochlorlte
    Sulfur Trloxlde

Class 36  Reducing agents,  strong

Olamlne
Hydrazlne
Continued on  next  page.

-------
                                   B-9E
Class 37  Hater and mixtures containing
          water

    Aqueous solutions arid mixtures
    Hater

Class 38  Hater reactive substances

    Acetic Anhydride
    Hydrobromlc Acid
    Sulfurlc Acid
    Sulfur Trloxide
SOURCE:  "A  Method  for  Determining  the  Compatibility of  Hazardous  Hastes"
         (Hatayama  et  al.,  1980).

-------
•"
     *•«•.<>»•—i
    Cf.
                          MfMO II
                           F' r a
                                    JS/Sfl
                                                 si
                                         • ITUtKttT
                                                                                 ri
                                                                                                                         <:••»•"> imr «M»T«M
                                                                        »O •OT»'IWHM «»TO«MC«tB> »MH IMT»HMtl
                                                                                  B-9F

-------
                               B-10A
               STABLE  LIQUIDS—OPERATING PRESSURE 2.5 PSIG or LESS
Type of Tank   Protection
               Minimum Distance In Feet
               from Property Line Hhlch
               Is or Can Bt Built Upon,
               Including the Opposite
                 Side of a Public Hay.
                 and Shall Not Be Less
                     Than 5 Feet
                                       Minimum  Distance  In  Feet
                                       from  Nearest  Side of Any
                                           Public Hay or  from
                                           Nearest  Important
                                          Building  on the Same
                                       Property and  Shall Not  Be
                                           Less Than S Feet
Floating
Roof1
 Protection
 for Exposure2

 None
               1/2 times diameter  of
               tank

               Diameter of tank but
               need not exceed 175 ft.
1/2 times diameter of
tank

1/2 times diameter of
tank
Vertical
with Heak
Roof to
Shell S«a«3
 Approved foam  1/2 times  diameter of
 or Inert!ng    tank
 system4 on
•tanks not
 exceeding
 150 ft. In
 diameter'

 Protection     Diameter of tank
 for Exposures2
              None
                2  times diameter.of
                tank but need  not
                exceed 350 ft.
                                        1/2  times diameter of
                                        tank
                                        1/2 times diameter of
                                        tank

                                        1/2 times diameter of
                                        tank
Horizontal
and Vertical
with Emer-
gency Relief
Venting to
Limit Pres-
sures to
2.S pslg
                1/2 times  Table  13-7
Approved
InertIng
system4 on
the tank or
approved
foui system
on vtrtlcal
tanks
              Protection     Table 13-7
              for Exposures2
1/2 times Table  13-7
              None
                2 times Table 13-7
                                        Table 13-7


                                        Table 13-7
Footnotes and source on following page;

-------
                                    B-10B
1    Aboveground tank which  Incorporates either:   (1)  a  pontoon or double deck.
    metal  floating  roof In an  open top  tank  In accordance with API Standard
    650; or (2) a fixed metal  roof  wUh ventilation at  the  top and roof eaves
    In  accordance  with API Standard  650  and containing a metal 'floating roof
    or  cover  meeting   the  requirements  of (1)  or  a   metal   floating  cover
    supported  by  llguld-tlght  metal  pontoons  or floats  capable of providing
    sufficient  buoyancy to prevent sinking of  the  cover  when  half   of   the
    pontoons or floats are punctured.

2   Fire protection  for structure  on  property  adjacent  to liquid storage shall
    be  acceptable  when  located:   (1)  within  the jurisdiction  of  any public
    fire department;  or (2)  adjacent  to plants  having private fire brigades
    capable  of providing  cooling  water  streams on   structures  on property
    adjacent to liquid  storage.

3   Aboveground  storage tank  with some  form  of construction or device  that
    will relieve  excessive internal  pressure   caused by fires.   Construction
    shall  tak« the  form of a weak roof-to-shelf seam  to fall  preferential to
    any other  seam.

4   See NFPA 69, Explosion Prevention Systems.

5   For  tanks  over  ISO feet  in diameter,  use  "Protection  for  Exposures" or
    "None" as  applicable.

SOURCE:  Table 2-1,  "(NFPA) 30:  Flammable and Combustible Liquids Code 1984."

SI Units:  1 foot -  0.30 meters.

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Type of Tank   Prottctlon
                B-10C


               M1 .    M1 „             Minimum Distance \n Feet
               Nlnliwfl Distance In Feet fro« Nearest Side of Any
               fro* Property Line Hhlch    Pub Me Hay or from
               Is or Can St Built Upon.    Nearest Important
               Including the Opposite     Building on the Same
                Side 'of a Public Hav	Property
            STABLE LIQUIDS-OPERATING PRESSURE GREATER THAN  2.5  PSIG
ANY TYPE
Protection     1-1/2 tines Table A
for            but shall not be less
Exposures2     than 25 feet

None           3 tines Table A    but
               shall not be less than
               50 feet
1-1/2 times Table 13-7
but shall not be less
than 25 feet

1-1/2 times Table 13-7
but shall not be less
than 25 feet
                                BOIL-OVER LIQUIDS
Floating
Roof1
Fixed Roof
Protection      1/2 times diameter of
for Exposure2  tank
              None
                Diameter of tank
Approved Foam   Diameter of tank
Or Inertlng
Systee£

Protection      1/2 times diameter of
for Exposure?  tank
              None
                Diameter of tank
  1/6 times diameter of
  tank

  1/6 times diameter of
  tank

  1/3 times diameter
  of tank
  2/3 times diameter of
  tank

  2/3 times diameter of
  tank
1   See definition, footnote 1. page B-lOb

2   Fire  protection  for  structures  on  property  adjacent  to  liquid  storage
    shall  bt  acceptable  when  located:   (1)  within the  jurisdiction of  any
    public  fire  department;  or  (2)  adjacent  to plants  having  private  fire
    brigades  capable  of  providing  cooling  water  streams  on  structures  on
    property adjacent  to liquid storage.

3   See NFPA 69.  "Explosion Prevention Systems."

Source:  Table 2-3. "(NFPA) 30:  Flammable and Combustible Liquids Code 1984."

         Table 2-2. "(NFPA) 30:  Flammable and Combustible Liquids Code 1984."

SI Units:  1 ft. • 0.30 m.

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UNSTABLE LIQUIDS
        Type of Tank
        Horizontal
        and Vertical
        Tanks with
        Emergency
        Relief Vent-
        Ing to Permit
        Pressure Not
        In Excess of
        2.S pslg
 Protection
                                           B-10D.
    Minimum Distance In
     Feet from Property
    line Which Is or Can
   Be Built Upon, Includ-
     ing the Opposite
    Side of a Public Hav
 Minimum Distance  In
  Feet from Nearest
  SUe of Any  Public
 Hay  or From  Nearest
  Important Building
 on the Same Property
 Tank protect-
 ed with  any
 one of the
 following:
 approved water
 spray: approv-
 ed  tnerttng;'
 approved Insu-
 lation and
 refrigeration;
 and approved
 barricade

 Protection for
 Exposures2
                         None
  page B-lOebut not
    less than 25 feet
Not less than 25 feet
   2-1/2 times page B-lOe Not less  than  50 feet
   but not less than
   50 feet

   5 times page  B-lOe but Not less  than  100 feet
   not less than 100 feet
           Horizontal
           and  Vertical
           Tanks with
           Emergency
           Relief Vent-
Tank protect-
ed with any
one of the
following:
approved water
2 times page B-lOe but
not less than 50 feet
Not less than 50 fee
           Ing to Permit spray;  approy-
           Pressure Over ed Inertlng;'
           2.5 pslg      approved Insu-
                         lation  and
                         refrigeration;
                         and approved
                         barricade
                         Protection for  4  times page B-lOe
                         Exposures2     but not less than
                                        100 feet
                         None
               8 times page  B-lOe but
               not less than  150  feet
                                           Not less than 100 feet
                            Not less than 150 feet
         1    See  "NFPA  69.  Explosion  Prevention Systems.*

         2    Fire protection for structures on property adjacent to liquid storage shall
             be acceptable  when located:  (1) within the Jurisdiction of any public  flrt
             department;  or (2> adjacent to plants having private fire brigades  capable
             of  providing  cooling  water  streams  on structures  on  property adjacent  to
             liquid  storage. \

         SOURCE:   Table 2-4.  -
-------
                                    B-lOe

                           Reference Table A


                               CLASS IIIB LIQUIDS
                         Minimum Distance In Feet
                         from Property Line Which
                         Is or Cm Be Built Upon,
                          Including the Opposite
                          Minimum Distance  In  Feet
                          from Nearest Side  of Any
                             Public Hay or  from
                             Nearest Important
                            BuiIdtng on* the  Same
Caoacltv (Gallons)
12,000 or Less
12,001 to 30,000
30.001 to 50,000
50.001 to 100,000
100,001 or More
Side of a Public Hav
5
10
10
15
IS
Prooertv
5
5
10
10
IS
SI Units?  1 ft. - 0.3048 •; 1 gal. - 3.785 L.
          Other Flammable or Combustible  Liquids
     TanX Capacity
        (Gallons)
Minimum Distance  in Feet
from Property Line Which
Is or Can Be Built Upon.
 Including the Opposite
 Side of a Public Hay
Minimum Distance  In  Feet
from Nearest Sid* of Any
   Public  Hay or from
   Nearest Important
  Building on.the Same
       Prooertv
275 or Less
276 to 750
751 to 12,000
12,00t to 30,000
30,001 to 50.000
50.001 to 100.000
100.001 to 500.000
500.001 to 1,000,000
1,000,001 to 2.000,000
2.000.001 to 3,000,000
3,000,001 or More
5
10
IS
20
30
50
80
100
135
165
175
5
S
5
5
10
IS
25
35
45
55
60
Source:  Table  2-5.  "(NFPA)  30:   Flammable   and  Combustible  Liquids
         1984."  Update of the 1977 and 1981  editions.
                                                 Code

-------
                                 B-11A
                    Factory Installed Sacrificial Anod«
                     Sacrificial Ar*«a
                     Altacftatf by
                     Manufacturer
FIGUKCS AHE rON ILLUSTMATIVt rMJNPOSES ONLT. THEY AMC NOT INTENDED fQ* USB AS

CONSTNUCTION DRAWINGS.

-------
                             B-11B
                  Sacrfficbjl Anod* Cathodte Protection
                                                  T«at Box
        Tank
  bisulato*
  Bushing
                                                             Coating
                                                       lalactrte Insulation

                                                      To Qrado
    MagiwahMi Anodo ta Bag
Sourci:   Suggtsttd  H»ys to  M«tt  Corrosion  Protection  Codes  for Underground
         Tanks and Piping,  The  Hlnchman Company, Detroit, MI.  1981.
   PIGUftCS AM FOB ILLUSTftATlVC ^UMFOSCS ONLY TH6Y Aftf NOT INTCNOCO FOR USE AS

   CONSTRUCTION DRAWINGS.

-------
                                        B-12
                         Impressed Current Cathodte Protection
                                                             20-00 VoM O.C.
            Return Circuit
    — 0 C  Current
       lo Anode fed
                                                             Anod* 1*4
NOTE: Wotno. not
                                                                             (or ctarity
Source:  Suggested  Mays  to  Mttt Corrosion  Protection  Codes  for Underground
         Tanks and Piping. The Hfncluun Company,  Detroit. MI.  1981.
            FIGUREa AN! FOft IUUSTRATIVC r>UK^OSCS ONLY. TNfV AM MOT INTENDED PON USE AS

            CONSTRUCTION DM AW INGS.

-------
                                   B-13
                       COMMON FORMS OF  LOCALIZED CORROSION
            Tvot
                      Description
Bacterial corrosion
Contact or crevice
  corrosionbetween a metal

Erosion corrosion
Galvanic corrosion
Intergranular corrosion
Pitting corrosion
Stray current corrosion
Stress corrosion  cracking
    Soils  or  water  that  become  oxygen-starved,
    I.e.. anaerobic,  cause this forn of corrosion.

    Occurs at the  point of contact or crevice
and a non-metal or between bio metals.

    Moving fluid removes  the protective surface  film
    on a metal, allowing  corrosion to occur.

    Occurs when an electrolytic cell  Is  formed  In
    cases where dissimilar  metals  are electrically
    connected or  where  dissimilar  soil   conditions
    or differential aeration conditions exist.

    Selective  corrosion   at  the  grain   boundaries
    (microscopic)  of a metal or  alloy.

    Formation of  shallow depressions  or dt«p  pits
    (cavities of  small diameter).
    Occurs  when  direct  electrical
    through metal.
currents  flow
    Corrosion accelerated  by residual  stresses  re-
    sulting from  fabrication operations or  unequal
    heating and cooling of structure.
Source:  New  York State  Department  of Environmental  Conservation, "Technology
         for  the  Storage of  Hazardous Liquids—A  State of  the  Art Review"
         (January  1983).  pp. 11-17.

-------
                                B-14
                        ENVIRONMENTS  THAT CAN CAUSE CORROSION
          Material
              Environment
Aluminum


Aluminum bronzes

Austenttlc stainless steels



Carbon and low alloy steels



Copper


Ferrltlc stainless steels
High strength alloy steels
(yield strength 200 psf
plus)

Inconel
Lead

Magnesium



Monel


Nickel

Titanium
Hater and steam; NaCl.  Including  sea  atmospheres  anc
waters; air;  water  vapor.
Mater and steam;
                      ;  caustics.
Chlorides,   Including    FeCb.    FeCl3,    NaCl ;    sea
environments;   ^SO*:  fluorides;   condensing   steai
from chloride waters;  acids.
HC1;  caustics;  nitrates;  HNOs; HCN;  molten zinc  an<
Na-Pb     alloys;     H2S;     H2S04-HN03;      H2S04;
seawater; water;  distilled water.

Tropical   atmospheres;    mercury;   HgN03; : bromides;
anmonla; ammontated organlcs;  adds.

Chloride.   Including   NaCl;    fluorides;   bromides;
Iodides; caustics; nitrates; distilled water;  steam.

Sea and Industrial environments;  water.
Caustic  soda  solutions;  high  purity  water with  fe»
ppm oxygen.

Lead acetate solutions.

NaCl,  Including   sea environments;  water  and  steam
caustics;   ^€4;   rural  and   coastal   atmospheres
distilled water.

Fused  caustic  soda;  hydrochloric  and  hydrof1uorf<
acids.
Bromides; caustics;
Sea environments; mercury; molten  cadmium;  stiver am
AgCI;  methanols  with   halldes;   red   fuming  HN03
    ; chlorinated or floor Inated hydrocarbons.
Source:  Adapted  from V.R.  Pludek, Design  and Corrosion-Control  (New  York,  NY
         John HIley and Sons, 1977).

-------
B-15
           1. Ordinary Quick Dteconn«ct
           2. Quick Otacomwct Pta« B«l V«lv«
            3. Dry Otaconrwct
                    Typ«« of Couplings
FIGUMS AMI fOn ILLUSTHATIVt
CONSTRUCTION OHAWINOS.
     OMW. TH«Y AMI MOT INTINOCO F0« USE AS

-------
             RolUf
            (Ovorflll Vont)
                  High
           Laval Transmitter
      Em*rg«ncy Ovorflow
      to AdJ«c»nt Tank*
                                                Alarm
                                               Laval Controller
                                      —cJo
                                     Motor Op«r«t«d
                                                        Pump
                             Etomtiils of an Ovtrfil Provontlon Systom
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS

-------
                     R*lnforc«d
                     Concrete
                     Foundation
                                Undteturt>«d 8oM
                                                            Secondary ConUfcMMnt
                                                            IOTP***
NoU: Volu«i«
      •hould !»• •
      of 1OO% of tli* tank
      voliiM* plua th« pr«-
      clpltailon from • 24
      hour, 20 yoar •torm
                                          Abovoground Tank
FIGUHES ARC FOA ILLUSTRATlVf PURPOSES ONL^T.
CONSTRUCTION DRAWINGS.
                                                  MOT INTCNOCO FOR USE AS
                               B-17A

-------
                                     SolCovor
                                   for Eroalon «id
                                     UHravlolat
                                     Protection
                               Lnar or
                             WMteproof
                               Coating
                            on Concrata

 Secondary
Containment
   Llnar
Natlva soil
Sump or trough for
aurfaca funoff and


                                                                     Now Aboveground Tank
     FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS

     CONSTRUCTION DRAWINGS.

-------
       CONSTRUCTION DRAWINGS.
                                              Submettlbl* Pump
                                                                          Intutetlno, Union
                                                                               Solely Velvo
 M«UI Manhole


   Ple»llc  Sleeve


Connocllone
••Ckllll
                             ••doing
                              •oil
                                                         SccondMy
                                                               Liner
    TANK
                                                                                                              O
                                                                                                              C
                                                                                                              fit
                                                                                                              3
                                                                                                              fit
                                                                                                              3
                                                                                                              a
                                                                     3
                                                                     ID

                                                                     CO
                                                                     *<
                                                              TANK
         DETAIL- ISOLATED
         MECHANICAL CONNECTION
                          DETAIL-  ISOLATED NYLON
                          • USHING CONNECTION

-------
                                                                     Conlmiiou*
                                                                     vapor baru««
                                                                     lapped a»«l
                                                                          above

                      Cast MI Place Remlmccd Cnnciclv
                                                              MultlpU Tanks In a Vault
FIGURES AMC FOft ILLUSTRATIVE PURPOSES ONLY. TMEV ARE NOT INTENOEO FOR USE AS

CONSTRUCTION DRAWINGS.
                                     B-19

-------
             L-
              r
   Inner   r«nk
Wall
 Samp I Ing
 Standpip*

  of

 Electronic
 Liquid
 Detection
OOUU.t-WALI.eO STfCL TANK
                                          Cit«rlot

                                          • Coil-tar •pony
                                       Interstitial Space
                  NOTf: M«yne(ta«praMntfaratoettonlerMnrtorin«
                  OOU0Lff*WAU£0  '*'  TANK
                                                       Two Doubto-Wal«4
                                                       Tank Configuration*
FIOUMCS AMI ton ILLUSTNATIVI PURPOSES ONLY. THfY AMI NOT INTENOIO 'OM US! A3
CONSTHUCTION OUAWINQS.

-------
            watt* Compatible
                                       Orata or Blow-off Valv«
                                       OtanMly CtoMd)
                                                                     Pip* System
                                                            (Cross Section)
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEV ARC NOT INTENDED FOR USE AS

-------
                               B-22
                              Wr«»»*« vltk Pllt«r Mat*rl*l
                       Typical U-TulM Placement
Monitoring W«M
                  Typical Observation WaB Placamant

-------
RtagwaM Found*!
                                     T«* SHOE duck for n»t •pott.
                                              pttUng, halrlln* crack*
                  Tank
                                            CtMCkforhaMM
                                              BottK CtMKk for n»t, ctoUriomtkxv and
                                       Areas pi Concern In a Typical Tank Foundation
     FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS

     CONSTRUCTION DRAWINGS.

-------
APPENDIX C
 GLOSSARY

-------
                                  C-l
                            Tank-Specific Definitions

    When  used  In 40 Part 264, Subpart J (as  revised  July 14,  1986),  the  terms
In this manual have the following meanings:

     'Aboveground  Tank"  (ACT)  means  a device meeting  the  definition of "tank"
as  set  forth  In  Sec.  260.10  that  Is situated  In  such  a way that the entire
surface  area  of  the  tank   Is  completely  above  the plane  of  the   adjacent
surrounding  surface and  the entire  surface  area of  the tank (Including  the
tank bottom) can be visually Inspected.

    ."Acutely Hazardous  Hastt"  meets  the  following criteria, as  defined  in  40
CFR 261.10:

    It has  been  found  to be fatal to humans In low doses  or,  In the absence of
    data on human toxldty.  It has been shown In studies  to have an oral  LO'50
    toxic!ty  (rat)  of  less  than  SO milligrams per kilogram, an  Inhalation  1C
    50 toxldty  (rat)  of less than 2 milligrams  per  liter,  or a dermal  LO  SO
    toxldty (rabbit)  of less  than 200 milligrams per kilogram or 1s  otherwise
    capable of causing or significantly contributing to an  Increase in seriois
    irreversible, or Incapacitating reversible, illness.

    "Ancillary equipment"  means  any device  Including,  but  not  limited  to,
such devices  as  piping, fittings, flanges,  valves and pumps,  that  is  used  to
distribute,  meter,  or  control  the  flow of  hazardous waste from its  point of
generation  to storage  or treatment tank(s).  between  hazardous waste  storage
and treatment  tanks to a point of disposal  on-slte.  or  to a point of shipment
for disposal off-site.

    "Aquifer"  means a  geologic formation,  group of  formations,  or part of a
formation capable of  yielding a significant amount of ground water to wells or
springs.

    "Certification"  means  a  statement  of  professional  opinion  based  upon
knowledge and  belief.

-------
                                  C-2
    "Component"  means either  the  tank  or   ancillary  equipment  of  a  tank
system.

    "Corrosion expert" means  a person who, by  reason of  his knowledge of the
physical sciences and  the  principles  of engineering and mathematics, acquired
by a  professional education and  related practical  experience,  Is qualified to
engage  In  the  practice  of  corrosion control  on  burled  or  submerged  metal
piping  systems and  metal  tanks.   Such  a  person  must  be  certified as being
qualified by  the  National  Association of Corrosion Engineers  (NACE)  or  be  a
registered  professional   engineer  who  has   certification  or   licensing  that
Includes education and experience  In'corrosion  control  on burled or  submerged
metal piping systems and metal tanks.

     'Existing  tank   system"  or "existing component14 means  a tank  system or
component that Is used for the  storage or treatment of  hazardous waste and  Is
1n  operation, or  the Installation  of  which has  begun,  on  or prior to  tne
effective  date of  the  regulations  (July  14,   1986).   Installation  will   be
considered  to  have  commenced If  the  owner  or   operator  has  obtained  all
federal,  state,  and  local  approvals  or  permits necessary  to  begin  physical
construction  of  the  site  or  Installation of the  tank system,  and  If either:
(1)  a continuous on-site  physical  construction or  Installation program  has
begun;   or   (2)   the   owner  or  operator   has   entered  Into  contractual
obligations—which   cannot  bt   cancelled  or  modified   without  substantial
loss—for physical  construction on the site or  Installation of the tank system
scheduled to be completed within a reasonable time.

    "FacUlty*  means  all  contiguous  land,  structures,  appurtenances,  and
Improvements  on  the land used for treating,  storing, or disposing of hazardous
waste.   A  facility may  consist  of  several  treatment,  storage, or  disposal
operational  units  (e.g.,  one or  more  landfills,  surface  Impoundments,  or
combinations of them).

    "Freeboard"  means tht vertical  distance between  the  top  of  a  tank,  or
surface  impoundment  dike, and the surface of  the waste contained therein.

-------
                                      C-3
    "Groundwater" mans water below the land surface In a zone of  saturation.

     'Incompatible  waste".wans  a hazardous  waste which  is unsuitable for:
(1)  placement  In  a  particular  device  or facility  because  It  may cause
corrosion or  decay of containment materials (e.g., container  Inner liners or
tank  walls);   or   (2)   co-mingling   with  another waste  or   material  under
uncontrolled  conditions  because  the   co-mingling   might   produce  heat  or
pressure, fire  or explosion,  violent  reaction,  toxic dusts, mists, fumes or
gases, or flammable fumes or gases.

    "Inground  tank"   (IGT)  means  a  device  meeting  the definition  of  "tank"
set forth In  Sec.  260.10 that has a portion of  the tank wall  situated  to  any
degree  on  or  within  the  ground,  thereby  preventing  expeditious   visual
Inspection of the surface area of the tank that  Is  on  or  In the  ground.

    "Installation  Inspector"  means a person who,  by  reason  of his knowledge
of  the  physical sciences  and the principles of  engineering,  acquired by .a
professional  education  and  related  practical  experience.  1s  qualified  to
supervise the Installation of tank systems.

    'Leak-detection  system"  means a  system  capable  of detecting either  the
failure  of  the primary  or  secondary containment structure  or  the  presence of
hazardous waste or accumulated liquid  1n the secondary containment  structure.
Such a  system must employ operational  controls  (e.g., dally  visual Inspections
for releases  Into the  secondary containment system  of  aboveground tanks)  or
consist  of  an  Interstitial  monitoring  device designed  to detect continuously
and  automatically  the  failure  of  the   primary  or   secondary  containment
structure or  the  presence of  a  release of  hazardous waste  Into  the secondary
containment structure.

    "New  tank  system"  or  "new  tank  component"  means  a  tank  system  or
component that  will  be  used for  the  storage or  treatment of  hazardous waste
and for which Installation has commenced after January 12, 1987.   However,  for
the purposes  of Sees.  264,193(g)(2)  and  26S.193(g)(2).  a  new tank system (s
one  for  which  construction  commences  after  January  12,1987.   (See  also
"existing tank system.*)

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                                  C-4
    "Onground  tank"  means  a  device  meeting   the   definition  of   "tank"   In
Sec. 260.10  that  1s  situated  In such a way  that  the bottom of the  tank  is  on
the same  level  as the  adjacent surrounding surface  so that  its  external tank
botto* cannot be visually Inspected.

    "Suap" means  any pit or reservoir  that  meets the definition of  tank, and
those troughs/trenches connected  to  It  that  serve  to collect hazardous  waste
for transport to hazardous waste storage,  treatment, or disposal  facilities.

    "Tank" means  a  stationary  device,  designed to  contain an accumulation  of
hazardous  waste,   which   Js  constructed  primarily  of  non-earthen   materials
(e.g., wood, concrete,  steel,  plastic) which  provide structural  support.

    •Tank  system" means  a  hazardous  waste  storage  or treatment tank and  Its
associated ancillary equipment and containment system.

    "Underground  tank"  (UGT)  mans  a  device  meeting   the   definition   of
"tank*  set  forth   In  Sec.  260.10.  whose   entire  surface  area  Is   wholly
submerged within  the ground (I.e., totally below the  surface of  and  covered  by
the ground).

    "Unf1t-for-use  tank  systea" means  a  tank system  that  has  been  determined
through an Integrity assessment or other Inspection to be no  longer  capable  of
storing or  treating  hazardous  waste without posing a threat of hazardous waste
release to the environment.

    "ZoiM  of  engineering  control" means  an  area  under  the control  of   the
owner or  operator that,  upon detection of  a hazardous waste  release,  can  be
readily  cleaned  up  prior  to   the  release  of  hazardous   waste  or  hazardous
constituents to ground water or surface water.

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APPENDIX O
REFERENCES

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                                                     OSWER 9938.4


                 Synopsis  of  Pertinent References
 1.  Compatibility of Waste in Hazardous Waste Management
    Facilities—A Technical Resource Document for Permit
    Writers. US EPA (November 1982).  This manual provides
    guidance on how to determine the compatibility of
    hazardous wastes with other wastes and with the various
    types of structures - tanks, piles, and containers - in
    which they are stored or treated.

2.  Design & Development of a Hazardous Waste Reactivity
    Testing Protocol. US EPA (October 1984).   The test scheme
    developed for determining waste compatibility includes a
    field-test kit, a series of flow diagrams, and a manual
    for using the flow diagrams and test procedures.   It also
    employs a compatibility chart; which classifies wastes by
    chemical class and/or procedures to classify hazardous
    waste materials according to their gross chemical
    composition when little or no. prior knowledge is
    available regarding their components.   Chemical
    composition information is then used to predict which
    waste materials can safely be mixed before actually
    performing mix tests.

3.  Draft Guidance for Suboart G. Closure and Post-Closure

    Requirements. US EPA (January 1987) OSWER Directive
    #9476-00-5, NTIS PB-87-158-978.  This document outlines
    procedures for TSDF's for complying with regulatory
    requirements for closure and post-closure care.

4.  Lining of Waste Impoundment and Disposal Facilities, by
    Matrecom Incorporated,, for the US EPA (September 1980).
    Based upon the current state of the art liner technology,
    this report provides information on performance,
    selection, and installation of specific liners and cover
    materials for various disposal situations.  It further
    describes the effects various wastes have on liners;
    liner service life and failure mechanisms; installation
    problems; cost information; and tests that are essential
    for pre-installation and monitoring surveys.
                               D-l

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                                                     OSWER 9938.4
5.  Model Permit, for Hazardous Waste Treatment.  Storage &
    Disposal Facilities-. US EPA (undated draft).   Companion
    to Permit Writer's Guidance Manual for Hazardous Waste
    Land Treatmentf Storage and Disposal Facilitiesf the
    model permit provides a standard permit format for
    facilities that store, treat, or dispose of  hazardous
    waste.  The model is divided into modules for various
    types of permit conditions.

6.  Permit Applicant's Guidance Manual for the General
    Facility Standards. US EPA, SW 968 (October  1983).
    Guidance, for permit applicants that addresses general
    information requirements of 40 CFR Sec. 270.14(b) (1-12,
    19) and the Sec. 264 standards referenced by those
    requirements for Part B applications.

7.  RCRA Inspection Manual. OSWER No. 9938.2A, US EPA
    (March 1988).  This manual has been developed to support
    federal, state, and local inspection personnel in
    conducting field inspections of RCRA-regulated facilities
    to determine facility compliance with RCRA regulations.

8.  RCRA Permit Writer's Manual for Ground Water Protection
    (40 CFR  264 Suboart F). US EPA  (October 1983).  Provides
    a comprehensive examination of items covering ground
    water protection requirements for permit writers to
    examine when reviewing Part B applications.

9.  Recommended Practices for Underground Storage of
    Petroleum, by Fred C. Hart Associates for the New York
    State Department of Environmental Conservation (May
    1984).  This manual provides specific guidance for the
    underground storage of petroleum and petroleum-derivative
    liquids.  The manual is intended for engineers,
    inspectors, and owners who are designing or  upgraded
    their underground facilities for leak and spill
    prevention.  Specific guidance includes:  (l) design of
    tanks and piping systems; (2) installation of
    underground storage tanks; (3) secondary containment;  (4)
    leak detection; (5) overfill protection and  transfer
    spill prevention; (6) tightness testing; (7)  storage tank
    rehabilitation; and (8) closure of underground storage
    facilities.

10. Technical Resource Document for Obtaining Variances from
    the Secondary Containment Requirement for Hazardous Wastg
    Tank Systemsr Vol. I and II (February 1987),  OSW, US EPA
    NTIS Nos. PB-87-158655, PB-87-158663, OSWER  Policy
    Directive #9483.00-2.  This document is prepared to help

                               D-2

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                                                     OSWER 9938.4
    owner/operators of hazardous waste tank systems to apply
    for either a technology-based variance or risk-based
    variance from secondary containment.

11. Technical Resource Document for the Storage ^pfl
    Treatment of Hazardous Waste in Tank Systems.  OSWER
    Policy Directive # 9438.00-01.  This document  provides a
    complete review of the regulations promulgated governing
    hazardous waste storage and treatment tank systems.   This
    document also provides a technical reference concerning
    the design and installation of tank systems in order to
    satisfy the regulatory requirements.  This document is
    written for owner/operators to help them comply with EPA-
    regulations for hazardous waste tank systems.

12. Technology for the Storage of Hazardous Liquids—A
   ' state-of-the-Art Review,, by Fred C. Hart, Associates,
    for the New York State Department of Environmental
    Conservation (January 1983).  This manual is a
    compilation of much of the latest information  on        ,
    underground and aboveground storage systems and on states
    of-the-art equipment available for storing and handling -"
    hazardous liquids in tanks.  Included is a discussion on
    the technology and practices for storage of petroleum and
    other hazardous liquids which could be accidentally
    released into the environment.  Among the topics covered
    are:  design features; piping systems; spill containment
    systems; spills and overfill prevention systems; leak and
    spill monitoring; and testing and inspection for both
    underground and aboveground tanks.

13. Underground Tank Leak Detection Methods - A State-of-
    fhe-Art Review. (1986) RPA/600/2-86/001) by IT
    Corporation for ORD, US EPA.  This report is a state-of-
    the-art review of available and developing methods for
    finding small leaks in underground storage tanks used
    primarily for petroleum fuels.  This review describes a
    total of thirty-six volumetric, non-volumetric, inventory
    monitoring and leak monitoring methods; provides general
    engineering comments; and discusses variables  which may
    affect the accuracy of detection methods.

14. Questions and Answers Regarding the July 14r 1986
    Hazardous Haste Tank System Regulatory Amendments.
    (August 1987), US EPA, OSWER Policy Directive  t9438.00-3,
    EPA/530-SW-87-012.  This document is intended  to provide
    answers to many of the questions that are likely to arise
    concerning compliance with the new requirements for
    storage and treatment of hazardous waste in tank systems.

                               D-3

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                                                    OSWER  9938
15.  Compilation Of persons w^^ Design.  Tpqt. Inspect.  and
    Install stooge Tank -Svst.ftps.  (February 1988) US EPA/530-
    SW-88-019.  This document provides  lists of  individuals
    and companies who:  (A) assess existing tank system
    integrity, (B) assess new tank system design,  (C)
    determine corrosion potential, (D)  inspect new  tank
    installations.
                               D-4

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