oEPA United States Environmental Protection Agency Office of Solid Waste and Emergency Response DIRECTIVE NUMBER: 9483.03(83) TITLE: Tank Inspection Procedures APPROVAL DATE: 9-26-83 EFFECTIVE DATE: 9-26-83 ORIGINATING OFFICE: office of solid waste E FINAL D DRAFT STATUS: r i REFERENCE (other documents) ] A- Pending OMB approval ] B- Pending AA-OSWER approval ] C- For review &/or comment ] D- In development or circulating headquarters OSWER OSWER OSWER VE DIRECTIVE DIRECTIVE Dl ------- PARTS 264 AND 265 SUBPART J - TANKS DOC: 9483.03(83) Key Words: Regulations: Subject: Addressee: Originator: Source Doc: Date: S umma ry: Tank 40 CFR 264.194(b) Tank Inspection Procedures Dennis Huebner, Chief, State Waste Programs Branch, Region I Bruce R. Weddle, Acting Director, State Programs and Resource Recovery Division #9483;03(83) 9-26-83 The periodic inspection of tanks required by §264.l94(b) should include a thorough visual inspection of the tank interior, which normally means emptying the tank and having an individual enter it to perform the inspection. If a RCRA permit applicant does, not wish to have its own facility personnel perform this type of inspection an outside inspection firm can be hired to do so. The fre- quency of these periodic comprehensive tank inspections should be established based on relevant factors, i.e., the nature of the wastes being stored, tank shell material, age of the tank, and anticipated corrosion rates. An applicant can propose alternative procedures to be substituted in lieu of an internal visual inspection, if they are demonstrated to be equally effec- tive in detecting "cracks, leaks, corrosion or erosion which may lead to cracks or leaks, or wall thinning...." ------- (83) MEMUiAMUM SUBJECT: lank Inspection Procedures FKCrt: Bruce R. Meddle, Acting Director State Programs and Resource Recovery Division • 'ID: Dennis Huebner, Qiief State Waste Ptujraiis Branch, Region I In your memorandum of August 29, 1983 to Steve Levy, you requested head- quarters guidance regarding internal inspections of hazardous waste storage tanks, I nope that tne following aoequately answers tne issues you raisea. The periodic inspection of tanks required by $264.194(b) should include a thorough visual inspection of the tank interior. This will usually involve enptyimj the tank and having an individual enter it to perform the inspection. It is our understanding that this can be done safely in all but very rare instances, so long as the proper equipnient is used and appropriate safety pre- cautions are followed. If a RCRA permit applicant does not wish to have its own facility personnel perform this type of inspection, there are a manner of tank testing and inspection firms that can be hired to do so. It may be possible, however, that an applicant could propose acceptable inspection procedures which do not involve physical entry into a tank. Such alternative procedures could be substituted in lieu of an internal visual in- spection, if they were demonstrated to be equally effective in detecting "cracks, leaks, corrosion or erosion which may lead to cracks or leaks, or wall thinning... [ref. $264.194------- |