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TABLE OF CONTENTS
I. INTRODUCTION
II. RATIONALE FOR REGULATION
III. SUMMARY OF PROPOSED REGULATION
IV- SUMMARY, ANALYSIS, AND RESPONSE TO COMMENTS
Issue #1 - Mandated Inspection Points 5
Issue #2 - Daily Inspection Frequency 9
Issue #3 - Who May Conduct Inspections 15
Issue #4 - Correction of Identified Problems 15
Issue #5 - Recording Inspection Results 16
Issue #6 - Duplication of Other Regulations 18
V. REVISED REGULATION LANGUAGE 19
§264.15 Full Status 19
§265.15 Interim Status 20
'References 22
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I. INTRODUCTION
This is one of a series of background documents accompanying
promulgation of the first set of regulations issued under Subtitle C
of the Resource Conservation and Recovery Acu (RCRA). These regula-
tions represent EPA's initial efforts to control hazardous wastes
from the point of generation through transportation, treatment, and
storage, to the point of ultimate disposal.
This document, and the others in this series, attempt to explain
why the regulations were developed and why they have come to be
written the way they are. In so doing, EPA addresses the (a) Con-
gressional mandate for regulation, (b) the need for the regulation
based on threats and impacts to human health and the environment,
(c) precedents set by state and other federal regulations, and,
perhaps most importantly, (d) analysis of and response to the many
comments received on the proposed version of these regulations which
was published in the Federal Register on December 18, 1978.
This background document is limited to the requirements for the
conduct of inspections at treatment, storage, and disposal facili-
ties. The general approach to the inspection regulations has changed
from designation of explicit requirements in the proposed regulations
to a general requirement that owners or operators develop an inspec-
tion schedule tailored to the ir-"ividual facility. The reasons for
this change are explained later in the comment analysis section.
The general requirement that an inspection schedule be developed is
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complemented by specific minimum inspection requirements which are
contained in the regulations for each facility type (i.e., landfills,
incinerators, etc.). These minimum requirements must be made part of
the inspection schedule for the appropriate kinds of facilities. The
specific minimum requirements are discussed in the background docu-
ments dealing with the relevant facility type rather than here.
The proposed inspection regulations (December 18, 1978) were
to be required during both the interim status period and during full
status (after permitting). Interim status regulations are in force
between the effective date of the regulations (normally, six months
after promulgation) and the receipt or denial of a permit as required
by Section 3005 of RCBA. As a general guideline the Agency used the
following criteria to decide which requirements should be in force
during the interim status period:
(a) implemetable by the regulated community within the
six-month period between the time regulations are
promulgated and their effective date
(b) requires no large capital expenditures for items
which require approval as part of the permitting
process
(c) implementable directly by the regulated community
without the need for consultation with or interpre-
tation by the Agency
There were exceptions made to these criteria with good reason in
other sections of these regulations, but all of the inspection
requirements meet these general criteria. Thus, these regulations
are incumbent upon facilities during the interim status period as
well as during the permitting phase.
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II. RATIONALE FOR REGULATION
Section 3004 of RCRA states:
"... standards shall include . . . requirements
respecting . . . (2) satisfactory reporting, monitoring,
and inspection . . . ." (emphasis added).
Inspections are intended to serve as a preventive measure, to
help avert the release of contaminants that could adversely affect
public health and the environment. When such incidents occur, they
are often the result of the deterioration and subsequent failure of
equipment or structures. Such problems include dike failures result-
ing from erosion, and leaking tanks and drums caused by corrosion.
Equipment malfunctions can also create pollution incidents. For
example, level controls or sump pumps may break down, causing an
overflow. Failure of monitoring equipment makes it possible that
a pollution incident will occur which would go undetected. Natural
deterioration or vandalism may impair the security system so that
unauthorized people could enter the facility. Malfunction of safety
and emergency equipment such as fire extinguishers can render opera-
tors helpless in an emergency. Many of these conditions can be de-
tected before deterioration or before a malfunction results in an
actual pollution incident—but only if someone notices that something
has gone wrong. Even operator errors, another major cause of pollu-
tion incidents, could often be detected in time to prevent real dam-
age, if someone were looking for such problems. Examples of operator
errors that could easily be corrected if detected include flushout
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and drain valves left open on tanks after cleanup, improperly set
valves on emergency bypass systems, and alarm systems which have not
been reset. Many of these mistakes occur in the course of routine
maintenance (for example, cleaned out parts may not be tightly
sealed, inactivated alarms may not be reactivated, etc.). Periodic,
routine inspection of critical equipment would ensure that someone is
looking for faulty or deteriorating equipment, dangerous conditions
caused by operator mistakes, and spills.
Routine inspections are not a new concept. They have become
commonplace in industry and are widely used to promote safe worksite
conditions, identify areas for preventive maintenance of machinery,
and to assure that inventory supplies are adequate. The visual in-
spection regulations proposed on December 18, 1978 (43 FR 243-59004),
were intended to cause the owners and operators of hazardous waste
management facilities to extend preventive techniques to cover facil-
ities, structures, and practices which, if they fail, could damage or
harm human health or the environment.
The State of Minnesota in its hazardous waste regulations has
recognized the value of preventive inspections and has adopted re-
quirements for inspecting storage areas, tanks, etc.'l' Other
states require facilities to submit an operating plan which includes
procedures that will ensure that the facility complies with permit
conditions. Periodic inspections are often a component of these
operating plans but are not usually specifically required by state
regulations.
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III. SUMMARY OF PROPOSED REGULATION
The proposed regulation called for hazardous waste facilities to
conduct daily visual inspections of seven specific areas of the fa-
cility and its operations and to record the results of these inspec-
tions in the facility's daily operating log. The daily inspection
requirement could be relaxed for certain aspects of the facility's
operation, if the owner or operator could demonstrate that less
stringent procedures would still adequately protect human health
and the environment. The seven mandated inspection points were:
(1) storage areas, (2) dikes, (3) operating and monitoring equipment,
(4) emergency response equipment, (5) fences and barriers, (6) vege-
tation, and (7) active areas for fugitive air emissions.
IV. SUMMARY, ANALYSIS, AND RESPONSE TO THE COMMENTS RECEIVED ON THE
PROPOSED REGULATIONS
Issue #1: The Agency should not prescribe which items must be
inspected
a. Summary of Comments
1. It is best to let the management of a facility decide which
of its facility's components to inspect.
2. Inspection of some of the listed items in the standard is
inappropriate for certain facilities (e.g., inspection of
a pile of goethite).
3. For some of the listed items, inspection is of questionable
value for any facility. For example:
visually inspecting fugitive air emissions is too
imprecise to be meaningful
- inspecting vegetation for damage from facility
waste requires training in botany, a qualification
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which the personnel of waste management facilities
do not usually have
- rust and corrosion are normal; they do not warrant
noting each rust spot, since only severe rust and
corrosion present a problem
4. On the other hand, the list omits items which should
be inspected in many facilities. It may be difficult
to enforce inspection of those items as long as the
requirements remain in the form of a list. Therefore,
the inspection requirements should be rewritten simply
as a performance standard.
k* Response to Comments
The Agency agrees that some of the listed items are inappro-
priate for certain types of facilities, and that—in many cases—the
list may not include all the items that should be inspected in order
to adequately protect human health and the environment. There is a
wide variety of conditions which might harm human health and the en-
vironment, which could be detected during routine inspections. They
are not the same for each facility and will seldom be exactly the
same for any two facilities although the Agency expects that similar
facilities can reap benefits from similar inspection activities.
Within each facility, the specific areas that appropriately should
be inspected depend upon the processes, equipment, structures, and
instrumentation used, and to a lesser degree on operating procedures,
location of the facility, and types and volumes of waste. Because
of his intimate familiarity with these facets of his operation, the
facility owner or operator is in the best position to initially
decide which areas of his operation could benefit from scheduled
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inspections. The Agency will review.the operator's proposed schedule
of inspections to ensure that it is adequately protective. The
Agency believes that its function should be not so much to dictate
in the regulations exactly what things must be done, but rather to
ensure in the permitting process that what the facility proposes to
do, adequately protects human health and the environment.
To decide what facilities must do, on a case-by-case basis, the
Agency, as a result of these comments, has changed its regulatory
strategy for inspections. Instead of the Agency listing all of the
items which must be inspected, the owner or operator will be required
to draw up an inspection schedule tailored to the facility. The
schedule will contain those items which the owner or operator deter-
mines could benefit from inspections. The schedule will provide a
structure to ensure effective and efficient inspections, and will
help to ensure that important items are not overlooked or put off.
The Agency will review this schedule as part of its permit review
process and will judge whether it provides adequate protection to
human health and the environment. As a result of its experience
reviewing other schedules, the Agency should be in a position to
help management to optimize the efficiency and effectiveness of their
schedule. The Agency will not be able to provide this assistance to
facilities in interim status because there will be too many demands
on Agency personnel to evaluate permits for other facilities and
to "start up" the other facets of this complex regulatory program.
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Thus, during interim status, owners and operators will be required to
develop the plan, but they will not be required to submit it to the
Agency for review until Part B of the permit application is called
for by the Agency.
While inspection plans must be developed on a facility specific,
case-by-case basis, the Agency is aware that not all owners and oper-
ators and personnel are equally knowledgeable about potential prob-
lems at their facilities. To ensure that no obvious problem areas
are overlooked, and to ensure that plans are implemented consis-
tently, the Agency is specifying certain inspection points for spe-
cific types of facilities (landfills, incinerators, etc.). Although
these inspection points will have to be included in all inspection
schedules for applicable facilities, they will seldom, if ever,
constitute a wholly adequate inspection plan in and of themselves.
The Agency believes that virtually every facility will have its own
specific inspection points which must be identified and included in
the schedule. The inclusion of minimum requirements, however, will
help assure the neighboring public that the facility is conducting
inspections adequate to protect their health and property. Because
the requirements are specific to types of facilities, they are in-
cluded with specific facility standards, and the rationale for them
is covered in the background documents that relate to those opera-
tions .
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A final point. The Agency agrees that inspecting for fugitive
air emissions, vegetation kills, and minor rust spots may often be
unproductive. Some facilities simply have no potential for fugitive
emissions or vegetation kills because of design, wastes handled,
and/or location. However, unusual odors, the unexpected presence
of smoke, and recently killed plants and trees can all be signs of
trouble. Moreover, these are signs that can be detected by most
employees—they do not require special training in botany or other
fields. Further, rust is a problem only in specific locations and
then, normally, only if severe. Therefore, the Agency insists that
facility management inspect for the three items above wherever they
are relevant.
Issue #2: The requirement for daily inspections is unnecessary and
burdensome
a. Sirmniary of Comments
1. Frequency of inspection should be based on:
(i) The probability and potential seriousness of
the failure of the components of the facility
to be inspected. For example,
- storage areas, dikes, fences and vegetation
should only have to be inspected weekly be-
cause they are not subject to sudden change
- "low" hazard operations should only have to
be inspected monthly
(ii) The number of truckloads of waste that are received
at a facility (i.e., the more truckloads, the more
frequent should be inspections).
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(iii) The type of facility. For example, one commenter
argued that treatment and storage facilities should
be exempted from the visual inspection requirements,
since they are "active businesses," where any signs
of possible damage will be seen by the personnel
operating them.
(iv) The type of waste (and its degree of hazard) handled
at the facility. For example, mining waste opera-
tions should not be subject to the daily inspection
requirement.
(v) The remoteness of the facility. For example, a
few commenters argued that it would be extremely
burdensome and costly to require daily inspections
of oil production facilities, since they are often
remote, and may use their disposal sites only in-
frequently.
2. The requirement for daily inspections could lead to
superficial inspections.
3. The Regional Administrator should have the authority
to waive or modify the daily frequency requirement as
he considers appropriate.
4. Several comments called for alternative inspection
frequencies—for example, daily inspection of monitoring
equipment, weekly inspection of dikes, and monthly inspec-
tion of fences and equipment corrosion. Another comment
urged that facilities not be required to inspect when they
are not in operation (i.e., when closed for a holiday or
for the weekend).
b. Response to Comments
The Agency agrees that an absolute requirement for daily
inspection in all cases will result in unnecessary inspections and
could lead to their becoming superficial. Corrosion and erosion
normally occur so slowly that deterioration can be detected long
before failure occurs. Therefore, such structures as dikes, fences,
and tank walls need not be inspected daily. In other situations, if
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the facility has containment structures (such as may surround tanks
to catch overflow), redundant equipment (such as spare pumps for
critical applications), or automatic fail-safe devices (such as auto-
matic feed cutoff systems triggered by incinerator flameouts or com-
bustion chamber temperatures), inspection may not be necessary as
frequently to prevent damage that would result from a failure. In
these cases, however, inspections may be necessary to be sure that
redundant and automatic equipment and alarms are in working order.
The Agency agrees, therefore, that inspection frequencies should be
based on the potential for damage to occur from a failure, and on
rate of deterioration.
The Agency also agrees that, in most cases, the probability that
problems will occur at a facility which is closed for the weekend or
a holiday is small. Most of the problems such as equipment malfunc-
tions, operator errors, and spills do not normally occur if the
equipment is not running. This is a facility-specific situation,
however, and in the case of prolonged shutdowns, deterioration such
as corrosion and erosion will continue. Equipment and structures
susceptible to corrosion and erosion should, therefore, be inspected
even during shutdowns. Similarly, nonattended (automatic) facilities
should be inspected periodically, if a failure of any equipment com-
ponents could lead to environmental contamination or a human health
hazard.
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The Agency does not agree that the relative seriousness of
potential incidents should be a consideration in determining the
frequency of inspections. The Agency cannot agree that any damage
to human health or the environment should be allowed to occur as a
result of equipment malfunction or deterioration, or as a result of
operator error, when it can be prevented by inspections. The only
benefit to reducing the frequency of inspections is a reduction in
the cost of performing the inspections. The Agency's mandate in the
RCRA (Section 3004) is to "promulgate regulations ... as may be
necessary to protect human health and the environment." It says
nothing of basing decisions on costs or economics. Therefore, while
the Agency agrees that its regulations must be practical, protecting
the human health cannot be traded off against cost, so long as the
requirements meet a test of practicality. In any event the Agency
believes that routine inspections do not represent a major expense,
and in most cases will reduce costs. Early detection will normally
preclude the need for more costly repairs, replacement, or cleanup at
a later date when the situation has become more serious. For these
reasons, the volume of waste managed (number of truckloads), the
hazardousness of the waste, the type of facility, and the remoteness
of the facility should not be factors in determining the frequency of
inspections, except insofar as these items may increase or decease
the probability that damage (serious or not serious) will occur.
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Frequency of inspections should be based primarily on the
probability that an environmental or human health hazard will occur
if a problem (malfunction or deterioration) goes undetected. The
time delay between a malfunction and a health or environmental impact
may also be a factor, as might the rate of deterioration (corrosion,
etc.) where applicable. Unfortunately, determining probability of
hazard occurrence, time delay, and rate of deterioration requires
personal judgment. Also, these factors vary from facility to facil-
ity depending on design, operation, and wastes managed, thus the need
for flexibility in the development of a facility specific inspection
schedule.
The Agency disagrees that personnel at facilities that actively
and routinely receive and process wastes would "notice" any problems
and that, therefore, these facilities should be exempt from the in-
spection requirements. Operators would not note the malfunction of
many of the items to be inspected (fire extinguishers, for example),
unless they were specifically looking for the problem. Looking for
other potential problems such as tank corrosion or dike erosion,
is usually outside the normal job functions of operating employees.
Unless someone is specifically required to inspect the facility for
these problems, they are likely to go undetected for months, unless
a failure occurs.
The Agency agrees that absolute adherence to daily inspections
could lead to superficial inspections. Because many conditions would
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not change except over long periods, there would be a natural ten-
dency on the part of inspectors to pass over these items.
The interim status standards have been designed to stand alone,
with no interaction between the regulated community and the Agency.
As previously discussed, this is because of the personnel demands
that the permit process and other aspects of the regulatory program
place on the Agency. As a result, EPA cannot accommodate the sug-
gestion that the Regional Administrator have authority to waive or
modify these requirements during interim status. However, during
the permitting process, the Agency will review facilities' inspection
schedules. Because the schedules are to be facility-specific except
for a few fundamental requirements, these regulations provide a great
deal of flexibility which was not present in the proposed regula-
tions. This added flexibility, coupled with the elimination of man-
datory daily inspections, eliminates the need for waiver provisions.
To sum up, as a result of comments, the Agency has modified the
inspection standard for interim status to allow owners and operators
to schedule inspections according to their perception of the rate of
deterioration and on their perception of whether an environmental or
human health incident is likely to occur if a malfunction goes un-
detected. Thus, different frequencies of inspection can be adopted
for different inspection points. In some cases, EPA has specified
minimum acceptable frequencies for certain facilities. These have
been included in the sections of the subpart which spell out the
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requirements for specific kinds of facilities, and are discussed in
the corresponding background documents. Inspection frequencies must
be spelled out by the owner or operator in the inspection schedule.
Issue #3: Change "owner/operator" to "owner/operator or responsible
designee(s)."
a. Summary of Comments
The owner or operator may not physically be onsite at all times.
Therefore, the language "owner/operator" should be changed to "owner/
operator or responsible designee(s)."
b. Response to Comments
The background document to the proposed visual inspection sec-
tion states that "the term 'owners and operators' refers to owners
of hazardous waste management facilities as well as operators, super-
visory personnel or other qualified personnel designated by the owner
to perform certain inspection duties." Since there is no language in
the regulations precluding it, owners or operators have the option of
using agents or designees to carry out their responsibilities. How-
ever, the owner or operator is responsible to see that requirements
for which he is designated are in fact carried out in accordance with
the regulations.
Issue #4; Remedying any deficiencies noted during visual inspection
a. Summary of Comments
The visual inspection section of the regulation should specify
that if any deficiencies are noted during the inspection, repairs
must be made promptly.
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b. Response to Comments
The background document to the proposed visual inspection sec-
tion states that "these types of incidents should be immediately rem-
edied before their effects are compounded and result in a condition
which adversely affects human health and the environment." However,
this requirement was not stated in the regulations themselves. The
Agency agrees that it makes little sense to identify problems unless
they are speedily corrected. After all, the entire purpose of the
inspection regulations is to prevent or minimize problems by early
detection. Therefore, the revised inspection standards require that
any damage or unsafe condition detected be corrected before it can
result in a pollution incident. Where a pollution incident is immi-
nent or has already occurred, repair must be accomplished immediately
and noted in the inspection record.
Issue #5: Recording the results of the visual inspection
a. S'""mary of Comments
1. Requiring a log notation of the results of the inspection
is needless paperwork.
2. The operating log should include the identity of the person
making the inspection; this will make it possible to deter-
mine at some future time who was responsible for the inspec-
pection.
b. Response to Comments
The Agency believes that recordkeeping is a sound management
practice. The inspection record will enable the Agency management
or other regulatory agencies to pinpoint when a difficulty arose,
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and perhaps assist in estimating the danger to public health and the
environment from a given incident. The requirement that a record be
kept will help ensure that inspections are carried out carefully and
are not conveniently forgotten or reduced to a superficial exercise.
The Agency believes that it will not be necessary to refer to these
records after three years, because any malfunctions and deterioration
that are not corrected will probably result in obvious damage within
that period; thus the three-year requirement for retaining the
record. As an incidental benefit, the record of inspection may help
management keep track of troublesome items, keep on top of needed
repairs, and perhaps assess the reliability of their equipment.
The Agency agrees that it may be important to know who made an
inspection. For example, during an emergency or an investigation it
may be necessary to discuss the extent or characteristics of a prob-
lem noted on the log with the inspector who observed it. Similarily,
the date and time of the inspection may prove useful in any future
investigation, in that they may relate to the extent and nature of
the problem.
We have added the date and nature of actions taken in response
to inspection observations to the information required on the inspec-
tion log. This record will document the facility's response. In the
event of a human health or environmental incident, this requirement
should assist the regulatory agencies in reconstructing a chain of
events. It will also help to ensure that repairs are made promptly,
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and not postponed or forgotten. As an incidental benefit, this rec-
ord should assist management in observing how effective and respon-
sive their maintenance program is to specific problems.
Issue #6: Duplication of other regulations
a. Summary of Comments
The visual inspection of certain components of facilities is
already required under existing regulations (e.g. , the inspection
of certain monitoring equipment under OSHA's safety regulations).
Therefore, it is unnecessary to regulate these components under RCRA.
b. Response to Comments
The Agency does not intend to duplicate the requirements of
other acts. In view of the flexibility that these regulations now
allow for the owner and operator to tailor his or her own inspection
schedule, it should be possible to develop one inspection schedule to
serve the requirements of all regulatory programs. The Agency is not
aware of any other programs that specifically cover any significant
requirements of these regulations. In any case, an owner or operator
would be in compliance with these requirements if he met more strin-
gent requirements of another regulatory program.
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V. REVISED REGULATION LANGUAGE
§264.15 General inspection requirements (General Status)
(a) The owner or operator must inspect his facility for
malfunctions and deterioration, operator errors, and
discharges which may be causing—or may lead to—(1)
release of hazardous waste constituents to the environment
or (2) a threat to human health. The owner or operator
must conduct these inspections often enough to identify
problems in time to correct them before they harm human
health or the environment.
(b) (1) The owner or operator must develop and follow a
written schedule for inspecting monitoring equipment,
safety and emergency equipment, security devices, and
operating and structural equipment (such as dikes and
sump pumps) that are important to preventing,
detecting, or responding to environmental or human
health hazards.
(2) He must keep this schedule at the facility.
(3) The schedule must identify the types of problems
(e.g., malfunctions or deterioration) which are to be
looked for during the inspection (e.g., inoperative
sump pump, leaking fitting, eroding dike, etc.).
(4) The frequency of inspection may vary for the items on
the schedule. However, it should be based on the rate
of possible deterioration of the equipment and the
probability of an environmental or human health
incident if the deterioration or malfunction or any
operator error goes undetected between inspections.
Areas subject to spills, such as loading and unloading
areas, must be inspected daily when in use.
[Comment: Part 122, Subpart B, of this Chapter requires the
inspection schedule to be submitted with Part B of the permit
application. EPA will evaluate the schedule along with the rest
of the application to ensure that it adequately protects human
health and- the environment. As part of this review, EPA may
modify or amend the schedule as may be necessary.]
(c) The owner or operator must remedy any deterioration or
malfunction of equipment or structures which the inspection
reveals on a schedule which ensures that the problem does
not lead to an environmental or human health hazard. Where
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a hazard is imminent or has already occurred, remedial
action must be taken immediately.
(d) The owner or operator must record inspections in an
inspection log or summary. He must keep these records for
at least three years from the date of inspection. At a
minimum, these records must include the date and time of
the inspection, the name of the inspector, a notation of
the observations made, and the date and nature of any
repairs or other remedial actions.
§265.15 General inspection requirements (Interim Status)
(a) The owner or operator must inspect his facility for
malfunctions and deterioration, operator errors, and
discharges which may be causing—or may lead to—•(!)
release of hazardous waste constituents to the environment
or (2) a threat to human health. The owner or operator
must conduct these inspections often enough to identify
problems in time to correct them before they harm human
health or the environment.
(b) (1) The owner or operator must develop and follow a
written schedule for inspecting all monitoring
equipment, safety and emergency equipment, security
devices, and operating and structural equipment (such
as dikes and sump pumps) that are important to
preventing, detecting, or responding to environmental
or human health hazards.
(2) He must keep this schedule at the facility.
(3) The schedule must identify the types of problems
(e.g., malfunctions or deterioration) which are to be
looked for during the inspection (e.g., inoperative
sump pump, leaking fitting, eroding dike, etc.).
(4) The frequency of inspection may vary for the items on
the schedule. However, it should be based on the rate
of possible deterioration of the equipment and the
probability of an environmental or human health
incident if the deterioration or malfunction or any
operator error goes undetected between inspections.
Areas subject to spills, such as loading and unloading
areas, must be inspected daily when in use. At a
minimum, the inspection schedule must include the
items and frequencies called for in §§265.174,
265.194, 265.2*26, 265.347, 265.377, and 265.403.
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(c) The owner or operator must remedy any deterioration or
malfunction of equipment or structures which the inspection
reveals on a schedule which ensures that the problem does
not lead to an environmental or human health hazard. Where
a hazard is imminent or has already occurred, remedial
action must be taken immediately.
(d) The owner or operator must record inspections in an
inspection log or summary. He must keep these records for
at least three years from the date of inspection. At a
minimum, these records must include the date and time of
the inspection, the name of the inspector, a notation of
the observations made, and the date and nature of any
repairs or other remedial actions.
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REFERENCES
(1) 6MCAR §4.S004(G)(3b), Minnesota Code of Agency Rules, Pollution
Control Agency, June 18, 1979.
GPO 868-067
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