Over the past year or so we have come across several situations where facilities have replaced their flammable liquid storage tanks, which some are used as a “waste tank”. These “waste tanks” fall under EPA’s RCRA rule and apparently these tanks have to be “fully inspected” on a set frequency and when tanks sit directly on their foundation this causes some issues with a “full RCRA inspection”. So it seems that there may be a concerted effort to install new flammable waste tanks, as well as other flammable tanks, on legs so that the bottom of the tank can be visually inspected with ease. Now I am no RCRA expert, but this explanation does make sense; and I have contacted two other businesses where we have seen this and they too stated the same reasons. But each facility viewed these new tanks as a “Replacement in Kind” since the tanks were the same size, same materials of construction, same operations, same nozzle arrangement(s), etc. EXCEPT these new tanks are installed on legs, which CHANGES things considerably and an MOC should have been done. Here’s why…
Flammable Liquid Tanks on “Legs”