In the fall of 2010, WasteXpress (a licensed hazardous waste transporter) approached representatives of the Oregon Department of Environmental Quality about a proposal to transport solvent to a secondary user. The original user was SolarWorld in Beaverton, Oregon,...
Federal regulations promulgated at 40 CFR 260.10 and at 40 CFR 279.1 define “used oil” as “any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities.” Oregon’s...
Did you know that the All Appropriate Inquiry (aka “due diligence” or “innocent purchaser”) standard now applies to persons who purchase land for any “commercial” purpose? That includes residential properties purchased as investment rentals or for development. Before...
State and municipal agencies are increasingly requiring that facilities manage their storm water discharges such that they do not exceed historical flows in duration or amount. Your facility’s last storm water permit limits probably assumed that your site was...
What’s in a name? Did you know that, according to the Department of Ecology, anything you “designate as” a dangerous waste is regulated as a dangerous waste? It has long been the practice of generators of solid waste to label certain wastes as “dangerous” (or...
Responsible Persons, no matter the magnitude or basis of their liability under Oregon’s hazardous substance cleanup law, and innocent persons (those who purchased without knowledge after AAI or who purchased under a Prospective Purchaser Agreement) who voluntarily...
The State of Oregon Department of Environmental Quality has determined that if Conditionally Exempt Small Quantity Generator Hazardous Waste is not shipped directly to a type of facility listed at 40 CFR 261.5(g)(3)(i)-(vii) that the waste loses its exemption from 40...