Category: Ask the Expert

SPCC: Trucking Terminal

Q. Does a trucking terminal need an SPCC plan? A. Although the SPCC regulations are geared to non-transportation-related facilities, in the transportation sector, SPCC rules also apply to many terminals and maintenance facilities, depending on their location and the amount of oil stored on site. A trucking terminal is subject to the rule if it […]

SPCC: Secondary Containment

Q. In an automobile dealership service department, can the floor (inside of a building) or oil/water separator drains be counted as secondary containment for containers ranging from 55 gallons (gals) to 500 gals?

Used Oil Management

Q. As long as the used oil’s flash point is => 140°F, can my spent acetone (used as a degreaser) be disposed of in my onsite oily wastewater treatment facility that has two 30,000 gallon used oil tanks holding used oil sold as on-spec oil?

Reusing Drums for Transport

Q. Can we reuse drums with UN rating code Y1.5/100 to transport two hazardous wastes with the DOT UN numbers of UN1263 and NA3077?

CESQG Status

Q. Can we keep our CESQG status if we ship more than 220 lb (e.g. 400 lb) of waste accumulated over an extended period?

Boiler MACT

Q. Will a source having four large gas fired boilers with fuel oil back up trigger the Boiler Maximum Achievable Control Technology Standards (MACT) if it burns oil to avoid high natural gas prices?

The Headworks Exemption

Q. Does the headworks exemption at 40 CFR 261.3 (a)(2)(iv)(A) and (B) apply only to those spent solvents identified in the regulation? If you are below the threshold for the identified solvents, can other solvents be considered exempt?

Removing Mold

Q. Is there a single resource, which list by State, whether a licensed contractor is required to remove mold?

Hazardous Waste Manifest

Q. What EPA Hazardous Waste Number should be assigned on the Hazardous Waste Manifest when shipping for disposal un-punctured, aerosol cans with carbon dioxide propellant that are assumed to be empty of the product they were intended to spray (e.g. paint)?

Solvent Contaminated Wipes

Q. Does the solvent contaminated wipes 180-day accumulation limit mean we accumulate and send wipes for disposal within 180 days or accumulate for 180 days and store on site for another amount of time?