Category: Ask the Expert

Flammable Substance Threshold

Q. Would the risk management plan (RMP) flammable substance exemption include warehouses? We will store cans of foam containing isobutane. Will the RMP regulations apply?

Identifying EHSs

Q. How do I identify extremely hazardous substances (EHSs) and hazardous substances on EPA’s List of Lists and SDSs?

Shipping Aerosols

What type of protective cap must be placed on aerosols if you don’t remove the nozzle? Is this the case if they are shipped in a 55 gallon drum? Or only if shipped loosely?

Turpentine Storage

Q. Is turpentine covered under Spill Prevention, Control, and Countermeasure (SPCC) and what are the spill containment requirements for AST of turpentine?

SPCC: PE Certified Revision Required

Q. Does replacing a 1000 gallon UST with an 8000 gallon UST in the same location require a PE-certified revision to the SPCC Plan if nothing else has changed at the site?

Wastewater Exemption

We treat our compressor condensate prior to discharge using this a crude oil water separator in a 55 gallon drum that has a 24 gallon oil storage compartment. Does the wastewater exemption apply? We are assuming that you are regulated under the federal Spill Prevention, Control and Countermeasure (SPCC) regulations, and that your facility meets […]

Exclusions to RCRA

Q. Does the addition of a spent material to wastewater treatment qualify for an exclusion to RCRA’s hazardous waste regulation?