Inspection requirements

• At least once a week, SQGs and LQGs must inspect container storage areas visually for leaking and deteriorating containers.
• EPA requires LQGs to develop a written schedule for inspecting all of their monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment.

Container storage areas: At least once a week, small quantity generators (SQGs) and large quantity generators (LQGs) must inspect container storage areas visually for leaking and deteriorating containers.

General inspection requirements: At 265.15, the Environmental Protection Agency (EPA) says the owner or operator must inspect the facility for malfunctions or deterioration, operator errors, and discharges which could cause or lead to:

• A release of hazardous waste to the environment or
• A threat to human health.

Conduct these inspections “often enough” to identify problems in time to correct them before they lead to any harm.

Written inspection schedules and recordkeeping

EPA requires LQGs to develop a written schedule for inspecting all of their monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment.

Keep the schedule at the facility.

The schedule has to identify the types of problems that will be looked for during the inspection (e.g., sump pumps that aren’t working, leaking fittings, etc.). How often the company conducts facility inspections may vary, but it should be based on the type of equipment used and the probability of an environmental or human health incident if the equipment malfunctions or operator error goes undetected between inspections.

Areas that are subject to spills, such as loading and unloading areas, must be inspected daily when in use.

Recordkeeping requirements for inspections are detailed in 265.15(d). The owner or operator must record inspections in a log, including the date and time of the inspection, the name of the inspector, observations made, and the date and nature of any repairs. These records must be kept for a minimum of three years from the date of inspection.