tanks

Management of Hazardous Waste in Tanks at Large Quantity Generator – 40 CFR 265.194 General Operating Requirements

The RCRA regulations for hazardous waste provide a generator of hazardous waste with four hazardous waste accumulation units, they are:

  • Containers
  • Tanks
  • Drip pads
  • Containment buildings

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A Large Quantity Generator of hazardous waste that accumulates its hazardous waste in tanks must comply with the regulations of 40 CFR 265, Subpart J – Tank Systems, referenced from §262.34(a)(ii).  A brief summary of these regulations reveals the following regulatory responsibilities for an LQG:

  • A thorough integrity assessment for existing tank systems.
  • Stringent design standards and installation requirements for new tanks.
  • Specifications for secondary containment and leak detection systems.
  • General operating requirements.
  • Inspection requirements:  frequency and scope.
  • Response to spills or leaks.
  • Requirements for tanks that are unfit for use.
  • Closure and post-closure care.  LQG is not subject to full post-closure care.
  • Special requirements for ignitable, reactive, or incompatible wastes.

A Small Quantity Generator of hazardous waste (SQG) that accumulates hazardous waste in tanks need comply solely with the requirements of 40 CFR 265.201.

This article will focus on the specific requirements of 40 CFR 265.194 – General Operating Requirements for the management of hazardous waste in a tank at an LQG. (more…)

The Requirements for Hazardous Waste in Tanks at a Small Quantity Generator

A Small Quantity Generator of hazardous waste (SQG) that treats or stores (i.e. accumulates) hazardous waste in a tank as defined in 40 CFR 260.10 – and explained in detail in an earlier article (What is a Hazardous Waste Tank?) – must comply with 40 CFR 262.16(b)(3) Accumulation of hazardous waste in tanks. (more…)

Hazardous Waste Management Unit: Tank

Pursuant to 40 CFR 262.34, a large or small quantity generator of hazardous waste (LQG or SQG, respectively) may treat or store (ie. accumulate) hazardous waste on-site without a permit in any of four hazardous waste management units:

  • Containers
  • Tanks
  • Drip Pads
  • Containment Buildings

The purpose of this article is to identify and explain what the RCRA regulations refer to as a tank for the accumulation of hazardous waste at an LQG or SQG. (more…)

What are the Requirements of 40 CFR 265.17 – General Requirements for Ignitable, Reactive, or Incompatible Wastes?

The regulations of 40 CFR 265.17, like all of those in Part 265, apply primarily to hazardous waste treatment, storage, and disposal facilities (TSDFs).  However, there are several places in the hazardous waste regulations (USEPA & authorized states) where the regulations of Part 265 are applicable to both Large Quantity Generators and Small Quantity Generators of hazardous waste, LQGs & SQGs, respectively.  Examples of this include, but are not limited to:

  • The reference to 40 CFR 265, Subpart I from §262.34(a)(1)(i) applicable to LQGs.
  • The reference to 40 CFR 265, Subpart C from §262.34(a)(4) applicable to LQGs.
  • The reference to 40 CFR 265, Subpart I from §262.34(d)(2) applicable to SQGs.

In this case, compliance with §265.17 is required for an SQG who accumulates hazardous waste in tanks.  An understanding of the requirements of this section will therefore be helpful to all generators of hazardous waste. (more…)