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

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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...."

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                                                                                    (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
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