Hydraulic Lift Tank Exemption

Many California environmental consulting firms are still investigating hydraulic lifts such as one would find in a mechanic’s shop or a building elevator. The Regional Water Quality Control Board placed a permanent exemption on these tanks in 1995.

The exemption can be found HERE

One of the interesting consulting problems with the exemption is that it appears to also render hydraulic fluids as non-hazardous. The exemption states

“With regard to toxicity, a literature search revealed no reported human toxicity associated with the ingestion of petroleum or vegetable based hydraulic oils.”

There is a slight problem with that blanket exemption though; polychlorinated biphenyls (PCBs) are a regular occurrence in hydraulic oil. As such, it creates considerable debate in the minds of environmental consultants as to whether to merely go with the exemption, or investigate the PCBs.

In addition, if the hydraulic lift is investigated for PCBs, and none are discovered, yet a hydraulic leak IS discovered, does that mean the leak has to be dealt with? The exemption and it’s dismissal of health risks certainly makes this debatable.

The bottom line appears to be site-specific, as is often the case in environmental consulting. If proof can be obtained that the hydraulic lifts never contained PCBs, it could be argued that the exemption applies. Given the RWQCBs use of “natural bioattenuation” in recent years to dismiss various gasoline spills, hydraulic oil certainly appears to be of little threat to human health or the environment…