Category: Ask the Expert

Biennial Reporting

Q. Our company is a 3rd party warehouse company. We have various customers and each one holds their own EPA ID number at our site. One customer is a Large Quantity Generator (LQG). Are there any regulations that specify that both us and our customer must submit the biennial report?

SPCC Plans and Secondary Containment Options for Mobile Tanks

Q. If we have an independent contractor come to our facility for 60 days each year with a 4000-gallon diesel tank, will we need to add their tank to our plan or have them develop a plan? What options do we have for secondary containment for mobile tanks?

The Kst Value for Dust

Q. Can a Hazardous Waste determination be made for dust waste using only the Kst value (ASTM Standard Test Method E 1226)?

Q&A: Climbing Ladders

Recently, a subscriber asked us the following question: Is there a requirement for using rungs versus rails when climbing on fixed vertical ladders or portable step/extension ladders?

Hydraulic Reservoirs

Q. Why are “process” tanks like hydraulic reservoirs considered as storage in the calculations?

Q&A: Industrial Hygiene Surveys

Recently, a subscriber asked us the following question: How long should industrial hygiene surveys be kept on file? This was our response:

Placards for Shipping

Q. Is there a threshold for placarding a trailer shipping compressed acetylene gas cylinders? I was told that if the cylinder and gas met or exceeded 1,000 pounds the trailer or vehicle transporting the cylinders would require placarding.

Secondary Containment

Q. Would the interior of a building count as a secondary containment area if you can assure the nothing can leak out?