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
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OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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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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