Hazardous Waste Tank Systems
Inspection Manual
RCRA Enforcement Division
Office of Waste Programs Enforcement
September 1988
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I JS£^j 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\*+Sj&* WASHINGTON, D.C 20460
,«r
OFFICE Of=
SOL.D WASTE AND EMERGENCY « = SPONS
MEMORANDUM
SUBJECT: Hazardous Waste Tank Systems Inspeci;ion Manual
x' *.? -r-
<^_ A-***?
FROM: J. Winston Porter
Assistant Administrator
TO: Regional Waste Management Division Directors
Environmental Services Division Directors
Regions I-x
Attached is 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 for
inspections of hazardous waste treatment and storage tank systems
pursuant to 51 FR 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.
Tlio manual provides an explanation of the applicability of
the tanlc system regulations in addition to:
o a complete regulatory overview; and
o detailed inspection procedures and inspection
checklists
This manual complements the March 1988 RCRA Inspection
Manual (OStfBR 9338. 2A) and expands on the inspection procedures
contained therein.
If you hAve any questions concerning the manual/ please
contact Tim KASten or Ken Gigliello, RCRA Enforcement Division,
FTS 475-9320c
Attachment
cc: Regional Counsels
Hazardous Maate Branch Chiefs
RCRA Enforcement Section Chiefs
Regions i-X
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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
1.3 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.l 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 System 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
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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.
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 inspection 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 the assessment of compliance
of a specific tank type, (e.g. concrete on-ground tank containing
50,000 gallons of liquid, sulfate bearing hazardous waste) is
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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 Hazardous 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.
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OSWER 9938.4
2.0 OVERVIEW OF HAZARDOUS WASTE TANK SYSTEM REGULATIONS
2.1 The Regulatory Approach/Framework
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 TanJc System Regulations
The regulations apply to owners and operators of facilities
that use:
o aboveground,
o onground,
o inground, and
o underground
tank systems used 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
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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 Superfund (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 KxH String TanX Systems
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
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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)J.
2.2.2 New Tgnk Systems
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 but 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
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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 must 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 Than 90—Dav Accumulation TflJflX SYfitiftMS
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:
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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)
o 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 Small Quantity 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).
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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 Exemptions
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 (§264.193 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:
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OSWER 9938.4
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
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
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OSWER 9938.4
2.4.1 Primary Containment /Tank Integrity Assessments
o tanks must be constructed with 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 Tank 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 Secondary Contajimgn't flJld Detection
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
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o capable of detecting and collecting releases
and 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
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o designed and installed to surround the tank
completely and 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 Double-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
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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 sealless 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 inspections/Operation and Maintenance
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
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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
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OSWER 9938.4
Administrator discussing the likely route of
migration of the release, characteristics of
surrounding soil (geology), results of any
monitoring or sampling and proximity to
downgradient drinking water, surface water
and population areas
o if a spill occurs that is not related to any
damage to the integrity of the tank system,
the system may be returned to service as soon
as the owner/operator removes and properly
disposes of the waste and the proper repairs
are made
o if a leak occurs from primary containment to
secondary containment the system must be
repaired prior to returning the system to
service
o if a release to the environment occurs from a
component of a tank system without secondary
containment the owner/operator must provide
the component or components from which the
leak originated with secondary containment
before returning the system to service,
unless the source of the leak is an
aboveground portion of a tank system that can
be inspected visually
o if a leak is discovered that is underground
or if a leak has occurred in any portion of a
tank system component that is not readily
accessible for visual inspection the entire
component must be provided with secondary
containment before the tank system is
returned to service
o any major repairs must be certified by an
independent, qualified, registered
professional engineer before the system can
be returned to service
In the event of a visible release to the environment the
owner/operator must immediately conduct a visual inspection of
the release and, based upon that inspection:
o prevent further migration of the leak or
spill to soils or surface water; and
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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
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- 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 Small Quant:i-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
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OSWER 9938.4
o data gathered from monitoring equipment
atleast 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 Special Wastes
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
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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 [S265.17(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 [§265.17(b)]
2-17
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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:
l. 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
li the tank
-------
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
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OSWER 9938.4
Figure 4A.
Applicability of the July 14, 1986 Hazardous Waste Tank Regulations
The generator must
comply with 2*2.34
Doot facility havo
link eyatomi mod
for tho atorage
or troatmont of
hazardous waatoa?
Voa x~
Dooa tho generator
accumulato waato
on-alto for loaa
than 90 daya?
Tho tank ayatom la
oxompt from 2*4.1*3
(••condary contalnmont
and look dotoctlon)
Tank ayatom la "now*
and muat comply
with Parti 2*4 and 2M
of lubpart J
Ar* the tank
ayatemi uied for
• torlng aecondary
matorialt mlondod
for reclamation in
a doted loop tyttom?
la tho tank ayatom
uaod for troatmont
of waatoa diachargod
undor an NPDES permit?
No
Ar* the secondary
materials ttored for
over 12 monthe In
the tank ty«l»mt?
W
1
...
Are the tanka uaod to
atoro or treat HW
which containa no free
llqulda and are altuatod
Inaldo a building with
an Impermeable floor?
Aro tho tanka uaod
aa a aecondory
contalnmont ayatom
to collect or contain
roloaaoa of HW?
No
t
No
Woro tho tonka
oporatlng or did
Inatollatlon commonco
prior to T/14/M?
Doot the generator
accumulato HW for
more than 160 daya
(or 270 daya If TSD
la >200 mllet away)?
I
Yea
Yea
No
Doet reclamation
Involve controlled
flame combuttion?
la the total amount
of HW accumulated
more than 8000 kg
at one time?
Yoa
Tank ayatem la "enletmg-
•nd muat comply
with Parta 2*4 and 2*9
of Subpart J
Yoa
y
NO
It the reclaimed
material used to
produce a fuel?
Yea
Yet
No
Tho generator muat
comply with 2*6.201
T
No
Regulation!
do not epply
4-2
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FIGURE 4B
How to Use Checklists in Appendix A
OSWER 9938.4
PRE-INSPECTION
Review facility files
and assemble appropriate
checklists
[One checklist per tank
system]
Record Review
Facility ID
SQG
Checklist I
New Tank
Checklist IV
Existing Tank
Checklist III
General Inspection
Requirements
Checklist II
ON-SITE INSPECTION
Special Wastes
Checklist V
4
Yes
Does facility
handle
ignitable
or reactive
wastes ?
Visual Inspection
Response to Release
Checklist VI
4
Yes
No I
Has there
been a
release of
waste from
the tank
system?
No
Visual Tank
Inspection
Checklist VII
Closed Tank
Checklist VIII
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 tie 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
rule, 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 will 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). S265.201(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
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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
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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
-------
OSWER 9938.4
5.2 Recordkeepina 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:
o 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.I 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 Dr 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 [§265.195(a)(1)].
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 [§264.194(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 [§264.194(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 [§264.194(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 i-s 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
-------
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 4B
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, §261.30-33, 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 [§264.193(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 [§264.193(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.l 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)(1)]. 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.l 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
[§264.191(a)(3)J.
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. Non-ent«?r?ble 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
[§264.191(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)(i)].
G.I Other Tank Types - Tank Integrity
The regulations for other tank types go into effect in
all unauthorized states. In authorized states, the
regulations go into effect after the state has amended
its statute (by 1987 or 1988) [§271.21(e)(2)].
G.la If the tank is not an underground tank the
owner/operator is required to include either a leak
test or an integrity test that is certified by an
independent, qualified, registered, professional
engineer [§264.191(a)(5)(ii)].
G.ib-G.lc
The owner/operator is required to conduct a tank
integrity test or otherwise have the overall condition
of the tank system assessed by an independent,
qualified, registered, professional engineer annually
[§264.193(1X2)]. The owner/operator must have the
results of the tests on file at the facility
[5264.193(1X4) ].
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 tank 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 §264.191(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(i)(3)]. 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.1-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)]. See
Appendix B-l 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.
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OSWER 9938.4
Secondary Containment
D.I The existence of an application for a variance will not
make any difference in the inspection of a new tank
system. Only if a variance is granted can the
inspector disregard the record review and visual
inspection relating to secondary containment.
D.2 If the facility has not been granted a variance and the
new tank system does not have secondary containment,
then the facility is clearly in violation of the
regulations.
D.3 [§264.193(d)]. See Appendix B, 17-21 for illustrations
of secondary containment systems.
D.4* The inspector should ask the owner/operator for any
records that describe the materials used for secondary
containment. This information is to be used to flag
any potential problems, such as incompatibility of
wastes for facilities that have not submitted Part B
permit applications (interim status tanks or 90-day
accumulation tanks).
D.5 A leak detection system must be provided that is
designed and operated to detect the failure of either
the primary or secondary containment structure, or the
presence of any release of hazardous waste or
accumulated liquid in the secondary system within 24
hours, or at the earliest practicable time
[§264.193(b)(3)].
Double-walled tanks must be provided with a built-in
continuous leak detection system capable of detecting a
release within 24 hours or at the earliest practicable
time [$264(d)(3)(ill)]. Commonly employed leak
detection methods are described in Appendix B-8.
D.6 The inspector should review logbooks/records over a
randomly chosen period of time to make sure that the
leak detection devices operate properly and that
facility personnel monitor leak detection points.
D.7-D.9
The inspector should note if the primary containment
system was found to be leaking into the secondary
containment. This type of leak within the tank system
does not have to be reported to EPA, however, the waste
5-13
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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 [(§264.196(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).
Aboveground 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
[§264.192(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.I 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 [5294.198(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 [§264.199(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 1 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)J.
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.
[§264.l96(a>].
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.
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OSWER 9938.4
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 will be looking for different signs of non-compliance
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 [S264.192(a>(4>].
B.2 For new underground tank systems or components, the
regulations require that the tank system must be
provided with 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 [§264.192(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 [§264.193Cb)(1)(ii) 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 [§264.193(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)].
F.4b The inspector should examine any leak detection
devices, if possible, to ensure that they are in good
working order.
F.5 Vaults [$264.193(6X2)].
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(bXD , (bXlXiv) and (bX2Xiv)J.
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 [§264.193(e)(l)].
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)(1)(iv)]. In
addition, the inspector should verify that the liner is
free of cracks or gaps [§264.I93(b)(l)(iii)]. 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.
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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 close', 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
[§264.197(b) ] .
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)].
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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 [§264.197(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.l97(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 [§264,197 (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.
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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
-------
APPENDIX A
INSPECTION CHECKLISTS
-------
HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE
Hazardous Waste Tank System Inspection
Checklist
Facility Identification
A.I
3.1
B.3
C.I
D.I
E.I
E.3
Faci 1 i ty Nane
Facility Address
State
Inspector Nane
Address (Region)
'eiephone Number
Date of inspection
3.2
B.4
B.6
City"
ip
Bailing Address (if different)
County
Nature of business; identification of operations
EPA I.D. Number
E.2
Faci 1 ity Contact
( )
Job Title
Contact Work Phone
F.I Identification of Hazardous Waste Tank Systems at this Facility
-------
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
lank volume (gallons) ian< description
(e.g. above-ground, steel, lined)
lank location (e.g. inside on cement floor, outside on aspnalt pad'
.1 Material Stored: 3e as specific as poss^ble( e.g., 2Q*.
chloride, 30* 1,1 ,-trichloroethane, 50% mineral spirits)
Hazardous *aste no. Description
3.2 Does this tank ever contain waste other than the above?
yes no
If so, list other waste:
EDA Hazardous Uaste Nunbe" Waste Description
yes no
8.3 Are hazardous wastes placed in tanks that are compatible
with the waste so that the tank or inner liner may 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
-------
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"eln"o~
Level of waste in tank each operating day
yes no~
Materials for signs of corrosion weekly
yes noT
Area around tank for spills or leaks weekly
yes no"
D. Special wastes
0.1 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 heal'.n?
yes no NA
D.2 Does the owner/operator follow appropriate procedures for reactive
of ignitab^e wastes? (See Special Wastes, Checklist VI)
yes no
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 any evidence
of spills (e.g. discoloration, dead vegetation)?
yes no
E.4 Are uncovered tanks operating with a minimum of
2 feet (60 cm) freeboard or are they equipped with
containment structure?
NA yes no
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Facility Id. Tank System Id.
I. Small Quantity Generators - Compliance with § 265.201
E.5 In tanks with a continuous feed systems,
is the system equipped with a cut-off or
by-pass system?
NA yes no
F. Preparedness and Prevention °lan Compliance
F.I Is there an emergency response plan?
yes no
c.l Internal comnunication or alarm system available
yes no
F.2 Is telephone or ot^er device capable of summoning
emergency assistance f"on local police, fire or
other emergency response tea.ms available?
yes no
P.3 Are portable fire extinguishers and spill
control equipment available and in operational
condition? yes no
-.-* Water available to supply *ater hose streams
yes no"
-------
Facility Id.
HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE
Hazardous Waste Tank System Inspection Checklist
II. Documentation of General Inspection Requirements under §264.195, 265.195
A.I Inspection plan/procedures adequately thorough in order to identify
problem areas and small leaks
yes no
A.2 Documented inspection as scheduled in permit ( ) for
overfill controls
yes no N/A
A.2a Interim status and 90-day accumulation tank systems must have the
overfill controls inspected (and documented) each operating day
yes no N/A
A.3 Documented daily inspection of aboveground portions of tank system
yes no
A.3a Use of inspection devices
yes no provide name of device used
A.4 Documented daily inspection of monitoring and leak inspection data
yes no
A.5 Documented daily inspection of construction materials of both tank system
and secondary containment, and inspection of tank location and secondary
containment for signs of erosion or releases
yes no
A.6 Confirmation of proper operation of the cathodic protection system
within six months of initial installation
yes no N/A
date of installation date of inspection
A.6a Annual inspection of cathodic protection after installation
yes no N/A
A.7 Bimonthly inspection of all sources of impressed current
yes no N/A
A.7a Method used to inspect impressed-current system
-------
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% Hethylene
chloride, 30% 1,1 ,-trichloroethane, 50% mineral spirits)
EPA Hazardous Waste Nunber 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? yesno"
C.3 Is a written assessment of tank system
integrity on file? yes no"
C.4 If assessment is 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
-------
III. Existing Tank Systems - Compliance with § 264.191, 265.191
D. 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 components
in contact with soil or water)
E.I Document describes existing corrosion protection
measures?
E.2 Type of systen 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
-------
III. Existing Tank Systems - Compliance with $ 2fi4.191, 265.191
G.2 Internal inspections
G.2a Certification by registered, professional engineer
G.2b Has the engineer checked and documented inspection
of all appropriate factors?
H.4 Have any of the leak tested tank syste'm components
been found to be leaking or unfit?
yes no
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.
-------
Facility Id. Tank System Id.
HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE
Hazardous Waste Tank System Inspection Checklist
IV. New Tank Systems - Compliance with §264.192
A. New Tank design
A.I A.2
Tank volume (gal tons) Tank typefabove-,on-,in-,be low ground)
4.3 A.4
Tank DimensionsTank shape (spherical, cylindrical,etc,
A.5 The tank is constructed with: (be as specific as possible e.g. fiberglass-
reinforced plastic, mild steel, nickel based alloy)
B. 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
-------
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.6 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
0.3 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
welded connections inspected for leaks daily?
E.3 Are all seal less 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
-------
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-
protection 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 included for this tank system.
-------
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 § 264.198
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 managenent 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
-------
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 N/A
A.2 Did the 0/0 immediately remove the tank component from service after
spill/leak?
yes no not able to verify N/A
A.3 Was waste removed from leaking component of the tank system and
from secondary containment?
yes no N/A
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 N/A
-------
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. Aboveground Portions 5 264, 265.194v'a)
A.I Metal Tanks -
Look for; Indicate Presence
Gross leakage,
l*ajor corroded areas
Deterioration (e.g blisters)
Discolored paint
Cracks
(nozzle connections, in welded seans, under rivets)
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 ringwalls
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 in vertical tanks
-------
Facility Id. Tank 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^
-------
Facility Id.
Tank System Id.
VII. Visual Tank System Inspection
0. Inspection of Ancillary Systems § 264.194
0.1 Inspect piping for the following:
Pipe bends, elbows, tees, and other restrictions
for leaks, external corrosion and rust spots
Deterioration (e.g blisters) and discolored paint
Orifice plates deteriorated
Throttle valves w/broken stems, missing handles
Wear and tear in flexible hoses
Traffic passing over noses
Vibration or swaying of pipe systems while punping
0.2 Inspect punps and compressors for the following:
Foundation cracks
Excessive vibration or cavitation of pumps
Laa'
-------
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? yes Fio~
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? yesno
F.4 Double-walled tanks: S264.193(e)(3)
F.4a If metal, is there appropriate corrosion protection
for the outer shell? Jisnb~
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
-------
Facility Id. Tank System Id.
VII. Visual Tank System Inspection
G. Corrosion Control (metal tank and metal components in-on-or underground)
"..1 °ressnce 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
r>.4 Coatf ngs or wraps
' ,4a Is the coverage complete?
yes no
•;.4b Has the cover or wrap dried, cracked or
dissolved?
yes no
Has the coating or wrap been damaged by
spills?
yes no
ft.5 Electrical isolation devices
"i.5a Are they adequate depending upon the number of
nearby, underground metal structures?
yes no
ft.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
G.7b Have the current requirements changed over time?
yes no
G.7c Is the inpressed-current system damaged?
yes no
G.7d Is the impressed-current system properly
maintained? yes no
-------
Facility Id. Tank Id.
HAZARDOUS WASTE TANK SYSTEM INSPECTION GUIDANCE
Hazardous Waste Tank System Inspection Checklist
VIII. Closure, Post-closure Care - Compliance with § 254.197
A. Tank Systems with Secondary Containment - § 254.197(a) (clean closure)
A.I Visual verification of clean closure
yes no NA
indicate if done
Tank system materials removed
Verification of proper disposal of contaminated equipment
Contaminated soils and residues disposed or treated properly
8. Tank systems that cannot be practicably decontaminated - 5 254.197(b)
8.1 Has the owner/operator demonstrated satisfactorily that all contaminated
soils cannot be removed?
yes no NA
B.2 Closure of tank site meeting § 264.310 landfill requirements
9.2a Does contaminated area have appropriate final
cover? yes no
B.2b Is owner/operator maintaining cover integrity ?
yes no
B.2c Is 0/0 monitoring ground water according to Subpart F?
yes no
C. Tank Systems without Secondary Containment - § 264.197(c)
C.I Has 0/0 prepared a closure plan for §264.197(a) and a contingency
plan for §264.197(5) which were submitted to EPA?
yes no
C.2 If the closure plans have not been submitted, are they on file
at they facility?
yes no
C.3 Is or has the facility closed this tank system at the present time?
yes no
If yes, evaluate closure with appropriate evaluation in A or B above.
-------
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
a.
Regulation Violated
'ank Systen or Component
b.
c.
d.
e.
3. Potential Problems
If the facility if applying for a permit, inspector should refer conments 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.
-------
B-2A
NATIONALLY ACCEPTED TANK DESIGN STANDARDS
Document Number
AA-ASD-1
AA-ED-33
AA-SAS-30
ACI-344R-70
ACI-350R-77
AISI-PS-268-685-5M
AISI-TS-291-582-10M-NB
ANSI B96.1
API 128
API 120
API 12F
API 620
API 650
ASME BPV-VIII-1
ASTM D 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 Helded Aluminum-Alloy
Storage 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 Helded Tanks for
Storage of Production Liquids, 7th Ed.
Recommended Rules for Design and Construction
of Large, Welded, Low-Pressure Storage Tanks
Welded Steel Tanks for Oil Storage
ASME Boiler and Pressure Vessel Code
Standard Specification for Filament-Wound
Date
1984
1981
1982
1970
1983
1985
1982
1981
1977
1982
1982
1982
1984
1980
1981
ASTM 0 4021
Glass-Fiber Reinforced Thermoset Resin
Chemical Resistant Tanks
Standard Specification for Glass-Fiber
Reinforced Polyester Underground
Petroleum Storage Tanks
1981
Continued on next page.
-------
B-2B
Document Number
AWWA-0100
NFPA 30
UL 58
Title
Standard for Welded 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 30 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-F1ber-Re1nforced Plastic 1983,
Underground Storage Tanks for Petroleum Products
-------
B-3
ORGANIZATIONS WITH UP-TO-DATE INFORMATION ON DESIGN STANDARDS
Tht Alunlnum Association (AA)
818 Connecticut Avenue, H.H.
Hashlngton. D.C. 20006
(202) 862-5100
American Concrete Institute
(ACI)
22400 West Seven Mile Road
Detroit, MI 48219
(313) 532-2600
American Petroleum Institute (API)
1220 L Street. N.H.
Hashlngton. D.C. 20005
(202) 682-8000
American Society for Testing
and Materials (ASTM)
1916 Race Street
Philadelphia. PA 19103
<215) 299-5400
American Iron and Steel
Institute (AISI>
1000 Sixteenth Street. N.H.
Washington, D.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
Qulncy, MA 02269
Publications: (800) 344-3555
American Society of Mechanical
Engineers (ASME)
Publications
22 Law Drive
Fairfield. NJ 07007
(201) 882-1167
American Water Works Association
(AWHA)
6666 Nest Qulncy Avenue
Denver, CO 80235
(303) 794-7711
Underwriters Laboratories. Inc. (UL)
333 Pflngsten Road
Northbrook, IL 60062
(312) 272-8800
-------
B-4A
COMPATIBILITY OF MATERIALS OF CONSTRUCTION HITH VARIOUS CHEMICALS
Material
Compatible Kith
Incompatible Hlth
Minerals
Sulfurlc ac1d(1>
Nitric acid
Phosphoric acid
Organic Acids
Acetic add
Bases
Sodium hydroxide
Ammonium hydroxide
FRP<2>
M11d Steel
Rubber-lined
Hydrochloric ac1d(3> FRP
FRP">
FRP
Concrete—slow disinte-
gration at 101 phosphoric
acid
FRP
FRP
Mild steel<5>
Concrete (101)
Mild steel<5)
FRp<6>
Concrete
Concrete <10t)
Mild steel
concrete. Including
steel at 101-371
hydrochloric acid
M11d steel concrete,
with 21 and 401
Nitric acid
H1ld steel
Mild steel
Mild steel<5>
Mild steel<5>
Sources:"Permit Hrlter's Guidance Manualfor Hazardous HasteTanks",U.S.
Environmental Protection Agency. EPA Contract 68-01-6515 (undated draft), pp.
8-5 through B-8.
"Effects of Substances on Concrete and Guide to Protective Treatments,"
Portland Cement Association (1981), pp. 7-11.
Footnotes at end of table.
Continued on next page.
-------
B-4b
Material
Compatible Mlth
Incompatible With
Aqueous Salts
Calcium chloride
Sodium sulfate
Copper sulfate
Ferric chloride
Sodium hypochlorlde
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—disintegration
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
Mild steel
Mild steel
Mild steel
FRP
Mild steel
Footnotes at end of table.
Continued on next page.
-------
B-4c
Material
Compatible Hlth
Incompatible Hlth
Aqueous Salts (Continued)
Alum
Solvents
Perchloroethylene
Carbon tetrachlorlde
Ethyl alcohol <11>
Methyl ethyl ketone
Acetone
Miscellaneous
Benzene
Hexane
Anlllnt
FRP
Concrete—disintegration
of concrete with Inadequate
sulfate resistance. Con-
crete products cured In
high-pressure steam are
highly resistant to sul-
fates.
FRP<8>
Concrete*9>
FRP(10)
Concrete(9)
M1ld steel/ stainless
steel, Concrete
FRP<12)
Concrete
FRP(14)
Concrete; however,
acetone may contain
acetic acid as Impurity.
FRP<16)
Concrete
Mild steel(17)
Stainless steel<18)
Mild steel
Mild steel
Mild steel
Mild steel (13
Mild steel(15>
Mild steel
FRP
FRP
M11d steel
Footnotes at end of table.
Continued on next page.
-------
B-4D
Material
Compatible Hlth
Incompatible Hlth
Miscellaneous (Continued)
Nitrobenzene
Phenol
Chlorobenzene
Naphthalene
Benzole acid
01 ethyl amine
Formaldehyde
FRP(19)
Mild steel FRP
Mild steel
Stainless steel
Concrete—slow disinte-
gration
Mild steel
Stainless steel
Mild steel<20) FRP<21>
Special metals Mild steel
(nickel-base alloys)
Mild steel<22>
FRP Mild 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 70%
concentration. H1ld steel (M.S.) Is good for concentrations from 931 to
981.
(2) Fiberglass-reinforced plastics (FRP) have been considered here.
However, there are 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 (NACE),
Houston, TX, has a graph for the compatibility of various metals for HC1
use.
(4) FRP Is good to 151 concentration.
(5) M.S. 1s good only to 25'C. 316 stainless steel (S.S.) Is recommended
for service conditions about 25*C.
(6) FRP Is .good to about 501 concentration.
(7) M.S. is Incompatible after about 51 concentration at 100*C.
(8) FRP Is good to about 25'C.
(9) Impervious concrete Is required to prevent loss from penetration, and
surface treatments are generally used.
(10) FRP Is good to about 125*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 2T to 79.5*C.
(15) M.S. is Incompatible for concentrations below 1001.
(16) FRP Is good from 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 1s 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. 1s good only at 1001 concentration and up to 100'C.
-------
B-5
COATING/LINING VS. CHEMICALS
Coating/Lining Material
GeneralIvlncompatlble Hlth
Alkyds
Chlorinated rubbers
Coal tar epoxy
Epoxy Umlne cured, polyamlde
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 acid).
ketones
Oxidizing acids, strong alkalies, miner-
al acids, ketones. aromatic hydrocarbons
Strong mineral adds, 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 Range
Typical Protective
Barrier Systems
Typical Uses
Mild
Under 40 mil
(1 mm)
Intermediate
125 to 375 mil
(3 to 9 mm)
Severe
20 to 250 mil
(1/2 to 6 ram)
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 fllied 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.
Protect
contact
cal solutions
a pH as low as
concrete In
with cheml-
havlng
4, de-
pending on the chemi-
cal.
o Protect concrete
from abrasion and
Intermittent exposure
to dilute adds In
chemical, dairy, and
food processing
plants.
o Protect concrete
tanks and floors
during continuous or
Intermittent Immer-
sion, exposure to
water, dilute adds.
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 ACI.
Continued on next page
-------
B-6B
Severity
Of Chemical
Environment
Total Nominal
Thickness Range
Typical Protective
Barrier Systems
Tvolcal Uses
Severe
20 to 280 ml 1
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
acids, strong
alkalies, and salt
solutions.
o Protect concrete from
concentrated acids or
add/solvent combina-
tions.
Other-membranes may be used depending on chemical environment.
-------
B-7A
CHECKLIST FOR TANK 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, if 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 spall ing
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.
-------
B-7B
Lined Steel Tanks*
(1) General condition of lining
—holes
—cracks
—gaps
—corrosion
—swelling
—hardness
—loss of thickness
(2) Proper positioning of liner
F1berg!ass-reInforced-plastlc Tanks
softening, 1 dentations, cracks, exposed fibers, crazing, checking*.
lack of surface resin, and delanlnatlon
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/01sadvantaqes
Thermal-
Conductlvlty
Sensors
Can monltor 11 quids In
soils
Primary advantage ,1s 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 monltor
sol Is
liquids In
Primary advantage Is the
early detection of spills.
Once a leak or spill Is de-
tected, the sensors must be
replaced. Can detect small
and large 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-Hal led
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 Conservation, "Technology
for the Storage of Hazardous Liquids—A State-of-the-Art Review"
(January 1983). p. 92.
-------
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
11 Cyanides
12 Dithiocarbamates
13 Esters
14 Ethers
15 Fluorides, Inorganic
16 Hydrocarbons, aromatic
17 Halogenated organlcs
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, phosphothioates, and phosphodlthloates
30 Sulfldes, Inorganic
31 Epoxldes
32 Combustible and flammable materials
33 Explosives
34 Polymerizable compounds
35 Oxidizing agents, strong
36 Reducing agents, strong
37 Hater and mixtures containing water
38 Hater reactive substances
Source: "A Method for Determining the Compatibility of Hazardous Hastes"
(Hatayaroa et al.. 1980).
-------
B-9B
LIST OF CHEMICAL REPRESENTATIVES BY CLASS
Class 1 Adds, mineral, non-oxidizing Class 5 Aldehydes (All Isomers)
Boric Acid
Chlorosulfonlc Add
Hydrlodlc Acid
Hydrobromlc Add
Hydrochloric Acid
Hydrocyanic Add
Hydrofluoric Add
Hydroldlc Add
Phosphoric Add
Class 2 Adds, mineral, oxidizing
Chloric Add
Chromic Add
Nitric Acid
Oleum
Perchloric Add
Sulfurlc Acid
Sulfur Trloxlde
Class 3 Acids, organic (All Isomers)
Acetic Add
Benzole Acid
Formic Add
Lactic Acid
Malelc Acid
Olelc Add
Salydllc Add
Phthallc Acid
Class. 4 Alcohols and glvcols (All
Isoatrs)
Allyl Alcohol
Chlorethanol
Cyclohexanol
Ethanol
Ethylene Chlorohydrln
Ethylene Glycol
Ethylene Glycol Monomethyl Ether
Glycerin
Methanol
Monoethanol Amlne
Acetaldehyde
Formaldehyde
Furfural
Class 6 Amides (All Isomers)
Acetamlde
Olethylamlde
Olmethylformamlde
Class 7 Amines, aliphatic and
aromatic (All Isomers)
Amlnoethanol
Aniline
01 ethyl amine
Dlamlne
Ethylenendlamine
MethyI amine
Monoethylanolamlne
Pyr1d1ne
Class 8 Azo compounds, dlazo
compounds and hydrazlnes
Dimethyl Hydrazlne
Hydrazlne
Class 9 Carbamates
Class 10 Caustics
Ammonia
Ammonium Hydroxide
Caldum Hydroxide
Sodium Carbonate
Sodium Hydroxide
Sodium Hypochlorlte
Class 11 Cyanides
Hydrocyanic Acid
Potassium Cyanide
Sodium Cyanide
Continued on next page.
-------
B-9C
Class 12 Dlthlocarbamates
Class 13 Esters (All Isomers)
Butyl Acetate
Ethyl Acetate
Methyl Acrylate
Methyl Formate
Dimethyl Phthalate
Proololaetone
Class 14 Ethers (All Isomers)
Olchloroethyl Ether
Dloxane
Ethylene Glycol Monomethyl Ether
Furan
Tetrahydrofuran
Class 15 Fluorides. Inorganic
Aluminum Fluoride
Ammonium Fluoride
Fluoroslllclc Acid
Flucsilic Add
Hydrofluorosilldc Acid
Class 16 Hydrocarbons, aromatic (Al
Isomers)
Benzene
Cumene
Ethyl Benzene
Naphthalene
Styrene
Toluene
Xylent
Class 17 Haloqtnated organic; (All
Isomers)
Aldrln
Benzyl Chloride
Carbon Tetrachlorlde
Chloroacetone
Chlorobenzene
Class 17 Halogenated organlcs (All
Isomers) (Continued)
Chlorocresol
Chloroethanol
Chloroform
D1Chloroacetone
Dlchloroethylether
Dlchloromethane (Methylene
Dlchlorlde)
Eplchlorohydrln
Ethylene Chlorohydrln
Ethylene Dlchlorlde
Freons
Methykhlorlde
Pentachlorophenol
Tetrachloroethane
Trlchloroethylene
Class 18 Isocvanates (All Isomers)
Class 19 Ketones (All Isomers)
Acetone
Acetophenone
Cyclohexanone
Dimethyl Ketone
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Qulnone (Benzoquinone)
Class 20 Hercaptans and other
organic sulfldes (All
Isomers)
Carbon Dlsulflde
Ethyl Mercaptan
Class 21 Metal comoounds. Inorganic
Aluminum Sulfate
Chronic Add
Silver Nitrate
Tetraethyl Lead
Zinc Chloride
Continued on next page.
-------
B-9D
Class 22 Nitrides
Class 23 Nitrites
Acrylonltrlle
Class 24 Nltro compounds (All Isomers)
Nitrobenzene
N1trophenol
N1tropropane
Nltrotoluene
Picric Acid
Class 25 Hydrocarbons. a]1DhatVc.
unsaturated (All Isowers)
Butadiene
Styrene
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
N1trophenol
Phenol
Picric Add
Resorclnol
Class 29 Orqanophosphates. phospho-
thloates. and phosphodl-
thloates
Malathlon
Parathlon
Class 30 Sulfldes. 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 Add
Chromic Acid
Silver Nitrate
Sodium Hypochlorlte
Sulfur Tr1ox1de
Class 36 Reducing agents, strong
Dlamine
Hydrazlne
Continued on next page.
-------
B-9E
Class 37 Hater and mixtures containing
water
Aqueous solutions and mixtures
Water
Class 38 Hater reactive substances
Acetic Anhydride
Hydrobromlc Acid
Sulfurlc Add
Sulfur Trioxlde
SOURCE: "A Method for Determining the Compatibility of Hazardous Hastes'
(Hatayama et al., 1980).
-------
Rf ACTIVIIV G»OO»
Acitft. Ml«««»4. Nwi-oiitflliN*
T
atsa.
at
It
IB
2f
2f
8T
1*0
tf
or
V*
m£J
m ȣ
rf*
i
00 HOfMUMTM «»TCMt«ICJM.<
IMTtPMll
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 Be 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
Publ1c Way or from
Nearest Important
Building on the Same
Property and Shall Not Be
Less Than 5 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 Seam3
1/2 times diameter of
tank
Approved foam
or Inertlng
system4 on
•tanks not
exceeding
150 ft. 1n
diameter^
Protection Diameter of tank
for Exposures2
1/2 times diameter of
tank
None
2 times diameter of
tank but need not
exceed 350 ft.
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
2.5 pslg
1/2 times Table 13-7
Approved
Inertlng
system4 on
the tank or
approved
foam system
on vertical
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 Hguld-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 take the form of a weak roof-to-shelf sea« to fall preferential to
any other seam.
4 See MFPA 69, Explosion Prevention Systems.
5 For tanks over 150 feet In diameter, use "Protection for Exposures" or
"None" as applicable.
SOURCE: Table 2-1, "(HFPA) 30: Flammable and Combustible Liquids Code 1984."
SI Units: 1 foot - 0.30 meters.
-------
Type of Tank Protection
B-lOc
Minimum Distance In Feet
Minimum Distance in Feet from Nearest Side of Any
from Property Line Which Public Way or from
Is or Can 8* Built Upon, Nearest Important
Including the Opposite Building on the Same
Side 'of a Public Wav Property
STABLE LIQUIDS—OPERATING PRESSURE GREATER THAN 2.5 PSIG
ANY TYPE
Protection 1-1/2 times Table A
for but shall not be less
Exposures2 than 25 feet
None 3 times 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
System3
Protection 1/2 times diameter of
for Exposure2 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 dUmeter of
tank
1 See definition, footnote 1, page B-lOb
2 Fire protection for structures 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 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.
-------
B-10D
UNSTABLE LIQUIDS
Tyoe of Tank.
Horizontal
and Vertical
Tanks with
Emergency
Relief Vent-
Ing to Permit
Pressure Not
In Excess of
2.5 pslg
Protection
Minimum Distance In
Feet from Property
Line Which Is or Can
B« Built Upon, Includ-
ing the Opposite
Side of a Public Hay
Minimum Distance In
Feet from Nearest
Side of Any Public
Hay or From Nearest
Important Bui 1 ding
on the Same Property
Tank protect-
ed with any
one of the
following:
approved water
spray; approv-
ed Inertlng;'
approved Insu-
lation and
refrigeration;
and approved
barricade
Protection for
Exposures*
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; approv-
Pressure Over ed Inertlng;1
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 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.
SOURCE: Table 2-4, "(NFPA) 30: Flammable and Combustible Liquids Code 1984.'
-------
B-lOe
Reference Table A
CLASS IIIB LIQUIDS
Minimum Distance In Feet
from Property Line Which
Is or Can Be Bui It Upon,
Including the Opposite
Minimum 01 stance In Feet
from Nearest Side of Any
Public Way or from
Nearest Important
Bui 1 ding on1the Same
Caoacltv (Gallons)
12,000 or Less
12,001 to 30,000
30,001 to 50,000
50,001 to 100,000
J 00, 001 or More
Side of a Public Wav
5
10
10
15
15
Prooertv
5
5
10
10
15
SI UnltsT 1 ft. - 0.3048 m; 1 gal. - 3.785 L.
Other Flammable or Combustible Liquids
Tank Capacity
(Gal Ions)
Minimum Distance In Feet
from Property Line Which
Is or Can Be Built Upon.
Including the Opposite
Side of a Public Way
Minimum Distance In Feet
from Nearest Side of Any
Public Way or from
Nearest Important
Building on.the Same
Property
275 or Less
276 to 750
751 to 12,000
12,001 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
15
20
30
50
80
100
135
165
175
5
5
5
5
10
15
25
35
45
55
60
Source:
Table
1984."
2-5, "(NFPA) 30: Flammable and Combustible Liquids
Update of the 1977 and 1981 editions.
Code
-------
B-11A
Factory Installed Sacrificial Anode
Sacrificial
Attached by
Manufacturer
FIGURES ARC FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE MOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS.
-------
B-11B
Sacrificial Anodo Cathodlc Protection
T«st Box
Tank
Coating
Insulatad
Bushing
[alactrte Insulation
To Qrada
Magnesium Anode In Bag
Source: Suggested Ways to Meet Corrosion Protection Codes for Underground
Tanks and Piping. The Hlnchman Company, Detroit. HI. 1981.
FIGURES ARi FOR ILLUSTHATlve PURPOSES ONLY THEY ABE MOT INTtMOEO FOR USE AS
CONSTRUCTION DRAWINGS.
-------
B-12
Impressed Current Cathodte Protection
RECTIFIER
20-6O Volt O.C.
Return Circuit
0 C Current
to Anode Bed
Anode Bed
NOTE: Pioinq not shown (or cferity
Source: Suggested Hays to M«et Corrosion Protection Codes for Underground
Tanks and Piping. The Hlnchman Company, Detroit, MI. 1981.
FIGURES ARf FOR ILLUSTRATIVE PURPOSES OMLY. THEY ARE NOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS.
-------
B-13
COMMON FORMS OF LOCALIZED CORROSION
Description
Bacterial corrosion
Contact or crevice
corroslonbetween 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 form of corrosion.
Occurs at the point of contact or crevice
and a non-metal or between two 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
(microscopic) of a metal or alloy.
boundaries
Formation of shallow depressions or deep 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
Austenltlc stainless steels
Carbon and low alloy steels
Copper
Ferrltlc stainless steels
High strength alloy steels
(yield strength 200 psl
plus)
Inconel
Lead
Magnesium
Won el
Nickel
Titanium
Water and steam; NaCl , Including sea atmospheres and
waters; air; water vapor.
Water and steam; H2S04; caustics.
Chlorides, Including FeCl2, FeCl3, NaCl; sea
environments; H2S04; fluorides; condensing steam
from chloride waters; adds.
HC1; caustics; nitrates; HNOs; HCN; molten zinc and
Na-Pb alloys; H2S; H2S04-HN03; H2S04;
seawater; water; distilled water.
Tropical atmospheres; mercury; HgN03; bromides;
ammonia; ammon fated organ Ics; acids.
Chloride, Including NaCl; fluorides; bromides;
Iodides; caustics; nitrates; distilled water; steam.
Sea and Industrial environments; water.
Caustic soda solutions; high purity water with few
ppm oxygen.
Lead acetate solutions.
NaCl, including sea environments; water and steam;
caustics; -N204; rural and coastal atmospheres;
distilled water.
Fused caustic soda; hydrochloric and hydrofluoric
adds.
Bromides; caustics; H2S04-
Sea environments; mercury; molten cadmium; stiver and
AgCl; methanols with halldes; red fuming HN03;
; chlorinated or fluorlnated hydrocarbons.
Source: Adapted from V.R. Pludek, Design and Corrosion-Control (New York, NY:
John Hlley and Sons, 1977).
-------
B-15
1. Ordinary Quick Dteconntct
2. Quick OtecoiNMct Ptu» 8*1 V«lv«
3. Dry Dlacomwct
Typ«s of Couplings
FIGURES *>lf fOn ILLUSTBATIVE PURPOSES OM(.Y THEY ARE MOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS.
-------
Relief Valve
(Overfill Vent)
B.
High
Level Transmitter
0
Emergency Overflow
to Adjacent Tank*
n
Alarm
©Level Controller
Motor Operated
Pump
Elements of an Overt!! Prevention System
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS
B-16
-------
Secondary
ContaJnmont
Llnor
Secondary Containment
for Piping
Reinforced
Concrete
Foundation
Undleturbed Soil
Not*: Volume Inelde borms
•hould b* • minimum
of 1OO% of th* tank
volura* pint th* pre-
cipitation from • 24
hour, 20 y*«r »torm
Aboveground Tank
FIGURES ARE FO« ILLUSTRATIVE PURPOSES ONLY. THEY ARE HOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS
B-17A
-------
SoM Cover
for Eroelon and
Ultraviolet
Protection
Liner or
Wasteproof
Coating
on Concrete
Secondary
Containment
Liner
Native soil
Sump or trough for
•urfaca runoff and
leak cotectton
New Aboveground Tank
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS
B-17B
-------
FIGURES ARI FOR ILLUSTRATIVE PURPOSES ONLY THEY ARK NOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS.
Submerttbte Pump
Intutatino, Union
Safety Valve
Plavllc Sleeve
Isolated Connection!
••ckllll
/
Bidding
Bolt
Secondary Containment
Liner
a
a
3
Q.
-4
at
0)
3
a
3
ID
.Pipe
Nylon intutattng
^/Bushing
-Collar
TANK
TANK
DETAIL- ISOLATED
MECHANICAL CONNECTION
DETAIL- ISOLATED NYLON
BUSHING CONNECTION
B-18
-------
Monitoring
A
Sampling
Piob«
Ml lutM (sealed)
Continuous
vapor Da»ie'
»n«J
Above
CaM 10 Place H*inloiced Cnnci«le
%r £-^£fey&£(&:>;v;^^
Multipto Tanks In a Vault
FIGURES ADE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS
B-19
-------
B-20
Sampling
Standpipe
or
Electronic
Liquid
Detection
OOUtLE-WALLEO STEEL TANK
Eiterior Protection:
Coil-tar *POKV
sacrificial anod«a;or
FRP Coa'irtg
Interstitial Space
NOTE: M«» not b« prat** tor »4actro«ite monitoring
DOU0LI -WALLED
TANK
Two Doub(*-Wa««
-------
Vapor 8*iwor
Sight
Noncorrodbig Secondary
ContalninMii Casing
bwtantansous Laak Datactor CaMa
Drain or Blow-off Valva
OtannaMy ClOMd)
Doubto-Waltod Pipe System
(Grose Section)
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY THEY ARE NOT INTENDED FOR USE AS
B-21
-------
B-22
W«l«rpr*«f fe«al«bl* Cap*-
Halt-«lott*d Pla« Wrappad with Plll*r U«t*rlal
Secondary ConlaUM««l Lin*
2'
Typical U-Tub« Placement
Grad*
Monitoring W»ll
8«condwy ContakwMot UMT
Typical Observation WeH Placement
-------
Mn0w«H Foundation
Tank
Tank 8hak Chack for mat apota,
pitting, hakMna crack a
Weida: Check for haMne
cracka, uniformity
Rtoate, Bolt* Chack format, deterioration, and
hablna cracka emanattng from hotoa
Foundation: Check for cnjmbMna,
deterioration, i
Ar«aa pf Concern In a Typical Tank Foundation
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED FOR USE AS
CONSTRUCTION DRAWINGS
B-23
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APPENDIX C
GLOSSARY
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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 Haste" 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 toxlclty, It has been shown In studies to have an oral LO 50
toxlcjty (rat) of less than 50 milligrams per kilogram, an Inhalation 1C
50 toxlclty (rat) of less than 2 milligrams per liter, or a dermal LD 50
toxlclty (rabbit) of less than 200 milligrams per kilogram or Is 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-site, 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.
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C-2
"CcMpontnt" 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 systea" or "existing component" 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-slte physical construction or Installation program has
begun; or (2) the owner or operator has entered into contractual
obligations—which cannot be 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.
"Facility" awans 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 the vertical distance between the top of a tank, or
surface impoundment dike, and the surface of the waste contained therein.
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C-3
"Groundwater" means water below the land surface In a zone of saturation.
"Incompatible waste" means a hazardous waste which Is unsuitable for:
(1) placement In a particular device or facility because 1t 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 In 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 265.193(g)(2), a new tank system Is
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
bottom 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 systea" means a hazardous waste storage or treatment tank and Its
associated ancillary equipment and containment system.
"Underground tank" (UGT) means 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.
"Zone 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 D
REFERENCES
-------
OSWER 9938.4
Synopsis of Pertinent References
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.
Design & Development of a Hazardous Waste Reactivity
Testing Protoco.1. 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.
Draft Guidance for Subpart 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.
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 Treatment. Storage and Disposal Facilities, 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
Faci1itv 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 Waste
Tank Systems, 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 and
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 Reviewf 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 state-
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-
the-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 14. 1986
Hazardous Waste Tank System Regulatory Amendments f
(August 1987), US EPA, OSWER Policy Directive #9438.00-3,
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 9938.4
15. Compilation of Persons Who Design. Test. Inspect, and
Install Storage Tank Systems. (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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