RCRA Containment

[Dolemite]

I have a RCRA containment dyke that is covered with open side. It gets rainwater accumulating to a sump. The float system on the pump (manually turned on) is set so that the pump is turned off with some inches of accumulation remaining. My safety Person is telling me that by code, the sump has to be drain 'dry' every day. Totally dry is not realistic unless i send somebody out with a shop vac everyday. The pump pick up is as low as it can go but will always leave a minimal level. I can't imagine the drained dry daily is correct, its not practical. Any thoughts?

 

[fegenbush]

In my interpretation, drain-dry is a tank function. In order to do this, you install a sump. So to drain-dry the tank, take the liquid level into the sump. You are correct that it is not feasible to drain the sump dry without entering the tank.

Of course, in this case, the "tank" is the containment dyke.

 

[Duwe6]

Our RCRA interpretation is that only oil must be removed immediatly. Thus we keep a Vac Truck on-call 24/7.

However, our Operators keep the containments pumped clear of rainwater, at their convienence. It is just good housekeeping. It is not convienent to be cleaning out containment in the dark, nor is it 'safe'. If there is the slightest sheen of oil, anything in a RCRA containment has to be handled as HazMat. If the Safety guy wants it pumped at night, get him to sign off "water accumulation only - no RCRA present" prior to each pumping. Might get him to understand the reality of 'immediate pumping'.

 

[IFRs]

Tanks that need to be drain dry might have the sump outlet in the bottom of the sump so it can be truly drained dry.

 

[fegenbush]

IFRs,

Undertank piping would only be acceptable if there is minimal settlement expected. Additionally, it seems as though the tank is already in place from Dolemite's original post.

 

[zelgar]

40 CFR 264.193(c)(4) requires

Sloped or otherwise designed or operated to drain and remove liquids resulting from leaks, spills, or precipitation. Spilled or leaked waste and accumulated precipitation must be removed from the secondary containment system within 24 hours, or in as timely a manner as is possible to prevent harm to human health and the environment, if the owner or operator can demonstrate to the Regional Administrator that removal of the released waste or accumulated precipitation cannot be accomplished within 24 hours.

Your safety person is correct in saying that the regulations require it to be pumped dry. The practical solution is to try to work with the regulating authority to deal with the sump issue. The main thing they'll want is to minimize the volume of liquids remaining. How much liquids would be remiaing in the sump when it's shut off? If it's a significant amount, you may need to revise the sump design to reduce this volume.

There's several items that will be a concern for the regulator and possibly your safety person:
1. How much liquids could be remaining?
2. How were the secondary containment calculations determined and was the sump volume included?
3. What is the chemical compatibility of the RCRA wastes and the secondary containment systen. (This may be a critical factor, if you have a coating that may be deteriorated after several days of exposure to the wastes.)
4. How will the secondary containment system (e.g., coating) in the sump be inspected if there are liquids present?
5. How is the facility maintaining the secondary containment system of the rest of the tank system?
6. Is there a schedule that will work for both the facility and the regulating agency for the removal of the liquids in the sump (e.g., weekly, bi-weekly, monthly)