Daniels Training Services

Posts Tagged weekly inspections

Weekly Inspections of Hazardous Waste Containers in Satellite Accumulation Areas

Mar 26

Posted by admin in RCRA Hazardous Waste Regulations | No Comments

Both Large and Small Quantity Generators of hazardous waste (LQG & SQG respectively) are required to conduct weekly inspections of their hazardous waste accumulation areas; typically referred to as Central Accumulation Areas (CAA’s) or 90 (for LQG’s) or 180 (for SQG’s) day accumulation areas.  I was recently at an LQG and was told by the EHS Coordinator that the weekly inspection took her almost 5 hours to complete.  The reason?  The inspection included more than 50 Satellite Accumulation Areas (SAA’s) distributed throughout the sprawling facility.  My observation that weekly inspections are not required for SAA’s caught her by surprise.  ”Are you sure?” she asked.

Yes I am.

The Federal regulations for managing hazardous waste in an SAA can be found at 40 CFR 262.34(c).  The baseline requirements are known to most:

  • No more than 55 gallons of hazardous waste or 1 quart of acute hazardous waste in a single SAA.
  • In a container at or near the point of generation where the waste initially accumulates.
  • Under the control of the operator of the process generating the waste.

While waste accumulates in the SAA, the generator must comply with other routine container requirements:

  • 40 CFR 265.171:  Containers in good condition.
  • 40 CFR 265.172:  Container compatible with waste.
  • 40 CFR 265.173(a):  Container kept closed except when adding or removing waste.
  • Mark container with the words “Hazardous Waste” or other words that describe the contents (check with your State on this point specifically since some require additional information to be included).

While the waste is maintained in the SAA in compliance with the above, it is not subject to the requirements of 40 CFR 262.34(a) 0r (d); these are the regulations that refer to the weekly inspection requirements of  40 CFR 265.174.  Therefore, proper maintenance of hazardous waste in an SAA precludes the requirement for weekly inspections.

Additional requirements kick-in when the SAA volume thresholds of 55 gallons for hazardous waste or 1 quart for acute hazardous waste are reached; at that point the generator must…

  • Date the container.
  • Move it to the CAA within 3 calendar days.  Note:  not 72 hours or 3 business days.
  • Once moved to the CAA, the generator may re-date the container and then begin the 90 or 180 day accumulation time period.
  • Once moved to the CAA, the container becomes subject to all the standard hazardous waste generator requirements of 40 CFR 262.34(a).

Weekly inspections of waste containers (both hazardous waste and acute hazardous waste) are an option, not a requirement.  Decide for yourself if the benefit from inspections is worth your time and effort.  For more information about SAA’s, review this US EPA FAQ’s on the subject.

I pride myself in providing a training service that not only complies with the regulations (training is required for LQG’s at 40 CFR 265.16) but also gives you information you can use (see above) to make your job of environmental compliance easier.  Please review my schedule of open enrollment training events or contact me to schedule on-site training.

Tags: , , ,

Weekly Hazardous Waste Inspections

Dec 26

Posted by admin in Compliance and Enforcement, RCRA Hazardous Waste Regulations | No Comments

You may conduct a variety of inspections at your facility:  quality control and regulatory standard, recommended and required, documented and undocumented.  If you generate a hazardous waste, conducting periodic inspections of certain critical risk areas is a good idea.  If you are a Large Quantity Generator or a Small Quantity Generator of hazardous waste, you are required to conduct weekly inspections of your hazardous waste accumulation containers. I will use this article to address the weekly inspection requirements required by US EPA regulation for accumulation containers of hazardous waste at LQG’s & SQG’s, it will not address…

  • The inspection requirements for tanks.  For more information on these management units an LQG should refer to 40 CFR 265.195 and an SQG should refer to 40 CFR 265.201.
  • The inspection requirements for the two remaining hazardous waste management units after tanks and containers:  Drip Pads [40 CFR 262.34(a)(iii)] and Containment Buildings [40 CFR 262.34(a)(iv)].
  • The inspection requirements of individual states, I will explain the regulations of the US EPA only.  Check with your State for clarification of these regulations unless you reside in Iowa, Alaska, or Puerto Rico since they lack approved programs to enforce RCRA.

To fully understand the inspection requirements it helps to appreciate the path that leads you to it.  You begin at 40 CFR 262.34(b) for an LQG and 40 CFR 262.34(d)(2) if an SQG; these are the accumulation time limit regulations for hazardous waste generators and are the starting point for most regulations applicable to generators of hazardous waste.  In this case both regulations point to 40 CFR 265.174—Inspections which is part of Subpart I—Use and Management of Containers.  40 CFR 265 is designed for Treatment Storage and Disposal Facilities (TSDF’s) that do not yet have a permit – thus “interim” – however, many times LQG’s and SQG’s are subject to these requirements as well.

At 40 CFR 265.174 you find this:  At least weekly, the owner or operator must inspect areas where containers are stored, except for Performance Track member facilities, that must conduct inspections at least once each month, upon approval by the Director. To apply for reduced inspection frequency, the Performance Track member facility must follow the procedures described in §265.15(b)(5) of this part. The owner or operator must look for leaking containers and for deterioration of containers caused by corrosion or other factors. Let’s take a look at this succinct and critical regulation one piece at a time.

“At least weekly…” - The US EPA does not define what weekly means; it has left the clarification of its meaning to the individual states.  However, based on conversations with State and Federal agents, it is safe to assume that this does not mean once per calendar week, but rather:  every seven days.  In other words, if you complete an inspection on Wednesday December 21st and the next week on Thursday December 29th, eight days separate the inspections and you have committed a violation.  Also, the regulations do not say anything about suspending the requirement during facility shut-downs (either planned or unplanned).  Therefore, the weekly – every 7 days – inspections must be completed even when you are shut-down for the holidays or maintenance if you have hazardous waste on-site.

“…inspect areas where containers are stored,” – This applies to anywhere within your facility that hazardous waste is generated, treated, accumulated, or stored; with one exception:  it does not apply to containers in satellite accumulation areas since 40 CFR 262.34(c) does not make compliance with 40 CFR 265.174 a requirement for hazardous waste containers managed in an SAA.  A container is defined at 40 CFR 260.10 as:  any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Thus it could include anything from a test tube to a 500-gallon portable tank to a 5,000-gallon tank mounted on a transport vehicle.

“…except for Performance Track member facilities…” – Forget it.  The National Environmental Performance Track is kaput.  Read its obituary here.

“…must look for leaking containers and for deterioration of containers caused by corrosion or other factors…” – The sole reason for the inspection is to determine the condition of the containers.  However, I recommend you take advantage of this opportunity to confirm your compliance with the following requirements as well:  labeling, date of accumulation, closed containers, condition of containment system (if required by your state), emergency communication and response equipment (as applicable), warning signs, and adequate aisle space.  Be sure to correct any errors you may find immediately and document the response action you take.  If damaged containers are found you must immediately transfer or manage the waste per 40 CFR 265.171.

Interesting that there is no requirement for generators of hazardous waste to document inspections or keep a log.  However, your state may require some form of documentation to prove you have been completing inspections as required.  I recommend you document your inspections and maintain records for at least three years.

Besides fulfilling the regulatory requirement, completion of a weekly inspection of your hazardous waste containers (I recommend you include SAA’s) is a good way to maintain regulatory compliance and provide a safe work environment.  Employees who complete these inspections should receive training on the applicable regulations and what it is they should be looking for.  Contact me if you wish for me to provide this training on-site for a flat fee of $1,749 or check out my schedule of nationwide public training events.

Tags: , , , ,

Weekly Inspections of Hazardous Waste Accumulation and Storage Areas

Dec 26

Posted by admin in Compliance and Enforcement, RCRA Hazardous Waste Regulations | No Comments

You may conduct a variety of inspections at your facility:  quality control and regulatory standard, recommended and required, documented and undocumented.  If you generate a hazardous waste, conducting periodic inspections of certain critical risk areas is a good idea.  If you are a Large Quantity Generator or a Small Quantity Generator of hazardous waste, you are required to conduct weekly inspections of your hazardous waste accumulation containers. I will use this article to address the weekly inspection requirements required by US EPA regulation for accumulation containers of hazardous waste at LQG’s & SQG’s, it will not address…

  • The inspection requirements for tanks.  For more information on these management units an LQG should refer to 40 CFR 265.195 and an SQG should refer to 40 CFR 265.201.
  • The inspection requirements for the two remaining hazardous waste management units after tanks and containers:  Drip Pads [40 CFR 262.34(a)(iii)] and Containment Buildings [40 CFR 262.34(a)(iv)].
  • The inspection requirements of individual states, I will explain the regulations of the US EPA only.  Check with your State for clarification of these regulations unless you reside in Iowa, Alaska, or Puerto Rico since they lack approved programs to enforce RCRA.

To fully understand the inspection requirements it helps to appreciate the path that leads you to it.  You begin at 40 CFR 262.34(b) for an LQG and 40 CFR 262.34(d)(2) if an SQG; these are the accumulation time limit regulations for hazardous waste generators and are the starting point for most regulations applicable to generators of hazardous waste.  In this case both regulations point to 40 CFR 265.174—Inspections which is part of Subpart I—Use and Management of Containers.  40 CFR 265 is designed for Treatment Storage and Disposal Facilities (TSDF’s) that do not yet have a permit – thus “interim” – however, many times LQG’s and SQG’s are subject to these requirements as well.

At 40 CFR 265.174 you find this:  At least weekly, the owner or operator must inspect areas where containers are stored, except for Performance Track member facilities, that must conduct inspections at least once each month, upon approval by the Director. To apply for reduced inspection frequency, the Performance Track member facility must follow the procedures described in §265.15(b)(5) of this part. The owner or operator must look for leaking containers and for deterioration of containers caused by corrosion or other factors. Let’s take a look at this succinct and critical regulation one piece at a time.

“At least weekly…” - The US EPA does not define what weekly means; it has left the clarification of its meaning to the individual states.  However, based on my experience, it is safe to assume that this does not mean once per calendar week, but rather:  every seven days.  In other words, if you complete an inspection on Wednesday December 21st and the next week on Thursday December 29th, eight days separate the inspections and you have committed a violation.  Also, the regulations do not say anything about suspending the requirement during facility shut-downs (either planned or unplanned).  Therefore, the weekly – every 7 days – inspections must be completed even when you are shut-down for the holidays or maintenance if you have hazardous waste on-site.

“…inspect areas where containers are stored,” – This applies to anywhere within your facility that hazardous waste is generated, treated, accumulated, or stored; with one exception.  It does not apply to containers in satellite accumulation areas since 40 CFR 262.34(c) does not make compliance with 40 CFR 265.174 a requirement for hazardous waste containers managed in an SAA.  A container is defined at 40 CFR 260.10 as:  any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Thus it could include anything from a test tube to a 500-gallon portable tank to a 5,000-gallon tank mounted on a transport vehicle.

“…except for Performance Track member facilities…” – Forget it.  The National Environmental Performance Track is kaput.  Read its obituary here.

“…must look for leaking containers and for deterioration of containers caused by corrosion or other factors…” – The sole reason for the inspection is to determine the condition of the containers.  However, I recommend you take advantage of this opportunity to confirm your compliance with the following requirements as well:  labeling, date of accumulation, closed containers, condition of containment system (if required by your state), emergency communication and response equipment (as applicable), warning signs, and adequate aisle space.  Be sure to correct any errors you may find immediately and document the response action you take.  If damaged containers are found you must immediately transfer or manage the waste per 40 CFR 265.171.

Interesting that there is no requirement for generators of hazardous waste to document inspections or keep a log.  However, your state may require some form of documentation to prove you have been completing inspections as required.  I recommend you document your inspections and maintain records for at least three years.

Besides fulfilling the regulatory requirement, completion of a weekly inspection of your hazardous waste containers (I recommend you include SAA’s) is a good way to maintain regulatory compliance and provide a safe work environment.  Employees who complete these inspections should receive training on the applicable regulations and what it is they should be looking for.  Contact me if you wish for me to provide this training on-site for a flat fee of $1,749 or check out my schedule of nationwide public training events.

Tags: , , , ,