Category: Q&A

Hazardous Waste: Property Owner/Operator

Q. A company on my property has generated hazardous waste from past operations (subsurface cleanup) and I’m wondering if I must be identified as the legal owner and operator on the forms for the EPA ID Number and subsequent Biennial Reporting.


What Is the Status of the RICE NESHAP (Subpart ZZZZ) Following the 2015 Vacatur of Certain Emergency Engine Provisions?

Q: On May 1, 2015, the U.S. Court of Appeals for the District of Columbia Circuit issued a decision on 40 CFR Part 63, Subpart ZZZZ vacating the 100-hour exemption for emergency generators participating in demand response from having to meet the more stringent emission limits, control device requirements, and/or work practice requirements applicable to […]


Do I Need to Install a Leachate Collection System?

Q. Is installing a leachate collection system required by the EPA for a solid waste landfill? A. It is most likely that either the EPA or a state environmental agency will require a leachate collection system in a solid waste landfill.


What are the PCB Handling and Disposal and Notification Requirements?

Q. What are the requirements for PCBs handling and disposal? What are the appropriate EPA and state agency notification requirements when the PCBs at greater than 50 parts-per-million (ppm) are discovered in an aboveground storage tank (AST) storing Fuel #2 and located at the Petroleum Bulk Storage Facility? A. An aboveground storage tank (AST) storing […]


Where Can I Find a Listing of Thresholds or Limits of Metals/Chemicals Signifying Our Separated Solids as Hazardous?

Q. We have a triple basin collection system on our city sewer line that allows solids and oils to separate out, leaving just the water to continue on to the city. We have the solids tested at a local lab, but I am having trouble finding a listing of thresholds or limits of metals/chemicals signifying […]


Should 9,500 Pounds of 1-Bromopropane Used at a Facility Be Included in the TRI Report?

Q. If a facility uses 9,500 pounds (lb) of 1-bromopropane for reporting year 2016, should it be included in the Toxics Release Inventory (TRI) report? A. 1-bromopropane is on the list of chemicals required to be included in the 2016 Toxic Release Inventory (TRI) reports.  However, the facility described in the question would not be […]


Where Can I Find a List of Toxicity Contaminants and Their Thresholds?

Q. Where can I find a list of thresholds for metal/chemicals to use to determine if the sludge-type waste from the triple basin collection system on our city sewer line is hazardous? A. From your question, we infer that you have already determined that your waste is not a listed hazardous waste and that you […]


How Often Do I Need to Conduct Opacity Monitoring on My Boilers?

Q. I have an Illinois Title V permit and we run three boilers with two firing natural gas and one we blend natural gas and biogas. We have the ability to use diesel and oil as well, but we simply do not use these. Although, we keep them on our permit just in case we […]


Do SQGs Need to Inspect Container Areas If There Are No Containers Present and for How Long Do Weekly Inspection Logs Need to be Kept?

Q. As a small quantity generator (SQGs), we know that our waste containers during the 180-day accumulation period must be inspected weekly. Does the area still need to be inspected weekly when there are no containers? Also, is there a record retention requirement for the weekly inspection log?