Category: Ask the Expert

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?

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.