['Waste', 'Tank Systems']
['Hazardous Waste', 'Underground Storage Tanks', 'Aboveground Storage Tanks', 'Tank Systems', 'Waste']
10/18/2024
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Facilities that store and manage petroleum, hazardous substances, and hazardous waste in underground and/or aboveground tanks are subject to audits by EPA. What are the auditors looking for when they arrive at your facility? Use the following checklists to evaluate your compliance with federal requirements.
Typical records to review
Review tank records for leak detection performance and maintenance, including:
- Monitoring results over the last 12 months;
- Most recent tank tightness test(s);
- Manual tank gauging records;
- Copies of performance claims provided by leak detection equipment manufacturers;
- Records of recent maintenance, repair and calibration of on-site leak detection equipment;
- Records of required inspections and test of corrosion protection systems;
- Records of repairs or upgrades to UST systems;
- Site assessment results of closed USTs;
- Spill prevention control and countermeasure (SPCC) plans;
- Spill response plans;
- Results of AST integrity assessments, sampling, monitoring, inspection and repair work;
- Notification forms and registration records for all in-service, temporarily out-of service, and permanently closed tanks; and
- Financial responsibility documentation.
Typical physical features to inspect
Inspections should include:
- Bulk storage tank farms;
- Transfer terminals;
- Secondary containment structures;
- Tank peripheral piping, manifolds, filling and dispensing areas;
- Dispenser pumps and check valves;
- Tank sumps, manway areas;
- Leak detection equipment;
- Overflow alarms or other audible and visual alarms, sight gauges;
- Fill ports, catchment basins;
- Oil/water separators; and
- Cleanup equipment (e.g. absorbent materials, fuel recovery pumps, personal protective gear).
Where can I find the regulations?
Hazardous waste storage tank requirements are dependent upon the classification of the facility (e.g., small quantity generator, large quantity generator, or treatment, storage, disposal facility). Tanks at all three types of facilities are required to meet basic requirements. The regulations are found in:
Underground storage tank regulations are found in 40 CFR part 280.
Typical hazardous wastes stored in tanks include solvents, paint, contaminated antifreeze or oil, and sludges. In some states, waste oil and other substances are also classified as hazardous waste.
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['Waste', 'Tank Systems']
['Hazardous Waste', 'Underground Storage Tanks', 'Aboveground Storage Tanks', 'Tank Systems', 'Waste']
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Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.