Search

Frequency of Hazardous Waste Tanks Self-Inspections

Posted on 7/24/2012 by James Griffin

Throughout Parts 264 and 265 of 40 CFR, the U.S. EPA requires persons who store hazardous waste, including large and small quantity generators, to periodically self-inspect waste containment units. These periodic self-inspections are your opportunity to ensure that you stay in compliance with RCRA and head off any inadvertent releases before they get out of hand.
 
Sometimes, the EPA specifies how frequently you must inspect your hazardous waste tanks, impoundments, and emissions control technology. Many of these inspection frequencies are phrased as “once each operating day”.
 
What Is an Operating Day?
For many years, the phrase was interpreted by the EPA to mean each day that hazardous waste is added to or removed from containment (i.e., each day the unit is operated). At some point, the U.S. and State environmental agencies began interpreting the term to mean each day that the unit contains hazardous waste, whether or not any is added or removed.
 
Contrast this statement from 1987:
[the] interpretation of “once each operating day” in Section 265.195 (hazardous waste tanks), to mean once each day during which manufacturing operations are being conducted, conforms with EPA’s interpretation of the term. EPA’s interpretation of the term “operating day” in Section 265.226(a)(1) (surface impoundments) is that inspections must occur on every day that any waste is placed in the surface impoundment. [To: Mr. P.E.Gerwert Manager General Motors Technical Center. From Ms. Marcia E. Williams Director US EPA Office of Solid Waste. Date: 10/16/1987 RCRA Online Number: 13063]
With this one from 2006:
“We [EPA] are changing the self-inspection frequencies for tank systems from daily to weekly at permitted and interim status treatment, storage and disposal facilities, as well as for large quantity generator (LQG) tank systems that are operated under certain conditions…Daily inspections enable tank systems, subject to subpart J, to comply with the 40 CFR 264.193(c) and 265.193(c) requirements to detect leaks and spills within 24 hours.” [Resource Conservation and Recovery Act Burden Reduction Initiative. 71 FR 16862. April 4, 2006.]
Keeping Hazardous Waste Tanks in Compliance
 
Hazardous Waste TankWhile neither statement is as clear as it could be, if the point of self-inspecting your waste accumulation units is to ensure you remain in compliance, and the EPA expects you to detect leaks and spills within 24 hours, then we can infer that a hazardous waste storage tank system must be inspected each and every calendar day during which it holds hazardous waste or that a system of work practices or automated sensors is in place to expeditiously detect leaks and spills.
 
Accurate and regular inspections are critical to effective compliance. Get the information you need about on-site storage options, reporting and recordkeeping, and more at Lion Technology’s Hazardous/Toxic Waste Management Public Workshops.
 
What techniques or procedure do you use to ensure successful tank inspections
 

Tags: hazardous, RCRA, waste

Find a Post

Compliance Archives

Lion - Quotes

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

Felicia Rutledge

Hazmat Shipping Professional

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.