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CHAPTER A UPGRADING OF TANKS BY LINING AND TANK REPAIR INTRODUCTION Chapter A describes comprehensive tank repair and lining procedures to meet the requirements of the Federal Regulation 40 CFR Part 280.21 (b) (1) (i), 280.33 (a) and 280.33 (d)(1). Chapter A provides minimum procedures for lining and repair of underground storage tanks including procedures for structural assessment of a tank to be lined. On pages 37131, 37132,and 37139 of the Federal Register,the EPA expressed the following: 1) "The first of the options for upgrading a tank is to internally line the tank in accordance with the tank repair provisions of 280.33" 2) "The submitted record of repaired tanks was found to be very good and numerous EPA contacts with tank lining users and regulators have generally confirmed the accuracy of this performance record" 3) "Data submitted and developed independently by EPA concerning field performance of tank lining indicate that if these codes* are followed,the lined tank will perform very well" *NLPA 631 or API 1631 4) 'Data developed by EPA since the proposal indicate that lined tanks rarely cause releases to the environment" 5) "Comments were also received that the addition of a cathodic protection system to a tank that was repaired by lining was not necessary and represented a significant additional expense.In view of the excellent performance record with relined tanks,EPA agrees" 6) "Lining tank interiors is another way to prevent releases due to internal or external corrosion" 7) "The EPA will allow lining alone as an upgrade alternative" Tank lining has been reported to the EPA as already having been used to repair or prevent releases in over 300,000 heating oil tanks and over 70,000 motor fuel tanks during the last 25 years. In 1987, the EPA sponsored a study of UST programs outside the U.S. which revealed that internal lining of tanks has been in wide use in Europe and Canada for the past decade.At least one major insurer of USTs in I