Satellite Accumulation Gone Wrong at a Truck Shop
At a truck maintenance facility, a 55-gallon drum of spent parts-washer solvent (toluene 45%, MEK 30%, mineral spirits 25%) has been in the satellite accumulation area for 200 days. Next to it are three more 55-gallon drums of the same solvent, a 5-gallon pail of used oil, and an open 5-gallon bucket of aqueous parts-washer sludge with pH 12.7. The satellite area has no secondary containment, no dated labels, and no weekly inspections. The facility generates about 2,200 kg of hazardous waste per month and is classified as a large quantity generator. The maintenance supervisor says the solvent is 'just dirty thinner' and can go into the used-oil tank. One drum is corroding and leaving a stain on the concrete.
1. Make the hazardous waste determinations for each material and identify the applicable RCRA waste codes. Explain your reasoning.
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The spent parts-washer solvent contains toluene and MEK, both listed non-halogenated solvents, so F005 applies. It is also likely ignitable, D001, if the flash point is below 140°F. The three additional drums are the same waste stream. The aqueous sludge at pH 12.7 is corrosive, D002, because the threshold is pH greater than or equal to 12.5. The used oil in the 5-gallon pail can be managed under the used-oil exclusion of 40 CFR 279 if it is recycled and not mixed with solvent; keep it separate, label it 'used oil,' and do not put solvent into the used-oil tank because that would make the entire mixture hazardous waste and destroy the exclusion. Each container needs a documented waste determination. At 2,200 kg/month, the facility is a large quantity generator, so full LQG accumulation, contingency, training, and manifest requirements apply.
2. Identify the satellite accumulation and generator accumulation violations, including volume and time limits.
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The satellite accumulation limit is 55 gallons per waste stream, or one quart of liquid acute hazardous waste. Four 55-gallon drums equal 220 gallons, four times the limit. Once the 55-gallon limit is exceeded, the excess must be moved to central accumulation within three days, and the container must be marked with the date the limit was exceeded. The 200-day age is a violation: a large quantity generator may accumulate waste for 90 days in central accumulation without a permit, and satellite accumulation is not a long-term storage area. The containers lack the required 'hazardous waste' label and accumulation start date. The open and corroding drum violates container management requirements to keep containers closed and in good condition. The stain indicates a release. Secondary containment is not a federal satellite-area requirement, but it is required in LQG central accumulation and should be installed given the corrosion. Weekly inspections are required in central accumulation.
3. What immediate and longer-term corrective actions should be taken?
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Immediately stop adding waste to the satellite area, close and label all containers, overpack the corroding drum, clean the stain, and characterize any spilled material. Move the excess solvent to a permitted central accumulation area with containment, or ship it offsite with a manifest to a permitted TSDF. Determine whether the release is reportable under CERCLA, EPCRA, or state law. Longer term, revise satellite accumulation procedures with a 55-gallon marker, dated labels, and a three-day transfer rule. Separate used oil from solvent, install secondary containment, and start weekly inspection logs. Train maintenance staff on waste determinations and container management. Conduct a waste minimization assessment for the parts washer, such as recycling or switching to an aqueous system. Follow up with a compliance audit at 30, 60, and 90 days.