Page 607 - Materials Chemistry, Second Edition

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578 Waste Management Practices: Municipal, Hazardous, and Industrial
A.19.1.2 RESPONSES TO SCENARIOS
1.
(a) Containers must be labeled “Used Oil”, not “Waste Oil” (40 CFR 279.22(c)(1)).
(b) Clearly, this is not the proper method to store drums, regardless of whether they con-
tain hazardous wastes or used oil. Some of the drums have experienced corrosion and
rust damage, and some appear to have leaked. Drums should be protected from the
elements and should be kept away from water in order to prevent rusting and leaks.
According to the federal regulations:
Containers and aboveground tanks used to store used oil at generator facilities must be:
(1) In good condition (no severe rusting, apparent structural defects or deterioration)
(2) Not leaking (no visible leaks) (40 CFR 279.22(b))

(c) In some facilities, hazardous wastes such as chlorinated solvents have been stored
mixed with used oil. If the inspector is suspicious, a waste determination of the drum
contents can be ordered.
(d) There are no federal regulations that limit the quantity of used oil in storage at a facil-
ity; however, local fire departments or state agencies may establish their own limits.

2. (a) A waste determination by the generator should be made to ascertain the presence of
hazardous waste solvent with the used oil.

Before the results of the waste determination were provided, the inspector stated in his report
that “poor housekeeping was apparent at the facility, which creates the potential for a release to the
environment.” According to 264.31:

Facilities must be designed, constructed, maintained, and operated to minimize the possibility of a fire,
explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste con-
stituents to air, soil, or surface water which could threaten human health or the environment.