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West General
provides independent hazardous waste storage inspection
per EPA
RCRA Regulations § 264/265.191 and § 264/265.192 that
require an independent professional engineer. We provide
inspections for existing as well as new tanks as paraphrased
below by the EPA's "Introduction on
Tanks (40 CFR Parts 264/265, Subpart J)"
SYSTEM INTEGRITY: ASSESSMENT OF EXISTING TANKS
Most existing tanks (i.e., tanks in existence on or before
July 14, 1986) did not have to meet the technical standards
for new tanks until the tank system was 15 years old.
In order to ensure the tank's structural integrity in
the interim, § 264/265.191 requires all existing tanks
without secondary containment to be assessed for leakage
and overall fitness for use. All existing systems must
have been assessed by January 12, 1988. Tanks that become
newly regulated after July 14, 1986 (e.g., tanks holding
newly listed wastes) must be assessed within 12 months
from the date the tank became regulated.
Integrity assessments of existing tanks must verify that
the tank was designed and maintained to contain the wastes
stored or treated therein without failing, collapsing,
or rupturing. Factors to consider include original design
standards, the age of the unit, corrosion protection measures
in place, compatibility of the unit with the hazardous
wastes involved, and results of leak tests or inspections
of the tank. The written assessment results must be certified
by an independent, qualified, registered, professional
engineer and kept on file at the facility (§ 264/265.191(a)).
NEW TANK STANDARDS
In order to ensure that a tank system can hold hazardous
waste for its intended lifetime, EPA subjects all new
tank systems and components to the design and installation
requirements in § 264/265.192. Corrosion protection measures
are also mandatory for certain new tank systems and components.
As previously mentioned, the phrase "new tank system"
includes reinstalled and replacement tank systems or components.
INSTALLATION
The tank system or component must be designed with an
adequate foundation, structural support, and corrosion
protection to prevent collapse, rupture, or failure of
the unit. Seams and connections must be sealed adequately
and pressure controls must be installed if necessary to
prevent tank rupture or explosion. Owners and operators
must submit a written design assessment attesting to the
structural integrity of the tank. The design assessment
must be reviewed and certified by an independent, qualified,
registered, professional engineer and must be kept on
site (§ 264/265.192).
Because even the most flawlessly designed tanks can fail
if installed improperly, new tank systems must be inspected
prior to use by an independent qualified expert to ensure
that no damage to the integrity of the tank occurred during
installation (§ 264/265.192(b)). Should damage occur during
the course of installation, the owner and operator must
correct the problem before the installation is complete
or the system is in use. All new tanks and ancillary equipment
must be tested for tightness, and any leaks discovered
must be remedied before the tanks are covered, enclosed,
or placed in use. |
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