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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

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