Hazardous Waste Management

10 Tips for LQGs for Inspecting Hazardous Waste Tanks

LQGs are those that generate either 1,000 kilograms (kg) or more of hazardous waste or more than 1 kg of acutely hazardous waste a month.

Note:

  • 1 kg = 2.2 pounds (lb)
  • 100 kg = 220 lb
  • 1,000 kg = 2,200 lb

What’s a Tank?

Although the answer may seem fairly obvious, there has been a lot of confusion from a regulatory point of view about the difference between a tank and a container.

The key difference is that a container is a portable device, whereas a tank is a management unit that remains stationary. The Resource Conservation and Recovery Act (RCRA) hazardous waste regulations define a “container” as “any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.” (This definition is intentionally broad to encompass all types of portable devices. Fifty-five-gallon drums and barrels are two common types of containers, but a container can also be a tanker truck, railroad car, small bucket, or test tube.) In contrast, a “tank” is defined as a stationary device designed to contain an accumulation of hazardous waste, which is constructed primarily of nonearthen materials that provide structural support.


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A Note About Secondary Containment for Tanks

A hazardous waste tank’s leak prevention and leak detection system is referred to as a secondary containment. Tanks used at treatment, storage, and disposal facilities (TSDFs) must have secondary containment and leak detection. LQGs must comply with the secondary containment standards for interim-status TSDFs (40 CFR 265.193) if they are accumulating hazardous waste in tanks. The accumulation time limit for hazardous waste for LQGs is generally up to 90 days, with some exceptions that you can find in 40 CFR 262.34.

10 Tips for LQGs for Inspecting Hazardous Waste Tanks

Tip 1: Inspect tanks on a routine basis to see that they are being operated and maintained in satisfactory condition.

Tip 2: Data gathered from monitoring and leak detection equipment must be inspected each operating day to ensure that the tank system is being operated according to its design.

Note: The EPA interprets the language “each operating day” as “every day the tank is in operation” (i.e., storing or treating hazardous waste) and not just on days the facility is open for business.

Tip 3: Develop and follow a schedule for inspecting tank overfill controls, and inspect at least each operating day.

Tip 4: Inspect any aboveground portions of the tank system at least each operating day for corrosion or releases of waste.


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Tip 5: Inspect the construction materials and the area immediately surrounding the externally accessible portion of the tank system, including the secondary containment system (e.g., dikes) at least once each operating day to detect erosion or signs of releases of hazardous waste.

Note: Examples of signs of releases are wet spots and dead vegetation.

Tip 6: You only have to inspect overfill controls, aboveground portions of the tank, the construction materials, and surrounding area of the tank at least weekly if you use leak detection equipment to alert facility personnel to tank leaks, or if you have implemented established workplace practices that ensure leaks are promptly identified.

Tip 7: If you use the alternate weekly schedule for inspecting overfill controls, aboveground portions of the tank, construction materials, and the area surrounding the tank, document it in your operating record for the facility. Include in the documentation a description of the established workplace practices at your facility.

Tip 8: Visually inspect tank ancillary equipment that does not have secondary containment at least once each operating day.

Tip 9: Ancillary equipment that does not require secondary containment if visually inspected daily includes aboveground piping; welded flanges, welded joints, and welded connections; sealless or magnetic coupling pumps and sealless valves; and pressurized aboveground piping systems with automatic shutoff devices.

Tip 10: Inspect any cathodic protection systems within 6 months after initial installation. After that, inspect these systems annually.