oEPA
               United St
               Environmental Protection
               Agency
            Office of
            Solid Waste and
DIRECTIVE NUMBER: 9943.2
TITLE: Enforcement of the USt Interim Prohibition
                        i
APPROVAL DATE: December 30, 1986
EFFECTIVE DATE: December 30, 1986
ORIGINATING OFFICE: OWPE
S FINAL
D DRAFT
 LEVEL OF DRAFT
   a A — Signed by AA or DAA
   CjJ B — Signed by Office Director
   DC — Review ft Comment
REFERENCE (other documents):
9943.1 EPA's Enforcement Strategy for the UST
     Interim  Prohibition
  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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&EPA
L
Anna B. Duncan
United States Envirc~— ?-•"' °::"5: 	 :--?••
Wcs.\. ' -
OSWER Directive Initiation Reemest
1 . Directive Number
9943.2
2. Originator Information
WH-527
Office
OSWER/OWPE/RCRA Enf
Telephone Number
382-4829
   Enforcement of  the UST Interim Prohibition
  4. Summary of Directive (Include brief statement of purpose}
    It is the purpose -of this memorandum to encourage the enforcement of the
    Interim Prohibition by reviewing the goals,  strategy, and resources
    available for compliance monitoring, and alternative enforcement
    mechanisms available to Regional personnel,  includes an underground
           tank inspection checklist.	
5. Keywords
  Enforcemnt, UST, Interim Prohibition
6a. Does this Directive Supersede Previous Directive " >C?
Date
OS WER          OS WER          OS WER
       DIRECTIVE      DIRECTIVE       D

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                                                       9943.2
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON. D.C. 20460
                          DEC $01966
                                                      OFFICE OF
                                             SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:  Enforcement of the UST Interim Prohibition
Gene A. Lucero, Director
Office of Waste Programs Enforcemen
FROM:
          Ronald Brand, Director
          Office of Underground Storage Tanks

TO:       Waste Management Division Directors,
            Regions I, V, VII, VIII
          Air and Waste Management Division Director,
            Region II
          Hazardous Waste Management Division Directors,
            Regions III and VI
          Water Management Division Director, Region IV
          Toxics and Waste Management Division Director,
            Region IX
          Hazardous Waste Division Director, Region X

     The Interim Prohibition  (Section 9003(g) Subtitle I of
RCRA)  became effective on May 8, 1985.  The Interim Prohibition
established a statutory standard on installation of tanks which
will remain effective until the promulgation of final new tank
standards. 1
1 Section 9003(g)establishes an interim prohibition against
the installation of any tank unless the tank  (A) will prevent
releases due to corrosion or structural failure for the
operational life of the tank; (B) is cathodically protected
against corrosion, constructed of noncorrosive material, steel
clad with a noncorrosive material, or designed in a manner to
prevent the release or threatened release of  any stored substance;
and (C) the material used in the construction or lining of the
tank is compatible with the substance to be stored.  Under
Section 9003(g)(2) metal tanks may be installed without corrosion
protection, if soil tests conducted in accordance with ASTM
Standard G57-78, or another standard approved by the Administrator,
show that soil resistivity in an installation location is
12/000 ohm/cm or more.., but the remaining requirements regarding
structural failure and compatibility (paragraphs (A) and (C)
above)  still must be met.  The Agency has published a final
Interpretive Rule, 40 CFR Part 280, in the Federal Register
(51 FR 20419, June 4, 1986).

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                                                             9943.2

                              -2-

     It is the Agency's policy to initiate enforcement action
when violations of the Interim Prohibition are detected.  EPA's
enforcement strategy for the Underground Storage Tank (UST)
Interim Prohibition was transmitted on September 16, 1986 by
Thomas Adams, Assistant Administrator for Office of Enforcement
and Compliance Monitoring and J. Winston Porter, Assistant
Administrator for Office of Solid Waste and Emergency Response.

     It is the purpose of this memorandum to encourage the
enforcement of the Interim Prohibition by reviewing the goals,
strategy and resources for compliance monitoring, and alternative
enforcement mechanisms available to Regional personnel.


I. EPA'S GOALS FOR ENFORCEMENT OF THE INTERIM PROHIBITION

     One of the Agency's long term goals for implementing and
enforcing the UST program is to establish strong State and local
UST programs and to minimize EPA's role in directly implementing
the UST regulatory program.  However, an EPA enforcement role is
important both to enforce the Interim Prohibition and to
establish a Federal UST program across the country.  Further,
EPA has primary responsibility to enforce the Interim Prohibition,
and, until State programs are authorized, any standards that
are promulgated.  States, municipalities and other persons may
enforce these requirements pursuant to section 7002 of RCRA and
may enforce similar State standards pursuant to State Law.

     The enforcement strategy for the interim prohibition set
forth a strategy for identifying and inspecting newly installed
tanks.  The Agency's goals for enforcement of the UST interim
prohibition are as follows:

   0 Conduct inspections both to promote voluntary compliance
     and to determine the need for enforcement actions;

   0  Pursue enforcement in response to clear cut violations,
      including:

      - filing of formal enforcement actions to enforce the
        Interim Prohibition, and
      - follow-through to achieve compliance

   0  To focus EPA inspection and enforcement activities in
      States that do not have State UST regulatory programs,
      and in States with minimal programs.
II. COMPLIANCE MONITORING STRATEGY AND RESOURCES

     Various methods exist for detecting violations of the
Interim Prohibition.  Tips and complaints on bare steel tank
installation from a variety of sources (i.e., letters and telephone

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                                                        9943.2

                              -3-

calls) may identify possible violations.  Most violations will
be detected by inspectors who observe the installation of a
bare steel tank or who visit the site of a recently installed
tank.

A. Inspections and Technical Guidances

     Inspections should be conducted to verify compliance with
the Interim Prohibition.  The attached checklist is intended to
serve as a guide to the inspector as to information which can
indicate violations of the Interim Prohibition.  It is possible
that some of the information requested on the checklist will not
be available during an inspection.  The information available
depends, in part, on whether the inspection is performed during
or after the installation as well as to the quality of the
records kept by the owner/operator, installer or other person.
Please use this checklist when performing your inspections.  Be
sure to attach this checklist to your work assignments when using
contractors to perform the inspections.

     In addition to the checklist, the following technical
guidances are available:

   Guidance Document for Installing Underground Storage Tanks
   Under the Interim Prohibition, UST 12, August 1986.

   Recommended Practices for Installing Underground Liquid
   Storage Systems, Petroleum Equipment Institute,  PEI RP
   100-86.

     Regions may find it useful to share this checklist and the
guidances with state and local government personnel who may
observe tank installations in the course of their duties and who
could refer violations of the Interim Prohibition to EPA.
B. Information Management

     We request that you advise Headquarters OWPE of the results
of each inspection.  This may be done by providing a very brief
summary of the results or a copy of the completed checklist.
More broadly, you should track by facility, the inspections
completed, violations identified and enforcement actions taken/
returns to compliance.
C. Resources

     The FY 1987 budget provides a total of 10 FTEs for the EPA
Regions for enforcement of the UST program.  Those 10 FTEs are
divided by Region as set forth below:

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                                                           9943.2
                              -4-
                      Region	FTEs
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
0.7
1.2
1.2
1.2
1.2
1.2
0.7
0.7
1.2
0.7
10.0
Additional resources are provided for UST implementation
activities (e.g., providing assistance to States in developing
UST programs, etc.).

     The Enforcement Strategy for the Interim Prohibition
(September 16, 1986) encourages the Regions to work closely with
State and local agencies, including local fire marshalls, who
may have independent authority to inspect newly installed
tanks.  State and local agencies are a substantial and valuable
component of the inspection program.

     Nevertheless, the Regions will need to conduct some
inspections, especially to support case development, and may
require contractor support in case development work.   For this
purpose, OWPE is setting aside $200,000 of Headquarters funds
(approximately 4,000 Level of Effort hours)  in the Technical
Enforcement Support (TES) Contracts III and IV for use solely
on UST enforcement.  These newly awarded contracts are zoned
contracts (TES III handles Regions I thru IV; TES IV handles
Regions V-X).  The following table indicates your Regional
allocation of the $200,000 for UST enforcement:
             Region	TES III	TES IV
I
II
III
IV
V
VI
VII
VIII
IX
X
$ 15,000
15,000
15,000
15,000










$ 15,000
15,000
15,000
15,000
15,000
15,000
         (Reserve)            20,000	30,000
                             $80,000        $ 120,000
                                 TOTAL $200,000

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                                                             9943.2
                              -5-

     I am also enclosing a list of Regional TES contacts who
can provide you additional information on these contracts and
can assist you in preparing work assignment forms.  (Each work
assignment submitted must specify that it is for UST enforcement.)
An initial total of $150,000 will be allocated to all ten Regions
(the remaining $50,000 will be held in reserve for now).  If a
Region chooses not to task its allocation by March 30, 1987, the
funding will be reallocated by Headquarters to another Region
utilizing the contracts as will the amount held in reserve.

     TES contract money can be particularly helpful in providing
technical assistance for case development.  For example, this
includes the measuring of soil resistivity or evaluating the
level of cathodic protection.  Such information may be necessary
to document the violation, before the Region can pursue the case.
III. ENFORCEMENT RESPONSES

     In the event that a violation is discovered by an inspection
or other means, the Region may proceed by taking one of the
following actions:

     o  Send a section 9006 letter to the alleged violator
        requesting more information.  A sample letter is attached
        to the September 16, 1986 enforcement strategy memorandum,

     o  File an administrative compliant incorporating by
        reference the 40 CFR Part 22 procedures.  (A penalty
        policy will be available in the near future.)

     o  Refer a civil action to OECM (a draft interim prohibition
        model litigation report was transmitted by Edward Reich
        for comment on December 1.)

     o  Verbally refer a civil action with a request for a
        temporary restraining order/preliminary injunction, if
        installation of a noncomplying tank is imminent.

IV. FEEDBACK

     We are interested in feedback.   Please let us know your
views on this subject.  We plan to address this subject in the
next RCRA Enforcement monthly conference call.

     If you have any questions with regard to this memorandum,
you may call Anna B. Duncan, OWPE (FTS 382-4829).

Attachments

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                                                                 9943.2
               UNDERGROUND  STORAGE  TANK  INSPECTION  CHECKLIST
                       Introduction and  Instructions
    Section 9003(g) of the Resource Conservation and Recovery Act (the
Interim Prohibition) prohibits persons from installing an underground
storage tank to contain regulated substances or petroleum unless the tank
(a) will prevent releases due to corrosion or structural  failure for the
operational life of the tank (b) is cathodically protected against
corrosion, constructed of noncorrosive material, steel clad with a
noncorrosive material, or designed in a manner to prevent the release or
threatened release of any stored substance; and (c) the material used in
the construction or lining of the tank is compatible with the substance
to be stored.-7  If the soil within which the tank is installed has a
resistivity of 12,000 ohm-cm or greater, the tank is not required to be
equipped with corrosion protection.
I/ As stated in the interpretive rule 51  Fed.  Reg.  20419 (June 4, 1986),
   the requirements are:
    (1)  That the tank and underground piping  be designed,  constructed,
         and Installed to prevent releases due to corrosion for the
         operational life of the tank and the  piping.
    (2)  That the tank and underground piping  be designed,  constructed,
         and installed to prevent releases due to structural failure for
         the operational life of the tank and  the piping.
    (3)  That the materials used In the construction or lining of the
         tank and its underground piping be compatible with the substance
         to be stored in the tank.

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                                                            9943.2
    Section 9003(g) specifies at least three acceptable methods of
corrosion protection:   cathodic protection,  a non-corrosive coating,  and
a non-corrosive material of construction.   The only non-corrosive
material presently acceptable for either coating or construction is
fiberglass-reinforced plastic (FRP).
    Structural failure, assuming a valid design, Is prevented primarily
through applying proper Installation  procedures.
    This Inspection checklist is Intended  to serve as a guide for the
Inspector 1n Identifying conditions which  might constitute violations of
the Interim Prohibition.  It Is possible that much of the Information
requested on the checklist will not be available during the Inspection.
The Information available depends, In part,  on whether the Inspection 1s
performed during or after the Installation as well as the quality of  the
records kept by the tank owner.
It 1s not essential that all the Information requested on the form be
provided.  Again, the checklist is intended  to guide the inspector to
details that can Indicate violations  of the  Interim Prohibition.
    Much of the checklist is self-explanatory.  The following pages
provide brief Instructions in completing specific items in the list.   In
addition, the Inspector should provide two more pieces of information.
First, In the space provided, indicate the status of the facility.  If
the facility is Inspected during installation, describe the status of the

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                                                              9943.2
Installation.  If the Inspection occurs after the Installation  Is
complete, describe the operational  status of the facility (e.g.,
installation complete, facility fully operational).
    Also, you will notice a set of  parentheses  next  to most  items.   The
inspector is to place a "1" in the  box if the information resulted  from
direct (first-hand) observation. If the information was  obtained from
the tank owner place a "2" in the parentheses.   If a third party, or
source other than the owner provides any Information,  place  a "3" in the
parentheses.
    Finally, note that parts I, II,  and III  should be  completed for each
facility investigated however, parts IV, V,  and VI must be completed for
each tank on the site.

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                                                                    9943.2
               UNDERGROUND  STORAGE  TANK  INSPECTION  CHECKLIST

    This Inspection is being performed under the authority provided by
Section 9005(a) of the Solid Waste  Disposal  Act, which is commonly
referred to as the Resoure Conservation  and  Recovery Act (RCRA).

INSPECTOR NAME	   TITLE	

ADDRESS
PHONE #
I.  IDENTIFICATION                      DATE OF INSPECTION
    A.I
         Facility Name

    B.I  	   B.2  	
         Facility Address (Street #)       Facility City/State/Zip

    B.3  (   )	
         Facility Phone

    C.I  	   C,2
         Facility Operator Name            Operator Address
                                           (Street/City/State/Zip

    D.I  	   D.2  	
         Facility Owner Name               Owner Address
                                           (Street/City/State/Zip

    E.
         Facility I.D. Number
         (From Notification Form)
    F.I  	   F.2. 	
         Name of Contact at Facility       Contact Job Title

    F.3  (   )	
         Contact Work Phone

    G.I  	
         Nature of Business (e.g. gas stations; auto/truck, fleet;
                                  chemical plant)

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                                                                     9943.2
[I.  BACKGROUND

    A.I   	
         Number of tanks (Attach a copy of Notification Form)

    A.2   	
         Number of newly Installed tanks (Indicate on facility sketch)

    B.I   	
         Sketch of facility,  showing all tanks  and their I.D.  numbers,
         piping, anodes, etc.,  including topographic features  on the
         attached grid (following page).
    C.I
         Date Inspection Performed

    D.I
         Status of Installation (If not complete)
III.    SITE ASSESSMENT

       A.      Soil  Resistivity:   Indicate the measured resistivity and
              who made the measurement,  along with the date of the
              measurement.  If possible,  show the approximate location  of
              the measurement on the site drawing.  Also, describe the
              weather and soil conditions during measurement,
              particularly regarding moisture.

       A.I     	(   )
              Soil  Resistivity (ohm-cm)

       A.2     	(   )
              Date of Resistivity Measurement

       A.3     	(   )
              Weather Conditions During  Measurement

       B.      Stray Current Analyses:  If the storage system utilizes
              steel or other metallic components, determine whether or
              not a stray current analysis was performed.  In addition,
              observe the area surrounding the site and note any

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   -9'943.2
j	i

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                                                                    9943.2
              potential  stray current sources,  such  as  buried  pipelines
              and power  cables,  subways,  and  welding operations.
              Indicate approximate  distances  from the site.

       B.I     	(   )
              Stray Current Analysis  Performed?

       B.2     Identify Potential  Stray Current  Sources  Near  Fac111ty(   )
              (Attach  sketch or  list)

       C.I     Identify Potential  Receptors, Conduits Off-Site       (   )
              (Attach  sketch or  list)

IV.  TANK-SPECIFIC DATA (Fill Out Part IV  For  Each Tank  Inspected)

       A.      Date of  Installation:   Enter  the  date  the installation was
              completed.

       A.I     	(   )
              Date of  Installation

       A.2     	<   )
              Tank I.D.  Number(s)

       B.      Material(s)  Stored:  Be as  specific as possible.   If It  Is
              gasoline,  state which  type  (e.g.,  regular leaded,  premium
              unleaded).   If it  Is  a  hazardous  chemical,  specify the
              trade name  as well  as  the chemical  name of  the primary
              constituent.

       B.I     	(   )
              Material Stored

       C.      Use of Material:   Is  this a final  product,  to  be  packaged
              and or shipped?  Is it  an Intermediate to be used  in the
              manufacture  of another  product?  If it is an intermediate,
              state that  the chemical is  used to produce  a final
              product.  Specify  the  final product.

       C.I     	(   )
              Use of Stored Material

       D.      Size of  the  Tank:   Indicate the maximum volume (gallons  of
              the tank being inspected.

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                                                             9943.2
D.I    _ (   )
       Volume of Tank

E.     Material of Construction:  General material  (e.g.,  steel,
       stainless steel, FRP).   If the tank is constructed  of
       another alloy, specify the alloy.

E.I    _ (   )
       Material of Construction

F.     Internal Lining:  Identify whether or not the tank  is lined
       internally.  Specify if the tank was lined after
       installation or during manufacture.  If line, specify the
       resin used in the lining or the name of the  franchisor used
       (e.g., Armour Shield, Bridgeport, Thermoset).

F.I    _ _ (   )
       Internal Lining, if any (N/A if no lining)

G.I    _ (   )
       Is the owner aware of the compatibility of tank/lining
       material with substance stored?

G.     Indicate whether the tank was new or used when Installed:
       (If the tank has been used, indicate the approximate age  of
       the tank).

G.I    _ (   )
       Age of tank when installed at this site; state "new" if
       new

H.     Manufacturer:  Name and address of the company that
       manufactured the tank.

H.I.   _ (   )
       Manufacturer
       Facility Address (Street No.)
       Facility City/State/Zip

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                                                                    9943.2
       I.     Installer:   Name and address of general  contractor who
              Installed the system.   If the tank owner contracted with
              several  contractors for specific Items,  list the owner as
              the installer and explain if the owner 1s also in the
              business of Installing tanks or just contracted with others
              to provide  needed services (e.g., a plumber, backhoe
              operator).

       I.I    	(  )
              Installer
              Installer Address (Street No.)
              Installer City/State/Zip

       J.     Tank Model :   Identify the specific type of tank, such as
              St1-P3 or equivalent and the manufacturer's model  number
              (e.g., Owens/Corning FRP model  G-6).   This Information may
              be available from Invoices.

       J.I    _ . _ (  )
              Tank Model (e.g., Sti-P3, BT-10, etc.)

    K.   Coating Material :  All tanks are  coated.  Even so called "bare"
         steel tanks are generally painted.  If the only Information
         available specifies bare steel, indicate this on the form.
         Otherwise, determine the type of  coating.

       K.I    _ (  )
              Coating Material

       L.     Coating Thickness:  If you are  able to measure the
              thickness (i.e.,  the tank is not yet  installed), measure at
              several spots and provide the average.

       L.I    _ (  )
              Coating Thickness (inches)

       M.     Other Design Considerations:

V.     CATHODIC PROTECTION

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                                                           9943.2
A.     Cathodic Protection:  Record the number,  type (material,
       such as zinc or magnesium), and size (In  pounds)  of the
       anodes.  If Impressed current is used,  be aware that not
       only do these systems also use anodes,  but that they use
       different materials, such as platenized niobium and
       graphite.  Zinc and magnesium are not used for Impressed
       current.

A.I    	(   )
       Number of Anodes

A.2    	(   )
       Type of Anodes

A.3.   	(   )
       Size of Each Anode

B.     Method of Attachment to Tank:  State If the anode wire 1s
       caldwelded, bolted, or clipped to the tank.  If possible,
       check the connection to ensure that It Is secure.  Provide
       a general description of the location of the connection
       (e.g., on the end caps).

B.I    Method of attachment to tank:
C.     Provided with Tank or Separately?:  If the anodes were
       attached at the factory (pre-engineered),  circle "with
       tank".  With this type of system, the anodes are attached
       directly to the tank, usually on the ends.  If the cathodic
       protection system was engineered separately, such as with
       impressed current, circle "separately".  In this case,
       whether the system is sacrificial anodes or Impressed
       current, the anodes are not, generally, attached to the
       tank.  Rather, they are buried some distance away, with
       only the lead wire running to the tank.

C.I    Provided with tank or separately?                       (  )
       (Circle correct answer)
                             10

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                                                                   9943.2
       0.     Cathodlc Protection Monitoring Station Provided?:   Circle
              yes only If a test station Is specifically provided with
              provisions for measuring the tank-to-soil  potential and
              anode current output.   Periodic monitoring of cathodic
              protection Is the only way to determine whether or not It
              1s functioning properly.  Because the subsurface
              environment can change over time, annual  testing of the
              system is recommended.  Test stations are  not essential,
              but they facilitate monitoring.

       D.I    Cathodlc Protection Monitoring Station Provided?

              Yes               No                                (   )

VI.    INSTALLATION

       A.     Backfil1 Material:  Was the proper backfill material  used,
              as specified 1n the Installation Instructions?  Generally,
              proper backfill consists of pea gravel, crushed stone, or
              clean sand.  Some native soils may be suitable for
              cathodlcally protected steel tanks,  but care must be taken
              to ensure proper compaction to provide structural  support
              for the  tank.  If sand Is used, It should  be mechanically
              compacted.

              Observe  the backfill material as it  Is deposited 1n the
              excavation to see that it is free of debris such as large
              rocks, scrap wood, and organic material or other trash.
              Such material can damage the coating, the  tank wall,  or set
              up localized corrosion cells in an otherwise noncorrosive
              environment.

              If possible, inspect the installation of the backfill  to
              determine that it is properly placed beneath the haunches
              of the tank along Its  entire length.

       A.I    	(  )
              Backfill Material

       A.2    	(  )
              Properly Tucked Beneath Tank?

       B.  .   Depth from the Top of  Tank to Ground Surface:  Determine
              the burial depth of the tank, Including the thickness  of
              the concrete or asphalt pad.  Compare this with the
              manufacturer's Instructions or PEI's Recommended Practice,
              RP100-86.
                                    11

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                                                                     9943.2
       B.I    	<  )
              Depth From Top of Tank to Ground Surface

       C.     Method of Anchoring Tank:  Describe the system used to
              anchor the tank, If any.  Include In your description the
              use of a concrete pad, dead-men anchors, and hold-down
              straps.  Observe whether or not the straps are placed as
              Indicated by the manufacturer.

       C.I    	(  )
              Method of Anchoring Tank

       D.I    	(  )
              Other Structural Problems (design/construction/installation)
VII.   PIPING
       A.     Material of Construction:  Indicate, where specified, the
              material of construction (e.g., steel, FRP, PVC), and
              whether or not the steel 1s galvanized.  Also, Indicate If
              the piping is cathodlcally protected and the type of
              protection provided.  Galvanized pipe Is not cathodlcally
              protected.  Be certain to distinguish the piping protection
              from the tank protection.  If the tank is protected by a
              pre-engineer1ng system, the piping must have its own system.

       A.I    	(  )
              Material of Construction

       A.2    If Steel, Galvanized?         Yes     No    (Circle)   (  )

       B.     Number. Type. Size of Anodes; Method of Attachment:
              Indicate on the site drawing the locations of the anodes.
              Also, provide the type (e.g., zinc, magnesium) and size of
              the anodes, as indicated.

       B.I    Cathodic Protection?          Yes     No    (Circle)   (  )

       B.2    Impressed Current      Sacrificial Anodes  (Circle)    (  )

       B.3    	(  )
              Number of Anodes
                                    12

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                                                                9943.2
B.4    	;	(   )
       Type of Anodes (material)

B.5     	 (   )
       Size Each of Anode (pounds)

B.6    Method of Attachment to Pipe (is sacrificial  anodes)   (   )
C.     Type of Coating Used on Pipe:   Galvanizing is  not
       considered a coating for the purposes of this  form.   If the
       pipe is steel,  without cathodic protection,  it must  be
       coated.  Indicate the coating  material  as specifically  as
       possible.

C.I    	 (  )

D&E.   FRP Pipe:   If FRP pipe is used, inspect for  the presence of
       cracks, bowing, or contact with other piping runs.   Also,
       if the air temperature is below 60°,  heating pads are
       needed to provide sufficient heat for the pipe adhesives to
       set properly.

D.I    FRP Pipe:
       Inspect for damage (Cracks, bowing,  contact  with other  pipe
       runs).  Note any damage.                              (  )
E.I    Joints (Indicate air temperature during installation)    (   )

E.2    Proper Heating Equipment Used to Set Adhesives (If below
       60°)?  Circle one.                                    (   )

                    Yes                  No
                             13

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                                                              9943.2
VIII   OTHER OBSERVATIONS
                                   14

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                                                                             9943.2
                     REGIONAL RCRA TES CONTACTS ADDRESS LIST
Steve Fradkoff
TES Contact
US EPA Region I
John F. Kennedy Federal Buidling
Room 2203
Boston, MA  02203
(FTS) 223-1724

Eddie Louie
TES Contact
US EPA Region II
26 Federal Plaza
New York, NY  10278
(FTS) 264-1369

Jeff Barnett
TES Contact
US EPA Region III
841 Chestnut Street
Philadelphia, PA  19107
(FTS) 597-6688

Allan Antley
TES Contact
US EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA  30365
(FTS) 257-4552

Bill Muno
TES Contact
US EPA Region V
230 South Dearborn Street
Chicago, IL  60604
(FTS) 886-4434

Linda Thompson
TES Contact
US EPA Region VI
1201 Elm Street
Dallas, TX  75270
(FTS) 729-2949

Scott Richey
TES Contact
US EPA Region VII
726 Minnesota Avenue
Kansas City, KS  66101
(FTS) 757-2891

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