Category: Ask the Expert

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?

Hazardous Waste Determinations

Q. We generate F006 filter cake that we ship to a recycling facility that recycles 100% of the waste. As a small quantity generator, must we include this hazardous waste toward our 1,000 kg allowed per month or is this exempt because it’s recycled?

Is this Tank Subject to RCRA?

Q. The wrong feedstock was placed in Tank A which holds a different one. The resulting mixed ignitable material (D001) is not usable. We intend to move this mixture out of Tank A quickly. Is Tank A subject to RCRA, or is it still a product tank?

What is Considered Oil?

Q. What is considered “oil?” I have had some conversations with the EPA that the Coast Guard’s list of regulated oils is broad, including automotive gas, hexane, mineral spirits, jet fuel, etc.

Closure Plan

Q. Are there compliance issues that would prevent our installation of a compressor on a concrete slab on which our (now clean-closed) RCRA-permitted hazardous waste boiler sat? Our Closure Plan states that we will close the slab when the facility closes.

Spills During Delivery

Q. If there is a spill of 50 gallons during delivery, do we need to add that in the spill history in the Spill Prevention, Control, and Countermeasure (SPCC) Plan?

Q&A: Storage of DEF Fuel Additives

Recently, one of our subscribers asked the following question: Are there any regulations regarding the storage of DEF fuel additives? This was our answer:

Q&A: Eyewash Locations

Recently, one of our subscribers asked the following question: Is there anywhere specific an eyewash station needs to be placed in a facility? This was our answer: